Comment on CFPB_FRDOC_0001-0050

Document ID: CFPB-2011-0009-0042
Document Type: Public Submission
Agency: Consumer Financial Protection Bureau
Received Date: March 07 2012, at 12:00 AM Eastern Standard Time
Date Posted: March 21 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: February 7 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: April 9 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80fd05d4
View Document:  View as format xml

This is comment on Proposed Rule

Electronic Fund Transfers

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Normally I support CFPB, but this time I have had enough....with Section B of Reg E, who are you really protecting? Safe Harbor MUST be in place SOON. I am a compliance officer for a 80 million dollar credit union that serves the ski areas of colorado as well as the west metro of denver. we have about 150 international wires each year, lots of people from other countries come here to ski and take their prepaid cards back with them. Our business accounts on occasion deal with international companies for business related purposes. I hear safe harbor numbers thrown around, but the safe harbor needs to be much more than that. This new regulation needs to apply to corner payday loans, pawn brokers. NOT depository financial institution. Get it right! The way that this regulation has been written is closing our boarders and international trade, you guys look like bigots. you really do. And dont wait! the burden this places on financial institutions, more so corporate credit unions, is enormous. If you drag your feet after we put thousands of man hours into compliance and software, only to go back and change what you have already put out there, you are going to lose all credibility, if that has not already happened.

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