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Regulation E Expected To Add New Consumer Protections for Remittance Transfers

Mercator Advisory Group by Mercator Advisory Group
August 2, 2011
in Analysts Coverage
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Proposed changes to Reg E under the Dodd-Frank Act will likely increase disclosure requirements to consumers of remittance services. The proposed new rules are currently in a comment period; comments so far are mixed, highlighting both the potential added costs as well as consumer benefits. Final responsibility for the regulation is being assumed by the CFPB.

Some of the proposed disclosure requirements call for remittance transfer providers to disclose to the sender, before the sender pays any money, the remittance value in the currency of the recipient’s country, all fees charged in connection with the remittance transfer, and the exchange rate that will be used (to the nearest 1/100 point). Then, after sending the payment, the provider must provide the sender a series of other disclosures on the receipt. Separate notices are required for transfer providers that offer Internet-initiated remittance transfers.

Additionally, remittance transfer service providers may be required to prominently display notices describing a model remittance transfer in every storefront location that the provider owns or controls. The proposal also adds new error resolution procedures for remittance transfers. Under the proposal, the deadline for a consumer to report an error is 180 days from the promised delivery date. This notice may be oral or written, but it must contain the amount of the transfer shown in the foreign currency amount, as indicated in the receipt.

Ironically, consumer research previously conducted by the Federal Reserve found users of the services to be relatively satisfied. While it was found that disclosures made prior to transactions could be improved, post transfer communications (as well as problem resolution experiences) were generally rated as good.

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