Partner Walter Zalenski in National Money Transmitters Association Q&AWalter E. Zalenski
The National Money Transmitters Association (NMTA) published a Q&A with Partner Walter Zalenski in their September newsletter. Mr. Zalenski discussed the CFPB's final rule, announced September 12, 2014, to oversee larger nonbank international money transfer providers – those that provide more than one million international wire transfers annually.
The CFPB is subject to certain jurisdictional limitations. It generally has enforcement jurisdiction over anyone providing consumer financial products or services, but its supervisory authority – its ability to conduct on-site examinations and gather reports on companies – is more limited. The CFPB’s supervisory authority over nonbanks in most cases exists only with respect to so-called “larger participants” in a market for a consumer financial product. The new rule defines larger participants in the market for international money transfers.