CUNA to CFPB: Raising remittance threshold will balance protection, access

June 28, 2019

WASHINGTON (June 28, 2019) — The Credit Union National Association (CUNA)today submitted a letter to the Consumer Financial Protection Bureau (CFPB) calling for “substantive amendments” to the Bureau’s Remittance Rule. The letter is a response to a request for information issued by the CFPB in April.

CUNA believes that the 100-transfer safe harbor established by the CFPB in 2012, intended to relieve smaller entities from burdensome reporting requirements and encourage the offering of remittance services, has not been robust enough, and has instead led numerous credit unions to withdraw or reduce such services. Today’s letter cites the CFPB’s own October 2018 report on the rule which shows that costs and challenges association with the rule has likely negatively affected the availability of remittances at small financial institutions. 

“While CUNA supports appropriate safeguards for consumers initiating remittance transfers, including clear and understandable disclosures,” wrote CUNA Senior Director of Advocacy and Counsel Alexander Monterrubio, “the Bureau should propose and finalize substantive amendments to the Remittance Rule to better balance necessary consumer protections with a more tailored regulation that allows consumers to access desired products and services.”

Specifically, CUNA called for three key revisions to the rule on remittances:

  • Increase the “normal course of business” threshold to at least 1,000 remittance transfers in each of the prior and the current calendar years, up from the current 100; 
  • Eliminate the 30-minute cancellation requirement or provide consumers the ability to opt-out of the mandated waiting period;  
  • Urge Congress to make permanent the temporary fee estimates exemption and explore alternative options to allow fee estimates for remittances sent over open-networks.  


About CUNA
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America's credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit

Stephen Fitzmaurice
CUNA Communications