Remittance Transfer Rule Temporary Exception Experience Interviews

1700 G Street, N.W., Washington, DC 20552

Date
NAME
BANK
ADDRESS
CITY, STATE, ZIP
RE: CFPB Interviews Regarding the Remittance Transfer Rule
Dear COMPANY PERSON:
I am writing to solicit your interest in a voluntary research effort that the Consumer Financial
Protection Bureau is undertaking as part of its monitoring of the implementation of the Bureau’s
Remittance Transfer Rule. We will be consulting with a variety of companies that provide
remittance transfers, and service providers, to discuss the use and impact of a particular
temporary exception in the rule that expires in July 2015 if the Bureau takes no further action.
The Bureau will use the results of this effort to inform the Bureau’s analysis as to whether it should
extend the exception. As you may know, the Remittance Transfer Rule went into effect on October
28th and requires entities covered by the rule to provide consumers sending funds abroad
disclosures and cancellation and error resolution rights.
I hope that you will agree to participate in this effort. Enclosed below is a detailed description of
the planned research effort, including context, key requests, and our approach. If you have any
questions, please contact XXXXX ([email protected]; 202-435-XXXX).
If you are not familiar with the Remittance Transfer Rule, we ask that you please forward this
letter to the individual(s) at your institution who are and whom you think might be able to assist
us with the request outlined in this letter.

Context for and objectives of this effort:
A team in the Bureau’s Division of Research, Markets, and Regulations is beginning to consider
whether the Bureau should let expire, extend, or otherwise change a temporary exception in the
rule that, absent the Bureau’s further action, is set to expire in July 2015. When certain conditions
are met, this exception allows insured depository institutions and credit unions to estimate certain
amounts for which the Remittance Transfer Rule otherwise requires disclosure of accurate
amounts. 1

1

The Securities and Exchange Commission (SEC) has written a no action letter that assures broker-dealers that SEC
staff will not recommend enforcement action to the SEC under Regulation E if a broker-dealer provides disclosures as
though the broker-dealer were an insured institution for purposes of the temporary exception. See
http://www.sec.gov/divisions/marketreg/mr-noaction/2012/financial-information-forum-121412-rege.pdf (accessed on
October 16, 2013).
consumerfinance.gov

To help inform the Bureau’s thinking, we would like to include your institution as one participant
to be interviewed about [[FOR BANKS, CUS, BROKER DEALERS] your experience using (or not
using) this temporary exception] [FOR SERVICE PROVIDERS] your experience helping other
institutions use (or not use) this temporary exception] [FOR MONEY TRANSMITTERS DOING
OPEN NETWORK TRANSFERS] your experience providing accurate disclosures as required by
the rule of non-bank remittance transfer providers]. You will also be able to share other parts of
your experience with the implementation of the Remittance Transfer Rule. The OMB control
number for this collection is 3170-0032.

What this can mean for your institution:
Participating entities will have the opportunity, together with other sources of input, to help shape
any future evolution of this important new regulation. For your reference, through this series of
interviews, we are seeking input from approximately XXX companies that we believe either send
transfers covered by the temporary exception, assist others in sending covered transfers, or are
remittance transfer providers that are already required by the Remittance Transfer Rule to provide
accurate disclosures.
Participation in this study is voluntary. The results of the study may be used to develop a proposed
rulemaking or other documents, but for the purposes of such documents the information will
collected not be disclosed in a manner allowing attribution to specific institutions or individuals
except to the extent required by law.
More generally, the Bureau’s confidentiality rules protect confidential commercial information
provided to the Bureau. Thus, the Bureau will not voluntarily disclose in a manner attributable to
your institution unless it is required by law. If the responses you provide are requested under the
Freedom of Information Act, the Bureau will withhold such responses to the extent that it
determines that they constitute trade secrets or confidential commercial information that you
would not ordinarily make public. The Bureau will treat the responses consistent with its
confidentially rules, including 12 C.F.R. § 1070.20.

Our approach
If you are interested in participating, we will schedule a time for a two hour meeting to occur in
January 2014, either over the phone or at our offices. To aid your preparations for this meeting,
we will send you in advance a series of approximately XXX questions. If you prefer, you may
choose to answer these questions in writing prior to our scheduled call. We expect that your
involvement in this process will take no more than five hours, including preparation time, and will
be complete by the end of January 2014.

Next steps
If [[FOR PROVIDERS] you provide remittance transfers as part of your normal course of business
and], please let us know by DATE if you are interested in participating.. If [[FOR SERVICE
PROVIDERS] you provide services to remittance transfer providers and assist them with providing
disclosed fees and exchange rates, please let us know by DATE if you are interested in
participating. We will confirm your participation by phone and with a followup email. You can
reach us by email at [email protected] or by phone at XXX. Please also include the
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name and contact information (email address and phone number) of the person(s) at your
company who will be responsible for responding to our questions.
If you do not elect to participate, please let us know by DATE.
Again, should you have any questions, do not hesitate to contact XXXX via e-mail at
[email protected] or phone at 202-435-XXXX.
Thank you for your consideration; we hope you are able to participate in this effort. We look
forward to working with you.
Sincerely,
David Silberman (or designee)
Associated Director
Division of Research Markets & Regulations

consumerfinance.gov