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CFPB issues remittance transfers FAQs
The CFPB has posted a Compliance Aid in the form of "Remittance Rule FAQs related to the COVID-19 Pandemic." The document comprises three questions (and their answers) related to a provider's failure to deliver remittance transfer funds by the disclosed date as a result of certain government-mandated closures in response to the COVID-19 pandemic.
A remittance transfer provider's failure to deliver funds on the disclosed availability date would not be an error under the Remittance Transfer Rule if it could not have reasonably anticipated the closure. For example, if a government-mandated stay-at-home order that deems remittance transfers non-essential in an intermediate or recipient country is announced after the transfer is sent, there is no error if the transfer is delayed. However, if the closure was announced before the transfer was sent, a failure to deliver by the disclosed availability date is an error.