WASHINGTON—CUNA has sent a comment letter to the CFPB on the Bureau’s overdraft disclosure prototypes.
In the letter, signed by Luke Martone, senior director of advocacy and counsel, CUNA says that it generally supports the prototypes, but still has concerns.
A primary concern, CUNA states, is that the study supporting the prototypes is based on the same data used for an earlier CFPB study and whitepaper, which was collected from a handful of the largest banks back in 2011-2012.
“It is important that policy decisions rely on accurate information, which necessitates the use of timely information. The CFPB should ensure it has an accurate picture of institutions’ current processes and practices, as financial institutions are constantly innovating and updating their operations. While it may be of some value, data collected in 2011 and 2012 is unlikely to be representative of transactions occurring in 2017. Increased competition in the financial services space, together with the rapid pace of technological advancements, force institutions to continually evaluate and update their services and the way they employ such services. Thus, we urge the Bureau, which describes itself as a data driven agency, to refrain from instituting any policy decisions related to overdraft—or otherwise—based on years-old data.” Martone wrote.
For the full letter go to CUToday.info’s The Gov.