Read the consent order here

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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.


Lynn Woosley

Lynn Woosley is a Senior Director with Treliant.  She is a seasoned executive with extensive risk management experience in regulatory compliance, consumer and commercial credit risk, credit and compliance risk modeling, model governance, regulatory change management, acquisition due diligence, and operational risk in both financial services and regulatory environments.