Mon, Sep 11, 2017
The Association attended the CFPB’s Credit Union Advisory Council Meeting late last week. The 18-member panel advises the Bureau on regulating consumer financial products or services and helps inform the CFPB’s policy development, rulemaking, and engagement work.
The CUAC meeting focused on the Bureau’s recently released “Know Before You Owe” overdraft disclosure models. According to the CFPB, there are four prototypes designed as one-pagers to “more clearly disclose fees and understand how ODP works in an account.”
The Bureau developed the ODP model forms based on a study of customers who frequently overdraw their accounts. However, the data was from only a few banks – credit unions were not included. During the Association's last CEO Roundtable with the CFPB, concerns that the research ignored credit unions were raised, but to date credit union industry data has not been included in the CFPB's research.
Members of the CUAC asked the CFPB to clarify its goal in offering the ODP forms, to which the Bureau responded that its primary goal is to increase consumer comprehension. Much of the feedback from credit unions was that the approach does not address the real problem -- disclosure is not the issue, the real issue is behavioral.