On Wednesday, August 29, Alston & Bird hosted the fourth session in its six-part series of teleseminar programs addressing issues of immediate concern for financial institutions impacted by the significant regulatory reforms of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
With only six months until the CFPB’s final remittance transfer rules take effect, many impacted providers are still struggling with the operational challenges of implementing a compliance program that satisfies the rule’s myriad consumer protection provisions. These compliance challenges were made even more difficult recently by the second set of “final” rules that the CFPB released in an attempt to clarify certain aspects of the rule, but have instead introduced another set of intricate disclosure requirements for preauthorized remittance transfers. Concerns over the accuracy, timing, delivery, form and content of the rule’s multiple consumer disclosure requirements continue to frustrate remittance transfer providers regardless of their size. Furthermore, the strict liability standards imposed by the rule are also a cause for serious concern.
Christina LaVera, Joe Yesutis and Stephen Krebs provided an overview of the Remittance Transfer Rule, with an emphasis on several of the more challenging compliance requirements. The panelists specifically discussed the compliance challenges involving the rule’s:
- detailed disclosure requirements;
- standards of liability within the rule’s error resolution scheme;
- additional requirements imposed by the supplemental final rule that the CFPB recently issued; and
- overall compliance challenges, particularly for open network providers.
To listen to a recording of the seminar, please click here.
Additional programs in our Dodd-Frank Teleseminar series include, on September 19, 2012, a presentation on the treatment of derivatives under Dodd-Frank, focusing on practical issues for users of derivatives.
August 29, 2012
12:00 p.m. - 1:00 p.m.