Academic journal article ABA Banking Journal

Is CFPB Proper Contact under Regulation E Rules?

Academic journal article ABA Banking Journal

Is CFPB Proper Contact under Regulation E Rules?

Article excerpt

Q. I'm having trouble determining which agency(ies) to list as a contact for Regulation E remittance disclosure purposes. We're a state-chartered bank, so does that mean we should list our state department of banking or should we use FDIC, because it is our primary regulator? Or, do we use the Consumer Financial Protection Bureau's contact information regardless of whether CFPB is our primary federal regulator?

A. Based on your circumstances, it appears that you should provide your state chartering agency's information as well as CFPB's. See the preamble to the Final Rule and the discussion in Section 1005.31 (b)(2)(vi).

CFPB stated that under the final rule, the provider must disclose the state agency that licenses or charters the remittance transfer provider. However, because disclosures must only be disclosed as applicable, if no state agency licenses or charters a particular provider, then no state agency need be disclosed. (For example, national banks would only disclose CFPB's information.)

The bureau also stated that it is appropriate to provide CFPB's contact information, even in instances where CFPB is not the provider's primary federal regulator. …

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