CFPB sets final trial disclosure policy
CFPB has finalized its new trial disclosure policy, which allows companies to apply for exemptions in order to develop and test potential disclosure improvements on a trial basis.
The new policy lays out which programs will be considered for the temporary waiver, the factors the CFPB will consider in deciding which eligible programs to approve for the waiver, procedures for issuing them and how the CFPB will disclose information about the programs.
NAFCU, commenting on the policy in February, warned that the potential cost of the program might keep most credit unions from participating unless costs can be split among a number of institutions. CFPB incorporated that approach into its final policy, which allows institutions to cost-share and collaborate as long as CFPB approves each participating institution.
NAFCU also noted in the comment letter the association’s concerns with the structure of the program since disclosures must meet certain standards and be approved by CFPB. The letter also noted concerns about the program’s structure, which could mean credit unions end up with the costs for at least two disclosure requirements – an initial trial disclosure and a second disclosure if the first one is waived.
This policy is expected to be published soon in the Federal Register.continue reading »