The Clearing House Payments Company LLC (TCH) submitted comments to the CFPB regarding its proposed changes to certain disclosure requirements under the Remittance Transfer Rule. TCH supports the proposed rule changes that are intended to encourage consumers to contact their remittance providers about errors before contacting the CFPB or a state agency. However, TCH believes that the CFPB has underestimated the amount of time required for industry to implement the disclosure changes and therefore the proposed compliance date is much too soon. Implementing the changes will require changes to the software that generates disclosures which requires significant testing at the same time that banks must also prepare for the conversion of the Fedwire Funds Service to ISO 20022.  TCH’s letter therefore requests that the compliance date be one year from publication of the final rule.   
 
A copy of the letter may be found here.