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ICBA Statement on New Requirements on Remittance Transfers

New Mandates Will Lead to Fewer, Costlier Consumer Options

Washington, D.C. (Aug. 8, 2012)—The Independent Community Bankers of America (ICBA) released this statement following the Consumer Financial Protection Bureau’s (CFPB) release of a final rule establishing a safe harbor from the February 2012 remittance transfer disclosure and error-resolution requirements for entities that do not provide remittance transfers in the normal course of business. The final rule provides a safe harbor to all bank and nonbank entities that consistently originate 100 or fewer remittance transfers per year.

“The new compliance burdens contained in the CFPB’s rule on remittances will result in fewer and costlier options for international transfer services. While the 100-transfer threshold is better than the originally proposed limit of 25, it will nevertheless force many community banks to no longer offer remittance services to customers. Once the threshold is exceeded, too many community banks will have no choice but to discontinue offering international transfers to consumers, rather than comply with the impractical disclosure requirements and assume the additional liability mandated by the error-resolution requirements.

“The CFPB also did not extend the effective date of Feb. 7, 2013, which is impossible for community banks to meet because they must establish agreements with upstream providers to offer compliant solutions. Moreover, these providers are still in the early stages of developing compliant solutions. ICBA urges the CFPB to extend the effective date of the rule to provide an additional two years to allow financial institutions sufficient time to create the infrastructure to comply with these requirements.

“The CFPB’s rule was intended to provide greater transparency, certainty and access to low-cost transfer services for consumers who use remittances and international transfer services. Instead, it will make providing these services dramatically costlier for community banks, resulting in fewer and costlier choices for consumers.”

For more information, visit www.icba.org/advocacy.