The Wisconsin Bankers Association (WBA) is the largest financial trade association in Wisconsin, representing approximately 270 state and nationally chartered banks, savings and loan associations, and savings banks. WBA appreciates the opportunity to comment on the Bureau of Consumer Financial Protection's (Bureau's) assessment of regulations related to consumer remittance transfers under the Electronic Fund Transfer Act.
WBA welcomes the Bureau’s efforts to assess the effectiveness of the Remittance Rule considering its objectives, including ensuring that outdated, unnecessary, or unduly burdensome regulations are regularly identified and addressed in order to reduce unwarranted regulatory burdens. In the assessment notice the Bureau indicates it intends to focus on two areas, including ways to promote access, efficiency, and limited market disruption by considering how remittance volumes, prices, and competition have changed. In making these considerations and comparing outcomes, WBA would like to recommend the Bureau also consider the increased costs and fees imposed as a result of the rule, whether the expected utility of disclosures has been achieved, the benefit of cancellation provisions weighed against inconvenience and delays for consumers, whether the refund provision has been truly beneficial, and the harm of potentially reduced access as a result of the low safe harbor threshold.
WBA appreciates the opportunity to comment on the Bureau’s assessment of the effectiveness of the Remittance Rule.