Remittance Assessment Industry Data Collection

1 700 G Street NW, Washington, DC 2 0552
XX XX, 2018
XX
XX
XX
RE: V o lu ntary Re quest fo r Information to Su pport the Bu reau ’s A ssessment of its
Re m ittance Ru le
Dear XX,
Please find attached to this letter a request for information to support the Consumer
Financial Protection Bureau’s (“CFPB” or “Bureau”) assessment of its Remittance Rule
(1 2 CFR 1005 Subpart B). Section 1022(d) of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (“Dodd-Frank Act”) requires that the Bureau conduct
assessments of its significant rules. The Bureau proposed the scope and goals of its
assessment of the Remittance Rule and asked for public comment in the Federal
Register (FR 2017-05681).1
Responding to this request, in whole or in part, is purely voluntary on your part. This
request is not a supervisory order issued under Sections 1025 or 1026 of the DoddFrank Act or an order to provide information under Section 1022(c)(4). The request
does not relate to any examination of your institution.
The data the Bureau is collecting through this outreach is part of a larger effort that is
gathering data about the remittance market from other sources. This survey has two
primary goals. One is to provide industry participants another opportunity to speak
about their experiences around the rule. The second is to understand whether there are
issues in the workings of the rule in the small part of the market where the Bureau has
limited information. This part of the market includes small money transmitters, small
credit unions, and small and community banks. This segment may experience issues
with certain provisions of the rule that would remain hidden if the Bureau only looked
at the large participants for which it has more comprehensive data. The Bureau expects
that this survey will allow respondents to highlight for the Bureau areas of concern that
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might not be visible through other means.
The Bureau seeks any information that will assist it in assessing the Remittance Rule;
therefore, even partial responses to this request could be useful, depending on their
content. We do not intend even voluntary responses to place any undue burden on
respondents. While responses to the questions below will be most useful for the specific
purposes of this survey, general feedback on your experiences complying with the
Remittance rule or responses to similar questions are also welcome.

1

https://www.federalregister.gov/documents/2017/03/24/2017-05681/request-f or-information-regardingremittance-rule-assessment

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This request does not seek any personally identifiable information that directly
identifies any consumer or consumers, and we specifically request that you not submit
such information to us. The request’s focus is on aggregate level data and practices. It
does not seek transaction-level, or consumer-level data or information.
The Bureau will treat information provided in response to this request as confidential
information in accordance with the Bureau’s confidentiality rules (12 CFR 1070.40 et
seq.). Thus, the Bureau will not voluntarily disclose such information in a manner
attributable to your institution unless it is required by law. Where appropriate, you may
also wish to designate responses as confidential business information. In no case will
any data, information, practice, or outcome that the Bureau publically reports be
attributed to any one provider; all results will be reported only in a way that precludes
the identification of any individual respondent.
The Bureau is committed to well-tailored and effective regulations. Your participation in
this request will assist us in ensuring that this assessment is evidence-based and reflects
the realities faced by industry participants and their c ustomers. To that end, we hope
this assessment will result in findings that identify areas of mutual benefit to consumers
and market participants. We believe that participation in this exercise will not only
benefit the Bureau and consumers, but respondents as well. We are grateful for all
assistance we receive in fulfilling our statutory obligations and in pursuing a
transparent, open, and competitive market for consumers.
If y ou have any questions about this request, please call me at 202-435-9798 or email
me at [email protected].
Sinc erely,

Scott Fulford, Ph.D.
Ec onomist, Offic e of Research

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1 700 G Street NW, Washington, DC 2 0552
XX XX, 2018
XX
XX
XX
UNIT ED ST A T ES OF A MERI CA
BUREA U OF CONSUMER FINANCIAL PROT ECT ION
V O LUNT ARY REQ UEST FO R I NFO RMAT ION T O SUPPO RT T HE BUREA U’S
A SSESSM ENT O F I T S REMI T T A NCE RUL E
Pursuant to the Bureau of Consumer Financial Protection’s (Bureau or CFPB)
obligation under Section 1022(d) of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act, or Act), codified at 12 U.S.C. § 5512(d), the Bureau
hereby requests that [recipient] voluntarily provide information to assist with its
assessment of its Remittance Rule, 12 CFR 1005 Subpart B.
Pu rpo se
The Bureau’s Remittance Rule, Subpart B of Regulation E (1 2 CFR 1 005), came
into effect on Oc tober 28, 2013. Pursuant to the Bureau’s mandate under Section
1 022(d) of the Dodd-Frank Act to “conduct an assessment of each significant rule or
order adopted by the Bureau…[which] reflect[s] available evidence and any data that the
Bureau reasonably may collection…not later than 5 years after the effective date of the
subject rule or order,” the Bureau seeks information from you which would assist in
fulfilling this statutory obligation.
Information provided in response to the request is intended to support the
Bureau’s assessment of its remittance rule. This is not a supervisory order issued under
Sec tions 1025 or 1026 of the Dodd Frank Act, codified at 12 U.S.C. §§ 5515 or 5516, or a
market-monitoring order issued under Section 1022(c)(4) of the Act, codified at 12
U.S.C. § 5512(c)(4). The Bureau will treat the information received in response to this
request in conformity with its confidentiality regulations at 12 CFR § 1 070.40 et seq.
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The Bureau requests responses be submitted on or before 5 :00 PM Eastern time,
XX XX, 2 017 [90 d ays].

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I n structio ns
1. Data and other proprietary submissions should be provided to the CFPB v ia the
sec ure file transfer protocol (SFTP) server here: XXXX. If y ou are unable to provide
y our submission via SFTP, or have any other questions about acceptable methods of
transfer, please contact Nicholas Tremper via email at [email protected]
or by phone at 202-435-9738 in advance of providing information.
2. Please submit all responses to section 1 via a spreadsheet in the .xls, .xlsx, or .csv file
format.
3. Do not include any personally identifiable information that directly identifies any
c onsumer, such as a consumer’s name, address, telephone number, Social Security
number, or account number.
4. Unless otherwise specified, requests apply to remittance transfers as defined by 12
CFR 1 005.30(e). For information covering time periods prior to the effective date of
the Remittance Rule, to the best of your ability please include only those transfers
which meet this definition.
5. When you have written policies or procedures that contain responsive information,
please provide those documents with your answer.
6. Unless otherwise specified, the requests seek information about current practices.
7. We request responses on or before XX XX, 2 01 7 .
8. The Bureau may issue follow-up requests in connection with your responses.
9. If y ou have questions about the information specified in or requested by the request,
please contact Scott Fulford via email at [email protected].
10.

The Bureau will accept partial responses.

11. The Bureau will accept responses to questions similar, but not identical to, those
asked below. Please annotate all such responses accordingly.
12. The Bureau will accept submissions of information not responsive to any question or
questions below that you nonetheless believe would assist the Bureau in its efforts to
assess the Remittance Rule. Please annotate all such submissions accordingly.
13. Any documentation you submit may be redacted so as to remove information that
would identify any entity with which you do business.
14. If y ou collect and store information on a fiscal year basis instead of calendar year,
please report the period that is most easily available and annotate the response
ac cordingly.
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De fin itions
1. For purposes of this request, “you” or “your” shall mean [recipient, its parent
c ompanies, wholly or partially owned subsidiaries, joint ventures, and affiliates, and
all principals, directors, officers, owners, employees, agents, representatives,
c onsultants, attorneys, accountants, independent contractors, and other persons
working for or on behalf of the foregoing.
2. The terms in this request, including “remittance(s),” “transfers,” “remittance
transfer” and “agent”, are as defined by 12 CFR 1005.30, except where explicitly
specified otherwise.

Dav id Silberman
Associate Director
Research, Markets, and Regulations

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Se c tion 1 : Qua ntitative informa tion
If, for any question, you processed no remittances in any of those years, or were not in
existence as an entity during any of those years, please note that accordingly.
1 -1. For each calendar year from 2007 through 2016, how many remittances did you or
y our agents process?
1 -2. For each calendar year from 2007 through 2016, what was the dollar volume of
remittances you or your agents processed?
1 -3. For each calendar year from 2007 through 2016, what was the dollar volume of fees
y ou or your agents assessed to consumers sending remittance transfers?
1 -4. For each calendar year from 2007 through 2016, what was the dollar volume of net
revenue you received from the difference in the exchange rate offered to consumers
sending remittance transfers and the exchange rate at which you were able to acquire
c urrency to provide to transfer recipients?
1 -5. At the end of each year from 2007 through 2016, how many physical locations in
the United States including territories, possessions) did you have that offered
remittance services, whether owned and operated by you or by an agent?
1 -6. At the end of each year from 2007 through 2016, in how many different US states
did you have a physical presence that offered remittance services? (A state, as defined in
Regulation E 1 2 CFR 205.2(l) is any state, territory, or possession of the United States;
the District of Columbia; and the Commonwealth of Puerto Rico.)
1 -7 . For each calendar year from 2007 through 2016, how many countries did you send a
remittance to?
1 -8. If you use the temporary exception, please list each destination country for which
y ou use the temporary exception when you send a remittance. For each destination
country, please indicate whether you are using the temporary exception to estimate fees,
exchange rates, or both.
1 -9. For each year from 2007 through 2016, what proportion of your remittance
transfers were initiated via digital means on a consumer’s device (e.g. a desktop
c omputer, mobile device, etc.)?

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1 -10. For each calendar year from 2014 through 2016, what was the number and dollar
v olume of remittance transfers for which you received a timely error notice from a
c onsumer? What was the number and dollar volume of such transfers for which you
determined an error occurred? To the extent you are willing and able to do so with a
minimum amount of burden, please subdivide your answers by the country in which the
designated recipient or their account was located.
1 -11. For each calendar year from 2014 through 2016, what was the number and dollar
v olume of remittance transfers cancelled within 30 minutes?
1 -12. For each calendar year from 2014 through 2016, what was the number and dollar
v olume of remittance transfers picked up by, or deposited into the account of, the
designated recipient within 30 minutes of the sender’s payment?
1 -13. For each calendar year from 2007 through 2016, how many transfers scheduled in
advance did you or your agents process? What was the dollar value of such transactions?
1 -14. For each calendar year from 2007 through 2016, how many recurring
preauthorized remittance transfers did you or your agents process? What was the dollar
v alue of such transactions?
1 -15. For each calendar year from 2007 through 2016, how many times did you provide
a consumer a prepayment disclosure when the consumer was physically present? Of
those times the consumer received a pre-remittance disclosure, how many times
did the consumer decide not to send the remittance after receiving the dis closure?
1 -16. At the end of 2016, what languages (other than English) did you or your agents use
to provide disclosures to c ustomers?

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Se c tion 2 : Qua litative information
For this section, please provide all answers in the form of w riting. If it would be useful
to provide documentation in relation to any of these questions that is not separately
solicited in Section 3 of this request, please feel free to do so.
2-1 . How do you determine the exchange rates you offer to consumers when they initiate
a transfer? How frequently are such rates subject to change?
2-2. To the extent not already clear from any documents provided in the next section,
please describe your procedures, policies, and processes for resolving errors pursuant to
1 2 CFR 1005.33. Please specifically note:
a. by what c hannels you accept notices of errors;
b. what kinds of information and documentation you provide to consumers
regarding the process once an error is asserted; and
c. your investigatory process, including how you determine whether or not any
error occurred.
Please also describe your procedures, policies, and processes for resolving consumer
issues and complaints that you determine are not errors or for which you did not receive
timely notice.
2-3. Please describe your procedures, policies, and processes for reducing potential
errors before, as applicable, a consumer pays for the remittance transfer and before the
remittance transfer is sent.
2-4. Describe your procedures, policies, and processes for cancelling remittances within
30 minutes pursuant to 12 CFR 1005.34.
a. Please note if any part of these policies or procedures systematically results in a
delay of the availability of funds to recipients. For example, do you delay
ex ecuting a transaction by 30 minutes to ensure the remittance can be cancelled?
If so, how many transactions were so delayed in 2016?
b. What does “executing a transaction” mean for your institution?
c. What alternative methods did you consider to comply with the 30 minute
c ancellation window? If you considered alternative methods, please describe
y our reason for rejecting them?
2-5. Describe any notable products or services you introduced or discontinued, at least in
part, for reasons related to the Remittance Rule. Please describe the precise reasons
such action was related to the Remittance Rule, as well as what other factors were
related (if any).
2-6. Describe any notable remittance products or services you introduced since Oc tober
28, 2013 which are either still in-market or were discontinued for reasons unrelated to
the Remittance Rule.
2-7. Describe the burden to you of compliance with the Remittance Rule. Please attempt
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to summarize this as best as you can in dollar terms. Please separate out one-time costs
relating to implementation of the rule from those costs of compliance that are ongoing.
To the extent it is possible to assign costs to specific provisions of the rule, please do so.
2-8. Please briefly describe the non-marketing disclosures relating to remittance
transfers you provide to consumers, both those pursuant to and those not required by
the Remittance Rule (e.g., those required by a state law). Please separate your response
ac cording to the channel (e.g., in-person, over the phone, fax, online) by which the
transfer was effected. Please treat transfers initiated online as a separate channel from
transfers initiated via a mobile device.
2-9. Describe the policies and procedures by which you determine which disclosures and
other documentation (both those pursuant to and those not required by the
Remittance Rule) should be translated into a non-English language, the policies and
procedures by which you ensure such translations are accurate, and the policies and
procedures by which you ensure consumers receive non-English disclosures and other
documentation which best meets their needs when such are available.
2-10. Describe the policies and procedures by which you make data about the availability
and pricing of your remittance transfer services available to third parties on a regular
and/or ongoing basis. For example, do you provide data to any entities which maintain
websites intended to allow consumers to compare the pricing and other features of
remittance transfers across different providers? If you do not do so, please note this,
along with the reasons why.
2-11. Is there other information relevant to our assessment of the Remittance Rule that
we have not asked for elsewhere? Please provide any data or documents available to
support this additional information.

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Se c tion 3 : Do cumentation
Responses to this section should take the form of documentation c reated by you or an
entity you have contracted to create it which is c urrently used by you in the course of
doing business. If any such documentation varies based on circumstance, providing a
single template document is adequate; in such c ases, please note which parts of the
document may vary and why.
3-1 . Please provide copies of all disclosures you provide consumers pursuant to the
Remittance Rule. Please note which disclosures correspond to which channels. If you
provide disclosures in non-English languages, you do not need to provide examples of
such disclosures; please simply list the languages in which you provide such disclosures.
If y ou do not provide any disclosures in English, please provide copies of all disclosures
in the non-English language in which you provide disclosures most frequently.
3-2. Please provide copies of internal documentation that lays out your error resolution
procedures and policies.

Pape rw o rk Redu ctio n A ct
According to the Paperwork Reduction Act of 1995, an agency may not conduct or
sponsor, and a person is not required to respond to a collection of information
unless it displays a valid OMB control number. The OMB control number for this
c ollection is 3170-0032 It expires on 05/31/2019 The time required to complete
this information collection is estimated to average 5 hours, per response. The
obligation to respond to this collection of information is voluntary Comments
regarding this collection of information, including the estimated response time,
suggestions for improving the usefulness of the information, or suggestions for
reducing the burden to respond to this collection should be submitted to Bureau
at the Consumer Financial Protection Bureau (Attention: PRA Offic e), 1700 G
Street NW, Washington, DC 20552, or by email to CFPB_PRA @cfpb.gov.

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