CUNA is concerned with a report on consumer testing used by the Consumer Financial Protection Bureau (CFPB) to analyze periodic statement forms for consumers in bankruptcy, but concurs with some of its findings. The bureau issued a report in February on its study that tracked comprehension, perceived utility and attitudinal reactions in response to various forms.
The data comes from 51 one-on-one interviews with subjects who had experience in various types of bankruptcy and some with no bankruptcy experience. Interviews were conducted in three locations: Arlington, Va., Ft. Lauderdale, Fla. and Chicago, Ill.
“We concur with the finding that clear information about consequences of non-payment are important to be included in the statement, even if the information appears somewhat threatening to the borrower,” CUNA’s comment letter reads. “We hope the CFPB will acknowledge that there are consequences to non-payment of borrowed funds, not only in the bankruptcy context, but in other situations as well.”
CUNA went on to urge the CFPB to go further with this conclusion and amend the forms to include more information about the consequences of non-payment, including information about late fees and when they will be assessed.continue reading »