As previously covered in InfoBytes, the CFPB recently released its summer 2017 Supervisory Highlights (Highlights) outlining its supervisory progress this year. Included among the issues highlighted by the Bureau is its recent activity in the remittance transfer rule (RTR) space under Regulation E. The Highlights indicate that the CFPB intends to continue its focus on RTR compliance at both large and small institutions. Of particular note, the Bureau—for the first time—has provided informal guidance on international mobile top-up products for telephone airtime. Prior to the Highlights, it was unclear to what extent these products were subject to the RTR. The Highlights confirm that the CFPB will take the position that these products fall within the scope of the rule and has taken supervisory action against at least one institution for that institution’s failure to treat international mobile top-ups in excess of $15 as remittance transfers subject to the RTR.
This edition of the Highlights helps to clear up prior confusion around the industry regarding international mobile top-ups and bill pay products, as discussed in a recent article.