Remittance Transfers

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The California Department of Financial Protection and Innovation announced last week that it has entered into a consent order with Lambda, Inc., which does business as Lambda School, to settle the DFPI’s claims that a provision in Lambda’s student financing contracts was misleading.  The consent order also resolves the DFPI’s claim that Lambda’s marketing materials were misleading. … Continue Reading

On December 21, 2020, the CFPB issued its third consent order involving violations of Subpart B of Regulation E, 12 C.F.R. §§ 1005.30 to 1005.36, the Remittance Transfer Rule (“Remittance Rule”) in the last four months and fourth order since August 2019. This most recent consent order was issued against Envios de Valores La Nacional Corp.… Continue Reading

The CFPB has issued a final rule amending its remittance rule.  The final rule is effective July 21, 2020.

The key amendments consist of the following:

  • Safe harbor threshold.  Currently, the rule’s safe harbor threshold removes from the rule’s coverage an entity that provided 100 or fewer remittance transfers in the previous calendar year and provides 100 or fewer remittance transfers in the current calendar year. 
… Continue Reading

The CFPB has issued a policy statement regarding its approach to supervision and enforcement of remittance transfers during the COVID-19 pandemic.

The EFTA, as implemented by the CFPB’s remittance rule, provides insured depository institutions with a temporary exception that allows them, under certain conditions, to disclose estimates of the exchange rate and covered third-party fees instead of exact amounts. … Continue Reading

The CFPB has entered into a settlement to resolve the lawsuit filed against it in May 2019 seeking a declaration that the CFPB’s failure to issue regulations implementing Section 1071 of the Dodd-Frank Act violates the Administrative Procedure Act and an order requiring the Bureau to promptly issue such regulations.  The plaintiffs in the lawsuit, which was filed in a California federal district court, are the California Reinvestment Coalition, the National Association for Latino Community Asset Builders, and two individual small business owners.… Continue Reading

The CFPB has proposed several amendments to its remittance rule.  Comments on the proposal must be filed no later than January 21, 2020.

The proposed amendments are:

  • An increase in the rule’s safe harbor threshold that currently removes from the rule’s coverage an entity that provided 100 or fewer remittance transfers in the previous calendar year and provides 100 or fewer remittance transfers in the current calendar year. 
… Continue Reading

Earlier this week, the CFPB announced a consent order with Maxitransfers Corporation, a remittance transfer provider that allows consumers to electronically transfer funds to people or companies in foreign countries. As the Bureau noted in its press release announcing the settlement, this is the Bureau’s first enforcement action based on violations of the Remittance Transfer Rule, 12 C.F.R.… Continue Reading

The CFPB has published a notice and request for comments seeking information to inform its consideration of possible changes to its rule on remittance transfers.  Comments are due by June 28, 2019.

The RFI sets forth a series of questions related to the following topics:

  • Expiration of the temporary exception. The EFTA provides a temporary exception set to expire on July 21, 2020, that allows insured depository institutions and credit unions to provide estimates of certain amounts required to be disclosed, such as the exchange rate and certain fees. 
… Continue Reading

The CFPB’s Winter 2019 Supervisory Highlights discusses the Bureau’s examination findings in the areas of automobile loan servicing, deposits, mortgage loan servicing, and remittances.  We discussed the Bureau’s auto loan servicing findings in a separate blog post.  In this blog post, we focus on the Bureau’s additional findings.

Although issued under Director Kraninger’s leadership, the Winter 2019 Supervisory Highlights covers examinations generally completed between June and November 2018 when Mick Mulvaney was Acting Director. … Continue Reading

The CFPB has released a “Remittance Rule Assessment Report.”  The report was issued pursuant to Section 1022(d) of the Dodd-Frank Act which requires the CFPB to conduct a review of a significant rule and publish an assessment report within five years of the rule’s effective date.  The remittance report represents the first assessment report issued by the CFPB pursuant to Section 1022(d).… Continue Reading