A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
CFPB MODIFIES REMITTANCE RULE WITH
Changes to Credit Card
On April 30, the Consumer Financial Protection Bureau modified its final remittance
rule, incorporating several changes that ABA and other trade groups requested in a
January comment letter.
2 ABA: Clarify Escrow
Rule, Small Bank
2 New Small Entity
The CFPB responded to ABA concerns by, among other things, extending the rule's
compliance deadline by 180 days to October 28 – twice the length of the originally
proposed deadline. It also reduced institutions’ liability for losses due to sender’s
3 MoFo Coverage
4 QM May Limit Access
In addition, the CFPB made optional in certain circumstances a sending bank’s
requirement to disclose fees that a recipient’s financial institution may charge. It also
made it optional for the sending bank to disclose how much tax might be deducted
before the funds reach the recipient. In place of these disclosures, the CFPB
required a simple disclaimer that foreign taxes and recipient bank fees may apply.
Read the rule. Read ABA’s comment letter.
4 Delay of Credit
4 Gift Card Preemption
ABA Staff Analysis: Remittances Final Rule
4 Proposed Guidance
on Deposit Advance
CFPB MAKES ABA-SUPPORTED CHANGES
TO CREDIT CARD RULES
5 Other Consumer
Bank Secrecy Act
The CFPB on April 29 released a final rule making it easier for stay-at-home
spouses and partners to receive credit cards in their own names. The rule amends
regulations issued under the 2009 Credit Card Act that required card issuers to
evaluate credit card applicants’ ability to repay based on their independent income
and assets. The new rule eliminates that requirement for applicants who are 21 and
older, and it permits issuers to consider income and assets to which such
consumers have a reasonable expectation of access.
5 SAR Activity Review-
By the Numbers
6 SAR Activity Review,
Trends, Trips & Issues
ABA has long sought such revisions and in a January comment letter said they
would “ensure that stay-at-home spouses and partners have access to credit cards
in their own names, as well as the ability to build their credit history, without having
to rely on the approval or control of their spouse or partner.” Read more.