These comments are filed by the National Consumer Law Center, on behalf of its low-income clients, and by the National Association of Consumer Advocates.
The proposed rule would identify a nonbank market for international money transfers and define “larger participants” of this market that would be subject to the Bureau’s supervisory authority. We support this proposal. However, we strongly encourage the CFPB not to limit this supervisory application to providers of international money transfers, but to include providers of all money transfers – including domestic transfers.