Comment from The Money Services Roundtable & the Electronic Transactions Association

Summary: The Money Services Round Table (TMSRT) and the Electronic Transactions Association (ETA) oppose several provisions of the proposed regulations regarding the excise tax on remittance transfers. They argue against the current refund procedures, the inclusion of "anti-avoidance" provisions that would tax non-cash funding sources, and the proposed effective date, requesting more time for system adaptation.