Comment on CFPB-2011-0021-0001

On behalf of Centinel Bank of Taos, a community bank in Taos, New Mexico, I would like to express my strong opposition to the proposed changes to Regulation E regarding Remittance Transfers. Centinel Bank of Taos supports the ICBA’s comment letter which proposes exempting community banks that complete less than 1,200 wire transfers per year. Centinel Bank of Taos (“CBT”) conducted less than one hundred (100) international wire transfers in 2011. In terms of income, CBT generated only $4,325 in 2011 from all wire transfers (both domestic and international) it conducted. CBT’s income generated from consumer-initiated international wire transfers is actually much lower, as most of CBT’s wire transfers are domestic wire transfers conducted for business customers, not consumers. Should this regulation apply to smaller financial institutions such as ours, we would have one of two options, both of which would negatively impact our customers. Either (a) CBT’s costs to implement such additional measures would greatly increase, CBT would be forced to increase the fee associated with this service, passing this cost on to our customers; or (b) CBT could stop doing international wire transfers altogether, thus putting an end to this service, which is clearly offered as a convenience to our customers, not as a revenue stream. The CFPB’s intent is to protect consumers by proposing this rule, but the impact on community banks’ consumer customers will have the opposite effect. Please note Centinel Bank of Taos’ strong opposition to the proposed rule as written and create an exemption for community banks who conduct a de minimus number of international wire transfers per year. Thank you, Maija West Enterprise Risk Officer Centinel Bank of Taos