WASHINGTON—The CFBP in is being asked to extend its request for information related to its survey of consumers on overdraft disclosure forms.
In a letter to the Bureau, NAFCU's Michael Emancipator argued that more time is needed to consider the proposed survey questions as the CFPB didn't release them until 12 days before comments were due.
Emancipator, NAFCU senior regulatory affairs counsel, wrote that the form and substance of survey questions masked the survey's usefulness. He requested the Bureau provide stakeholders more time to review and comment on the questions recently released.
The CFPB issued the request for comments on its plan to conduct an online survey of consumers' understanding of ATM and debit card overdraft disclosures in November. The purpose of its survey is to explore consumer comprehension and decision-making in response to overdraft disclosure forms, and to gain insights to consumers' financial product usage, behavioral traits, and other characteristics that might influence a consumer's use of overdraft programs and disclosure forms.
NAFCU has urged the CFPB to exempt credit unions from any potential overdraft rule, as the loss of such programs could lead credit union members to seek out more expensive alternatives, the trade association stated.
In the letter, Emancipator noted that "credit unions have developed responsible overdraft programs that are often coupled with free financial education and counseling services," which ensures credit union members are informed of the benefits and uses of overdraft products.
Emancipator also wrote that instead of limiting or eliminating overdraft services, the CFPB should provide "the financial services industry with guidance and additional flexibility so that credit unions can create even more options that fit the various needs of their members, whether it be convenience or access to cash."