Category: Comment Letters

MSBA submits comment letter to the CFPB on the Remittance Rule

MSBA submits comment letter to the CFPB on the Remittance Rule

The MSBA submitted a comment letter to the CFPB to explain that  the obligations imposed on RTP’s through the Remittance Rule are in many ways redundant to rules already in place at the state level. Additionally, any consumer protection benefits they do afford are outweighed by the burdens imposed upon RTPs which are already sufficiently regulated by other federal agencies and the individual states. We therefore provide several recommendations for modifications to the Remittance Rule which will greatly reduce the burden and costs imposed on RTPs without sacrificing the Rule’s intended purpose of protecting consumers in the United States.

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MSBA submits comment letter to the OCC

MSBA submits comment letter to the OCC

The MSBA submitted a letter to the OCC noting our questions and comments regarding their proposed National FinTech Charter. We commended the OCC for exploring new and innovative ways to increase payment innovation and reduce duplicative regulatory burdens. The concept of a Special Purpose National Bank Charter for Fintechs (to be referred to herein as the “Fintech Charter”) is one that has garnered a lot of attention and inquiries over the last few weeks.

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MSBA Comment Letter on NMLS Call Report

MSBA Comment Letter on NMLS Call Report

December 4, 2015 NMLS MSB Call Report Working Group Re: Request for Comment: NMLS – Money Services Business Call Report – Proposal 2015- 3. Dear Ladies and Gentleman: This letter is submitted to the NMLS Working Grou ...

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