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Thursday, February 21, 2013

ABIA and ABA Comment on Trial Consumer Disclosure Programs

The Consumer Financial Protection Bureau should provide more incentives for financial services companies to participate in trial consumer disclosure programs, ABIA, ABA and the Consumer Bankers Association said last week in a comment letter.

The trade groups were commenting on the CFPB's proposed policy that would allow companies to test new consumer disclosures on a case-by-case basis. The CFPB would approve limited-time exemptions from federal disclosure laws to enable the companies to conduct the trials, and the bureau would use the resulting information to improve its disclosure rules and model forms.

"Companies and trade associations should be allowed to jointly develop test proposals, and be permitted to use approved trial disclosures for at least a one-year period, and for the period ... after the test during which the bureau is evaluating the results," the trade groups said.

They added that the CFPB should broaden the safe harbor for the trial disclosures to include both federal and state disclosure rules. The bureau also should be responsible for informing the test population about its participation in a trial disclosure program and the results, the trade groups said.

Read the letter.