The CFPB has recently updated its Small Entity Compliance Guide on Remittance Transfers to correspond with the May 11, 2020 changes to the rule. The main changes to this guide include the following:
Updated to address revised requirements to the Remittance Transfer Rule, including:
An increase to the normal course of business safe harbor threshold (Section 3.2.2).
Expiration of the 12 CFR 1005.32(a) temporary exception (Section 4.2.1).
Two new permanent exceptions that permit banks and credit unions to use estimates in disclosures of certain fees and exchange rates in certain circumstances (Sections 4.2.2 and 4.2.3).
Updated to note that this guide is a Compliance Aid under the Bureau’s Policy Statement on Compliance Aids (Section 1.1).
Updated to include the Bureau’s current process for informal inquiries (Section 1.2).
Updated to reflect miscellaneous formatting and administrative changes in various sections; revises internal cross references to refer to sections of this guide.
The revised guide can be found here.