CFPB updates remittance rule small business guide and makes “clarificatory” amendment and technical correction to rule

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The CFPB has updated its small business guide on the remittance transfer rule to reflect the changes to the rule that were made this past May dealing with the scope of the error resolution procedures, disclosure of recipient institution fees and disclosure of foreign taxes or other third-party taxes. (For a summary of the changes, see our legal alert.) The CFPB has also updated its video on the rule. The remittance rule becomes effective on October 28, 2013.

In addition to updating the guide and video, the CFPB made what it calls a “clarificatory” amendment as well as a technical correction to the final rule. In the amendment, the CFPB clarifies a provider’s duty to make a refund or, at the consumer’s request, reapply funds to a new transfer when an error occurred because the sender provided incorrect or insufficient information. The technical correction fixes a numbering error and restores an inadvertently deleted comment.

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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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