In November 2012, we sent you a special bulletin updating you on anticipated changes to the remittance transfer rule for international transfers expected to be proposed by the CFPB. On December 31, 2012, the CFPB issued the proposed rule. As expected, the proposed amendments relate to changes in the error resolution procedures for instances in which funds are credited to a wrong account as a result of sender error. The proposal also addresses disclosure requirements for third party fees and foreign taxes, and provides some relief by allowing remittance transfer providers to disclose the highest possible tax or fee that may be imposed. Additionally, for foreign tax disclosures, the use of foreign taxes imposed at a national level, as opposed to those taxes levied at a local, state, or sub-national level, is proposed. The comment period closed on January 31, 2013.
More recently, on January 22, 2013, the CFPB issued a final rule announcing the delay of the February 7, 2013 effective date for the rule. It is expected that the effective date will be 90 days after the December 2012 proposed changes are finalized. At present, a new effective date has not been established.