Defining Larger Participants of the International Money Transfer Market Docket No. CFPB /RIN 3170-AA25

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1 Robert G. Rowe, III Vice President/Senior Counsel Center for Regulatory Compliance Phone: April 1, 2014 Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street, NW Washington, D.C Defining Larger Participants of the International Money Transfer Market Docket No. CFPB /RIN 3170-AA25 Dear Ms. Jackson, The American Bankers Association 1 (ABA) appreciates the opportunity to comment on the proposal of the Bureau of Consumer Financial Protection (Bureau) to extend its supervisory authority to large non-depository providers of remittance services. The Bureau proposes to amend its rule that defines which larger participants of consumer financial product and services markets are subject to Bureau oversight. The amendment, which would be the fourth such rule, 2 would add a new section to define larger participants in the market for international money transfers. According to the Bureau, the proposal will help it assess compliance with federal consumer financial laws, obtain information about these activities (including through complaints from consumers) and detect and assess risks to consumers and consumer financial markets. If adopted, the proposal would apply the same examination procedures to large nonbank providers that the Bureau currently uses to assess performance by depository institutions. Since many nonbank providers are subject to state supervision, the Bureau also anticipates coordinating examinations with the appropriate state regulatory authorities. While the proposal would establish the Bureau s supervisory authority over large nonbank remittance providers, it would not impose any new substantive consumer protections. Overview of ABA Comments ABA applauds the efforts by the Bureau to extend supervision for remittance transfers to large nonbank providers of the service. As often noted, 3 the great majority of consumer remittance services are offered by nonbanks. Therefore, to achieve consistent application of the requirements, uniform supervision is essential. 1 American Bankers Association represents banks of all sizes and charters and is the voice for the nation s $14 trillion banking industry and its two million employees. The majority of ABA s members are banks with less than $185 million in assets. 2 The first three rules extending the Bureau s authority over nonbank consumer financial providers defined larger participants for consumer reporting, consumer debt collection, and student loan servicing. 3 See, e.g., CFPB Report on Remittance Transfers, July 20, 2011, p. 6,

2 First, ABA recommends that in order to achieve this goal, it would be far more logical to apply a lower threshold to identify which large nonbanks are subject to Bureau supervision. Otherwise, an important segment of the market will be outside comparable federal oversight. Second, if consistency and uniformity are the goals, ABA believes it would be far more appropriate to apply uniform terminology to these consumer services to avoid confusion and potential disparate construction of the rules by the judiciary and others. Finally, ABA believes there are a number of other revisions that would help ensure uniform and consistent treatment and thereby establish a healthier environment for both consumers and providers. The Coverage Threshold for Nonbank Providers Should be Lower When it adopted the rule on remittances to implement section 1073 of the Dodd-Frank Act 4 and as it has reiterated in the current proposal, the Bureau believes that compliance with the remittance rule helps improve the predictability of remittances and provides consumers with better pricing information. 5 This proposal would bring some nonbanks within the Bureau s supervisory jurisdiction and establish federal supervision over non-depository remittance providers where there currently is no comparable federal oversight. ABA agrees it is appropriate to establish uniform federal oversight for the market to ensure consistency and uniform consumer protections, and so we support this effort within that context. The Bureau goes on to posit that this in turn will help promote the Bureau s objective to enforce federal consumer financial laws consistently, in accordance with its authority under Section 1024 of the Dodd-Frank Act. For example, in the Bureau s view the authority would help ensure that nonbanks comply with the new consumer protections and other consumer protections, such as UDAAP (Unfair, Deceptive or Abusive Acts or Practices). While the Bureau lacks precise data on the market, it has used existing data, particularly information from the states of California, New York, and Ohio, along with information from the Census Bureau and FinCEN, to extrapolate information about the market. As a result, the Bureau estimates that approximately 340 nonbanks provide international money transfers. In reviewing this market, the Bureau estimates that 150 million annual transfers worth approximately $50 billion were sent in To identify which segment of the market contained the largest providers and which should be subject to its supervisory authority under the Dodd- Frank Act, the Bureau segregated the market into tiers by volume. 6 The Bureau further extrapolates from the available data that the first tier, or those with the greatest volume of transfers, were providers that sent approximately 3 million transfers annually; this constituted ten companies which accounted for three-fourths of the market. The second tier of 15 nonbanks, providers which sent between one million and 3 million transfers each, constituted one-sixth of the market. The third tier was nonbanks which sent between 500,000 and one million transfers each year but represented only 1.5% of all transfers. The final tier, the smaller providers, was made up of those which sent less than 500,000 remittances annually and covered a few hundred providers. Based on these assumptions, the Bureau proposes to apply its supervisory authority only to the very largest transfer providers, or those which send more than 1,000,000 transfers annually. 4 The Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law , enacted July 21, 2010, 12 USC 501 et seq 5 12 CFR et seq 6 The Bureau acknowledges that these estimates are based on assumptions that could affect their accuracy, such as including business transfers not subject to the remittances rule. 2

3 When establishing the threshold for which providers are covered, two factors are important to recognize. First, as the Bureau has repeatedly pointed out, the general understanding of the market for remittances services is limited, and extending Bureau oversight allows it to collect better data about the market. Second, if consistent application of the rules is important to protect and inform consumers, then the proper threshold is particularly important in this market because, as the Bureau notes, there is currently little federal oversight for non-depositories, unlike the regime which exists for depository institutions. Therefore, ABA believes that setting the threshold at 1,000,000 transfers annually in fact undercuts the Bureau s stated purposes for establishing its authority over larger providers in the market. Without discussing all the nuances that the Bureau proposes for determining coverage, 7 such as the elements of averaging over three years and other complex calculations to determine whether or not a provider is subject to the Bureau s supervisory authority, the proposed threshold itself is too high. Contrasting the proposal with the previously established threshold for determining whether a depository institution offers remittances in the normal course of business underscores this disparity. For depository institutions, the Bureau set an annual threshold of 100 transfers per year. 8 When the Bureau adopted the threshold to determine if a depository institution offers remittances in the normal course, ABA and others advocated a much higher threshold. While according to the Bureau, this proposal would capture a significant percentage of the current market based on the Bureau s estimates, it also means a substantial number of nonbank provided remittances transfers will not be covered and not subject to comparable federal oversight. 9 If the Bureau s goal is to ensure consistent treatment across providers, whether bank or nonbank, then setting a threshold lower than 1,000,000 transfers annually is necessary. ABA suggests that Bureau consider using at least 100,000 transfers annually as the threshold as a starting point and then re-assessing this benchmark after additional data are collected and the Bureau has a better understanding of the nonbank remittance market. 10 Separately from setting the correct threshold, once it determines which entities are subject to its oversight authority, the Bureau then has the authority to determine when and whether to conduct an examination of nonbanks, a fact it notes in the proposal. 11 Similarly, the Bureau 7 ABA believes that the incredible complexity of calculations needed to determine coverage, such as annual averaging of number of transfers using detailed mathematical equations, works to the disadvantage of providers and consumers since there is no easy way to determine whether a provider is covered. Since the complexity of the calculations do not affect depository institutions, ABA reserves comment but we cannot help but note that the complexity for determining coverage is both confusing and a series of steps that only serve to obfuscate and not promote transparency CFR (f)(2) 9 While a depository institution may not be subject to oversight by the Bureau, it is still subject to significant federal oversight and supervision. Moreover, even when a depository institution does not offer remittances in the normal course, all its activities are still subject to federal oversight and review so that even the smallest depository institutions are subject to regular and constant supervision by the federal prudential regulators. Regular examination of depositories ensures compliance with all federal requirements, including the new remittances rule. That would not be the case for nonbanks. 10 One of the points that the Bureau has raised in meetings and other contexts is the need for more data on the remittances market and their use by consumers. In order to collect appropriate data from non-depository institution providers, a lower threshold will ensure a more comprehensive dataset for analysis. 11 As stated in the proposal, CFPB prioritizes supervisory activity among nonbank covered persons on the basis of risk, taking into account, among other factors, the size of each entity, the volume of its transactions involving consumer financial products or services, the size and risk presented by the market in which it is a participant, the 3

4 notes that it has the authority to collect information from supervised entities and, if it intends to collect better data on the market as a whole, then including additional providers is not only appropriate but vital to meet the Bureau s stated goals. These two elements work in conjunction to give the Bureau better data and greater flexibility to focus resources on where it identifies risks to consumers. Definitions Should be Consistent One of the problems often identified by bankers as problematic when dealing with regulations is inconsistent definitions. For example, the concept of business day is a source of constant confusion and disagreement due to the panoply of definitions for what constitutes a business day. Unnecessary disparities in defining terms, therefore, should be avoided. The proposal would define international money transfer in place of remittance transfer and then would use the term aggregate international money transfers to determine if an entity is covered, similar to the approach taken for the three prior rules on larger participants. Similarly, the proposal would replace remittance transfer provider with international money transfer provider; the key distinction to be that an international money transfer provider would be defined without regard to the amount of the transfer where remittance transfers exclude transfers of $15 or less in accordance with Regulation E for receipts for other transactions. 12 The proposal also includes other subtle distinctions between the existing terminology and the proposed definitions for the supervision of non-depositories, such as replacing the term person with nonbank covered person and using the larger participant rule definition of consumer instead of the Remittance Rule definition, as well as eliminating the reference to providing remittances in the normal course of business. Although the Bureau intends the terms remittance and international money transfer to be interpreted the same, ABA finds that the use of different terminology needlessly invites confusion and disparate interpretations by courts and other officials. While some of the elements, such as providing remittances in the normal course, might not apply to non-depository institutions, ABA strongly recommends that absent a clearly articulated and very compelling reason, the final rule should use the same terminology for all providers. Despite the Bureau s intention, a court faced with different terminology can easily judge that the existence of two distinct terms infers differences, undermining the goal of consistency and similarity in treatment for all players in the arena. More important, disparate terminology invites unintended distinctions elsewhere. To avoid confusion, dissimilar treatment, and unintended consequences, ABA believes the Bureau should maintain one set of definitions, using the term remittances to be consistent with the existing rule and the terminology of the statute. extent of relevant State oversight, and any field and market information that CFPB has on the entity. Federal Register, volume 79, No. 21, Friday, January 31, 2014, p

5 Additional Comments The Test to Define Larger Participants Should be Streamlined The Bureau is considering several criteria to identify covered nonbanks, including annual number of transfers, annual receipts, and annual dollar volume transmitted. The Bureau proposes to use the annual number, measured as a three-year moving average. While ABA supports the general concept that identifies a covered nonbank based on the annual number of transfers, and agrees that using an average over several years is logical, we question whether the complexity of the proposed calculations is necessary. There should be a simpler mechanism in place to identify which providers are covered without all the arcane calculations that the Bureau suggests in the proposal. The more complex the calculations, the greater the chance for error and the less transparent are the entities covered. The Bureau is also considering whether to apply different thresholds for different regions based on the region where transfers are sent, but it has raised concerns that such an approach might be difficult to administer. ABA agrees that an approach based on the region where a transfer is sent would be difficult to administer, would be unduly complex and, as a result, highly prone to error. To avoid unintended consequences and needless burden and argument, ABA believes a simple approach is preferable. Therefore, ABA supports a threshold based on the total number of annual transfers sent by a provider, similar to and consistent with the approach already adopted for depository institutions. Agents Play an Important Role ABA agrees with the Bureau that agents play an important role in the remittances market and supports the proposal to define an agent in accordance with applicable state law. Using state law to define agency status is consistent with other applications, including the remittance rule. ABA also agrees that it is appropriate to include transfers by an agent when determining whether a provider is covered and therefore subject to Bureau oversight. At the same time, since agents can have relationships with other providers, the proposal would specify that transfers that an agent conducts for other providers would not be included in determining coverage. ABA agrees but urges the Bureau to simplify the specification of which transfers by agents are included in the calculation; the articulation of coverage in the current proposal seems unnecessarily complicated. A second aspect to the agency relationship is the authority which the Bureau has over agents. Given the important role that agents play in this market, when an agent acts on behalf of a larger participant supervised by the Bureau, then the Bureau would have the authority to supervise the agent s performance as well; ABA concurs that this is logical and appropriate. Affiliates Must be Recognized As proposed, the aggregate annual international money transfers for each nonbank would be the sum of the annual international money transfers of the nonbank and its affiliated companies. While the annual money transfers of each affiliated company would be calculated separately and each affiliate would be treated as if it were an independent nonbank covered person, the totals would be aggregated to determine whether the affiliates are subject to supervision by the Bureau. ABA agrees with this approach. Since the goal is to ensure consistency and uniformity for the market and for consumers who use the market, and since nonbanks are not otherwise subject to comparable federal oversight, ABA believes this will support the Bureau s stated goal of the regulation to protect consumers. 5

6 Costs & Benefits The proposal identifies a number of costs and benefits associated with the proposed rule. Since supervision of larger participants would be probabilistic in that the Bureau would determine when to conduct examinations, and while examinations would not be regularly scheduled, the Bureau believes that the prospect of an examination creates incentives for larger participants and their agents to allocate resources and attention to federal consumer financial law. When the Bureau actually conducts an examination, it would be able to identify compliance weaknesses which could be corrected through supervisory activity or enforcement. Increased compliance would be beneficial to consumers by increased transparency, facilitated dispute resolution, and identification of UDAAP issues. The proposal also should increase consistency between nonbanks and banks. While the Bureau anticipates that increased costs likely will be passed on to consumers, it believes that since small nonbank providers would not be affected, their costs would not increase, which in turn would reduce the likelihood that larger participants would increase prices. ABA disagrees with this premise and suggests that it misinterprets how the market will operate. First, if a non-covered provider has a relationship with a larger covered provider, the costs incurred by the larger entity will be passed down. Second, and more important, when larger participants are compelled to increase price, it is likely that smaller entities will increase fees to take advantage of market factors. Third, many of the other factors that come into play, including new disclosures and other requirements that apply regardless whether the Bureau supervises the provider or not, will also compel increased fees for consumers. Therefore, ABA believes that the entire fee structure for consumers will rise as the new regulatory regime goes into effect. Types of Costs According to the Bureau, there would be two major categories of costs associated with the proposal: costs associated with increased steps for compliance in response to Bureau findings, and increased cost of supporting supervisory activity. The Bureau, using its analysis for nonbank payday lenders as a proxy, estimates it will take approximately 10 weeks for an examination: 8 weeks on-site and 2 weeks prior for the nonbank to prepare. Using this preliminary calculation, the Bureau further calculates that this would require one full-time compliance officer plus one-tenth of a legal attorney s time for approximately $23,500 total for the examination of a large nonbank international money transmitter. Based upon the examination experience of our members, ABA suspects that this grossly understates the time and effort that a covered entity will need to prepare for an examination, particularly for assembling data and information required by examiners and the time and effort necessary to support the large examination teams that the Bureau has been sending to institutions. This will be especially likely if the data are not readily available in current market conditions; ABA suspects it is not. The proposed analysis of costs likely to be incurred also does not include costs for determining whether an entity is covered, since the proposal does not require nonbanks to determine if they are covered. ABA believes this omits a critical part of the equation, inasmuch as it is likely that most nonbank providers will take steps to determine whether they are covered and subject to the Bureau s oversight since responding to Bureau requests and examinations will be an important element to any company s strategic plan and budget. 6

7 Conclusion Thank you for the opportunity to comment. ABA encourages the Bureau to take the appropriate and necessary steps to streamline the application of the proposal by simplifying the steps necessary to determine whether a large nonbank participant in the market for remittances should be subject to supervision by the Bureau. By using consistent definitions, lowering the threshold, and simplifying the calculation of the threshold, ABA believes that the Bureau will be more likely to foster the goal of consistent protections for all consumers. Sincerely, Robert G. Rowe, III Vice President & Senior Counsel 7

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