The National Consumer Law Center submitted the following comments on behalf of its low-income clients, as well as the listed national and statewide organizations, all representatives of low and moderate income senders of remittances. In addition, the above-listed law professors teach and research extensively in the areas of consumer and/or payments law, have signed on to these comments.
All of these organizations and individuals have serious concerns with the proposed exceptions to consumer protections included in this docket. The Consumer Financial Protection Bureau (“CFPB”) has proposed three reductions in consumer protections for remittance senders. One of these reductions is quite serious: eliminating from coverage under the error resolution rules the delivery of the remittance into the wrong account because of the sender’s mistake with the account number.