The CFPB’s decision to provide an exemption for institutions that conduct 100 or fewer remittance transfers per year in its recently-issued final supplementary remittance transfer rule has not abated concerns about the compliance costs facing institutions that provide remittance services. 

In an August 16 letter to CFPB Director Cordray, 32 House members urge the CFPB to delay the effective date of the remittance rule (now set for February 7, 2013) by two years until February 2015. During that time, they want the CFPB to undertake a “comprehensive study” of how international transfers are used and the rule’s impact on pricing and product accessibility.  

The House members state that they “are very concerned that whatever price certainty and transparency that the final rule imparts will come at the cost of a significantly higher price and drastically reduced product availability.” In addition to imposing a significant fee burden on consumers, they estimate the rule will result in the exodus of thousands of providers of remittance services from the market. According to the House members, “these outcomes were clearly not intended by Congress” when it passed the provision of Dodd-Frank implemented by the CFPB’s remittance transfer rule.