The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether the 2014 larger participant rule for international money transfers should be revised to better reflect market conditions and supervisory priorities. Comments are due September 22, 2025.
Current Rule Snapshot
Market |
Current Threshold |
Rule Adoption Year |
Comment Deadline |
|
International Money Transfer |
$1 million annual receipts |
2014 |
September 22, 2025 |
There has been no proposed change to the definition at this stage. The current rule, found in 12 C.F.R. § 1090.107(b), defines a nonbank as a "larger participant" if it has more than $1 million in annual receipts from international money transfer services, which are electronic transfers of funds requested by a sender in the United States to a designated recipient in a foreign country, whether or not the provider holds the funds at any time.
The CFPB, citing data collected by state regulators from the fourth quarter of 2023 through the third quarter of 2024, estimated that about 28 nonbank covered persons currently meet the threshold set by the rule.
Questions for Comment
The advance notice of proposed rulemaking seeks input on whether the current threshold of $1 million in aggregate annual international money transfers continues to be the most appropriate measure for identifying larger participants in this market. In particular, the Bureau has expressed concern that the benefits of supervising smaller providers under the existing rule may not justify the associated compliance costs, especially for firms whose revenues fall below the Small Business Administration's $28.5 million annual revenue threshold for money transmission services (NAICS Code 522390).
Commenters are encouraged to address:
- Whether the Bureau should raise the current threshold to reduce supervisory coverage of smaller providers whose compliance costs are disproportionate to their market share
- Whether alternative metrics—such as the total dollar value of transfers—would more accurately identify the largest participants
- The availability of additional data sources to estimate market size, participant mix (nonbanks, banks, credit unions), and the number of entities that would qualify under different thresholds
- Potential disproportionate impacts on specific geographic corridors or consumer segments, including rural consumers, servicemembers, and veterans, if the threshold is increased
- The costs to covered persons—both specific to CFPB supervision and related to monitoring larger participant status—and whether those costs are proportionate for entities near the threshold
- The impact on consumers of raising or otherwise changing the threshold, including potential changes to pricing, service availability, or competition
- Any recordkeeping or reporting requirements that could be reduced by adjusting the threshold
- Other costs or benefits to consumers or market participants not identified above
Why It Matters
A relatively low current threshold means many smaller providers are subject to federal supervision. Changes could either narrow oversight to major players or extend it further into the long tail of providers.
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International transfer providers should review their receipts, consider the operational impacts of threshold changes, and file comments by September 22, 2025.
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