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Remittance Threshold to Increase

May 14, 2020 1:11 pm

A (non-COVID) regulatory amendment came along this week that you should be aware of, if only to decide it may not change anything operationally at your credit union. The CFPB finalized a rule to amend the remittance transfer rule and increase the safe harbor threshold for compliance from 100 remittances annually up to 500.

When the rule changed in 2012, a lot of credit unions adjusted their offerings to avoid having to comply with the more cumbersome requirements. Many are telling me they don’t do enough remittances to comply now, but the change may still provide some breathing room when it becomes effective on July 21 if you had been close to the previous threshold.

If you qualify as a covered provider under the rule, your credit union is required to comply with disclosure of exchange rate and third-party fees, error resolution, credits, and estimates under Reg E. Under the safe harbor, the remittance rule permits financial institutions to provide estimates of the exchange rate and fees in certain circumstances.

You can read more about the requirements in the Small Entity Compliance Guide or in the Infosight Summary. In the meantime, it might be worth ensuring your credit unions is tracking how many you are doing, if at all, so you can prove your classification under the safe harbor.


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