Bulletin outlines additional remittance exam procedures for banks under $10B

Supplemental exam procedures on remittance transfers were issued Monday by the regulator of national banks, permanently allowing smaller institutions (those under $10 billion) to estimate certain fees and exchange rates when making disclosures to their customers about the cost of remittance transfers.

The Office of the Comptroller of the Currency (OCC) said its Bulletin 2021-33 supplements the Federal Financial Institutions Examination Council’s (FFIEC’s) interagency Electronic Fund Transfer Act (EFTA) procedures adopted by the OCC in 2019. The bulletin also, the agency said, summarizes the Consumer Financial Protection Bureau’s (CFPB) Regulation E amendments regarding remittance transfers that became effective in July 2020. The CFPB has rulemaking authority for banks with more than $10 billion in assets; the OCC has authority for banks below that threshold.

According to the bulletin, the procedures address remittance disclosures by:

  • Setting increases in the safe harbor threshold that excludes certain banks from the requirements for a bank that provides remittance transfers for consumers in the normal course of the bank’s business.
  • Establishing e xceptions regarding exchange rates and third-party fees. Banks continue to be allowed to provide disclosures of exchange rates and third-party fees, both under certain conditions.

The bulletin also rescinds the “Electronic Fund Transfer Act” booklet of the OCC’s Comptroller’s Handbook; the 2019 “Consumer Compliance: Revised Interagency Examination Procedures”; and the 2014 “Electronic Fund Transfer Act: Comptroller’s Handbook Booklet Revision and Rescission.”

OCC Bulletin 2021-33: Electronic Fund Transfer Act: Supplemental OCC Examination Procedures on Remittance Transfer Amendments; Summary of Amendments; and Rescissions