Meanwhile, the CFPB on Dec. 21 proposed revisions to its remittance rule that would relax requirements to disclose taxes and fees imposed by foreign governments and the recipient's institution. The CFPB also proposed that remittance providers would not be required to bear the cost of funds that cannot be recovered when a consumer provides incorrect account numbers.

However, remittance providers are still required to disclose up front other fees and taxes, as well as the exchange rate, and must also provide consumers with transaction cancellation rights.

Despite a previously scheduled Feb. 7 compliance date, the CFPB will delay the rule's effective date until sometime this spring.

Rather than set an effective date following the publishing of the rule in the Federal Register, Dunn said, she expects the CFPB to publish the final rule on its website next month, with the bureau mandating compliance 90 days later.

While legal, she said the process is “definitely a departure from the process other agencies use,” and Dunn added she is concerned other regulators will follow suit. The publication of rules in the Federal Register provides a valuable delay for implementation by financial services providers that would be lost if the process is changed, she said.

Hunt said NAFCU will give CFPB feedback regarding that process. The Administrative Procedures Act provides a uniform process and comment period for federal rulemaking, she said, and “everyone should play by the same rules.”

In reality, the publication of new rules in the Federal Register provides only a week or two of lag time, Hunt said, so the elimination of that wouldn't make a huge impact. However, the volume of new rules coming out of the CFPB have been difficult to manage, she said.

“Sometimes, every day does count,” the NAFCU attorney said.