CFPB’s First Final Rule Addresses International Remittance Transfers

In the Consumer Financial Protection Bureau's ("CFPB") first official final rulemaking, announced January 20, 2012 ("Final Rule"),¹ the agency amended Regulation E² to define standards and provide initial guidance in implementing section 1037 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("DFA").³ Simultaneously, the agency issued a concurrent proposal soliciting comment on the application of the Final Rule to certain transactions and remittance transfer providers ("Proposed Rule").⁴ The Final Rule becomes effective January 20, 2013, and the CFPB expects to address the issues raised in the Proposed Rule prior to the effective date of the Final Rule.

Section 1037 imposes various consumer protections on international electronic money transfers originating in the U.S. Such "remittance transfers," sent by U.S. consumers to recipients in foreign countries, account for billions of dollars annually and make the U.S. the largest source of any country