WASHINGTON—Concerns around the allocation of error resolution responsibilities in the context of peer-to-peer (P2P) payments have been shared in a letter to the CFPB from NAFCU, which was responding to the agency’s request for comment regarding its Paperwork Reduction Act (PRA) notice for Regulation E.
In the letter, Senior Counsel for Research and Policy Andrew Morris drew attention to potential uncertainty around investigations of “token errors” as described in the bureau’s Fall 2021 Supervisory Highlights.
“To mitigate the compliance challenges associated with payment error investigations (and their associated information collection burdens), NAFCU asks that the Bureau clarify expectations around token error investigations, which may be difficult for a credit union to conduct without access to certain information, particularly when the underlying transfer involves a P2P service,” wrote Morris.
The Recommendations
In summary, NAFCU recommended the Bureau do the following:
- Clarify expectations around token error investigations by specifying that for P2P transfers, P2P providers be primarily responsible for investigation token errors
- Consider ways to achieve a more equitable balance of error resolution responsibilities that may be shared between financial institutions and P2P payment service providers.
“NAFCU supports clear and fair rules governing error resolution procedures for financial institutions,” concluded Morris. “By clarifying expectations for token error investigations and considering a more equitable framework for allocating Regulation E responsibilities when transfers involve P2P services, the Bureau will improve consumer outcomes by supporting a more efficient error resolution process.”
Give Us Less Than 1 Minute & We’ll Give You Good News!
The ongoing popularity of CUToday.info’s daily Fresh Today newsletter has led to a need to move to a new server in order to provide improved service to our readers. In order to continue to receive the daily email, you must register by March 7. To register, just click here. The daily Fresh Today news headlines email remains FREE! The new service is being launched as part of a partnership with ResponseGenius.