A volcanologist is a person who studies volcanoes. It must be a frustrating job; one to which I can relate. I guess I am a CFPBologist. I study the Consumer Financial Protection Bureau to try to predict when they will erupt.
The Bureau of Consumer Financial Protection (CFPB) is publishing a final rule to implement section 1073 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which creates a comprehensive new system of consumer protections for remittance transfers sent by consumers in the United States to individuals and businesses in foreign countries. The Dodd-Frank Act requires that regulations to implement certain of these provisions be issued by January 21, 2012. The final rules were approved on January 23rd and should be published soon. The Board of Governors of the Federal Reserve System (Board) issued a Notice of Proposed Rulemaking in May 2011 with the expectation that the CFPB would complete the rulemaking process. Authority to implement the new Dodd-Frank Act provisions amending the EFTA transferred from the Board to the CFPB effective July 21, 2011.
I am a lending guy. Regulation E is not a major concern in my area of emphasis. But I find these final regulations to be significant. This is first major new or revised regulation published by the CFPB. Thousands of pages of new or revised regulations are expected in the next 12 months. Some, much like Regulation E, began as proposed regulations issued by the Board, and will now become final regulations issued by the CFPB.
This may be the beginning of the major eruption of regulations expected from the CFPB. We have been watching for this type of activity since July 2011. Is this the beginning of the major eruption, or just a false tremor?
For those of you who do have to worry about Regulation E, the final rule, which is effective one year after publication, can be found at https://www.consumerfinance.gov/wp-content/uploads/2012/01/Remittances_Final_Rule_2012Jan24.pdf.
