The Consumer Financial Protection Bureau (CFPB) has issued a Notice of Proposed Rulemaking (NPRM) related to the Remittance Transfer Rule implemented in Regulation E (Electronic Fund Transfers Act). The Remittance Transfer Rule establishes protections for consumers sending international money transfers or remittance transfers by requiring remittance transfer providers to disclose the exact exchange rate that applies, the amount to be received by the recipient, and certain fees and other information associated with the transfer. The […]
Category: Regulation E
REMITTANCE TRANSFER RULE CONSENT ORDER
On August 27, 2019 the Consumer Financial Protection Bureau (CFPB) announced a settlement with Maxitransfers Corporation (Maxi), a company that serves consumers looking to send money overseas. This is the CFPB’s first enforcement action based on violations of the Remittance Transfer Rule, which implements the Electronic Fund Transfer Act (EFTA). Maxi provides remittance transfer services from more than 1,600 third-party locations in the U.S., such as grocery stores and pharmacies, to over 19,500 payment locations […]
PREPAID ACCOUNTS – EXAMINATION PROCEDURES
The Federal Deposit Insurance Corporation has released examination procedures for Prepaid Accounts to incorporate the Consumer Financial Protection Bureau’s (CFPB) amendments to Regulation E and Regulation Z. The examination procedures may be helpful to financial institutions seeking to better understand how examiners will evaluate an institution’s compliance with the prepaid account rule.. On October 3, 2016, the CFPB published its Final Rule for Prepaid Accounts to create comprehensive consumer protections for prepaid accounts. Specifically, the […]
COMPLIANCE RISK – READING BUT NOT ACTING
In late 2017 the FDIC’s Dallas Region Quarterly Newsletter contained an article entitled Automated Overdraft Program and One-Time Debit and ATM Opt-In Procedure Considerations. The article described a situation observed in several examinations regarding overdraft programs and the interplay with Regulation E opt-in requirements. The well-written article concluded with the following admonition, “If you self-identify violations or potential issues described in this article, management should immediately modify procedures to prevent consumer harm, identify any customers […]
USAA ENFORCEMENT ACTION
When a big bank gets hit with a big penalty I often find that community banks think it is a “big bank thing” that does not impact community banks. Big banks make the same mistakes as community banks but they do it on a bigger scale. The recent settlement between the Consumer Financial Protection Bureau (CFPB) and USAA Federal Savings Bank (USAA) is a good case in point. The CFPB found that USAA: Violated the […]