Read the consent order here

  • Source:

Treliant Takeaway:

Treliant knows Regulation E. If you need help with Regulation E compliance, we can help.

Consent Order Highlights:

The Consumer Financial Protection Bureau (CFPB) has entered into a consent order with an international remittance transfer provider for violations of the Electronic Funds Transfer Act (EFTA) and Regulation E, 12 CFR §1005, Subpart B (Remittance Rule).

According to the consent order, the provider failed to adequately comply with several Remittance Rule requirements. Compliance gaps include failures to:

  • Honor cancellation requests;
  • Refund fees due to the consumer following properly-asserted cancellation requests;
  • Develop and maintain error resolution policies and procedures;
  • Investigate error notices and make error determinations;
  • Provide written reports of its investigation findings;
  • Refund certain fees and taxes when the designated recipient does not receive funds int a timely fashion;
  • Treat international bill pay services as remittance transfers, as required by the Remittance Rule;
  • Disclose the currency in which the remittance transfer will be received;
  • Use the term “transfer fees” or a substantially similar term in certain disclosures; and
  • Disclose the data on which the remittance transfers would be available for pick-up.

In short, the remittance transfer provider failed to implement many of the consumer protections required by the Remittance Rule. As a result, the remittance provider was ordered to develop and implement a compliance plan, prepare and maintain appropriate written policies and procedures, remediate existing compliance failures, submit certain documents and reports to the CFPB, and pay a civil money penalty of $750,000.

If your institution needs assistance in ensuring your Regulation E compliance management system meets regulatory expectations, Treliant can help.