CFPB Releases Examination Procedures for Remittance Transfer Rule

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The CFPB issued examination procedures to incorporate the remittance transfer rule finalized and amended several times (see May 14, 2013 Alert). The focus of the examination procedures reportedly will be in 3 areas: (1) providing required disclosures concerning fees, exchange rate, and the amount the recipient will actually receive; (2) error resolution procedures (including notifying the consumer of the outcome); and (3) refund and cancellation rights—including refunding the full transfer amount within three days if the consumer cancels the transfer within thirty minutes of payment. To assess compliance with the remittance transfer rule, examiners will focus on compliance risk management systems, identifying specific practices that drive risk, and fact-gathering to identify potential violations of consumer law, among other areas of focus. The rule became effective October 28, 2013.

IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice contained in this informational piece (including any attachments) is not intended or written to be used, and may not be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

Topics:  CFPB, Disclosure Requirements, Remittance Transfer Rule

Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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