ARLINGTON, Va.–NAFCU told the Consumer Financial Protection Bureau that it should have included the survey questions it intends to use as part of a national web-based survey of 8,000 individuals that is part of its ongoing study of overdraft protection services.
"While NAFCU and our members appreciate the CFPB’s effort to understand consumer activity in this market prior to engaging in any rulemaking, we are concerned that this PRA notice failed to include the actual survey questions for public comment," noted NAFCU Regulatory Affairs Counsel Kavitha Subramanian in the letter. "NAFCU firmly believes the validity and usefulness of the survey data hinges on the form and substance of the questions. Therefore, NAFCU urges the CFPB to publish its consumer survey for public comment prior to beginning this data collection effort."
NAFCU’s letter is in response to the CFPB’s request for approval under the Paperwork Reduction Act (PRA) to conduct the national web-based survey of 8,000 individuals.
“Accordingly, NAFCU and our members strongly urge the CFPB to craft its consumer survey instrument in a way that allows consumers to provide feedback on how they interact with their financial institution before and after incurring an overdraft fee,” said NAFCU. “The CFPB must be careful to allow the consumer data to be objective and neutral, while avoiding the easy pitfall of tailoring questions toward preconceived notions about consumer attitudes and understanding of overdraft products in the market.”
In its own letter to the CFPB, CUNA is asking the Bureau solicit input via a subsequent rulemaking, once the survey has been developed.
“We believe it is critical that the public—including consumers—have the opportunity to review the survey before it is administered,” stated Luke Martone, CUNA’s senior director of advocacy and counsel. “Credit unions offer overdraft programs as a convenience and accommodation to their members. As the Bureau contemplates whether new rules are needed for overdraft protection programs, we urge it to continue its thorough approach to ensure it has obtained all relevant information. Further, we encourage the CFPB to continue to study overdraft so that it can gain a better understanding of the benefits consumers derive from this product, and the differences between the overdraft products offered by credit unions and other financial institutions.”