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Regulatory Advocacy

Working Together to Reduce Regulatory Burdens
Regulation Summary
Agency Consumer Financial Protection Bureau
Comment Due Date 10/19/15

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In accordance with the Paperwork Reduction Act, the CFPB is requesting a new information collection titled, Web-Based Quantitative Testing of Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms. The CFPB is seeking approval from the Office of Management and Budget (OMB) to conduct a national web survey of 8,000 individuals.

The CFPB is currently in the pre-survey stage. This current request for comments relates only to the CFPB’s request to OMB. Once the survey has been developed, the CFPB will solicit input via a subsequent rulemaking.

“The survey will explore consumer comprehension and decision-making in response to revised overdraft disclosure forms. It will also explore financial product usage, behavioral traits, and other consumer characteristics that may interact with a consumer’s experiences with overdraft programs and related disclosure forms. The survey will include a representative sample of the U.S. adult checking account-holding population, with oversampling of respondents who are more likely to have experience with overdraft fees.”

The CFPB is reviewing the current model form disclosure associated with financial institutions’ overdraft programs to identify whether alternative content or design of the form may better support consumer comprehension and decision-making.

Comment Request: While the request for comments focuses on the need for an information collection, please send CUNA any comments/questions/concerns related to the forthcoming survey that you would like us to convey to the CFPB. The CFPB is accepting comments until November 3; please send CUNA your comments by October 19.