While the proposals put forth by the CFPB to ease the disclosure burden are appreciated, they do nothing to resolve the larger issue that puts such a burden of liabliity on the financial institution aiding the sender. I think it is ridiculous to require a bank or credit union to know the amount of taxes a foreign government might impose on such a transaction. That liability and responsibility should be borne solely by the person initiating the send and/or the end-point receiver.
The CFPB must know that this regulation will cause banks and CU to cease sending International remittances rather than bear this liability. These taxes were imposed before this regulation and, to my knowledge, they were not an issue. Now they are made an issue and the regulation will impair consumers ability to send foreign wires.
Dodd-Frank will just be creating another business opportunity for international money senders. Money changers here in the states will accept funds for deposit into their account at a US bank, which funds will be withdrawn by their associate at an ATM in a foreign country and dispensed to the recipient for a fee. With email and using Apple's FaceTime this could be completed in minutes given that most third world countries have adopted smart phones more readily than we have here in the states. This would work best in high density population areas like Mexico City or Delhi.
Comment on CFPB-2012-0050-0001
This is comment on Proposed Rule
Electronic Fund Transfers Regulation E
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