The Credit Union National Association (CUNA) sent another comment letter to the Consumer Financial Protection Bureau (CFPB) asking the agency to provide a broader international remittance transfer exemption level and additional compliance relief for credit unions. Included with the comment letter was a separate memo to the CFPB outlining the agency’s statutory authority to exempt credit unions from regulations such as the remittances rule. CUNA asked the agency to differentiate between entities that are profiting as a result of offering remittance transfers as a business line or a product, as opposed to credit unions that offer international remittance transfers as a service to their members. Also, they encouraged the agency to use its exemption authority to shield as many credit unions as possible from the terms of the remittance regulations, and to delay the compliance date by at least 12 months.
Further, CUNA believes the CFPB could also ease the regulatory burden faced by credit unions and other financial institutions by compiling and maintaining its own central database of foreign taxes and recipient institution fees; requiring each remittance provider to find and maintain this information independently will be incredibly burdensome and costly for credit unions. Their comment letter also addressed the specific proposed rules regarding liability, fees, and foreign tax issues.