Financial Literacy Network, Inc. (FLN) encourages the CFPB to adopt a safe harbor with respect to informing our understanding of that part of the rule referring to the "normal course of business" of a remittance transfer provider. Specifically, FLN supports the proposed safe harbor that limits remittance transfers to 25 or less in the current year. The safe harbor provides a clear notice of when a person will subject himself to the regulation, and the "25" transfers creates a clear and unambiguous mark by which a person can make a fully-informed business decision as to whether he desires to de facto subject himself to the regulation. Additionally, the person is provided the "complimentary" information regarding the business cost of associated with becoming a remittance transfer provider, and can more accurately determine "per unit" cost of each remittance transfer.
Comment on CFPB_FRDOC_0001-0050
This is comment on Proposed Rule
Electronic Fund Transfers
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