WASHINGTON (11/3/15)--A proposed survey on point-of-sale/ATM overdraft disclosure forms should be open for comment before its release, CUNA told the Consumer Financial Protection Bureau (CFPB) Monday.
The CFPB currently is in the pre-survey stage of its review of the current model disclosure form associated with overdraft programs. The survey will identify whether alternative content or designs of the form may better support consumer comprehension and decision making.
“CUNA agrees that more research about overdraft could be helpful to the CFPB, to help it better understand the value of this important service. In that connection, we support the Bureau's efforts to contact consumers directly through a survey,” the letter reads. “However, as noted above, it is critical that the public have an opportunity to comment on the survey in proposed form.”
CUNA also reiterated a number of concerns it has with potential CFPB overdraft rulemaking.
“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,” the letter reads. “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.”
CUNA also urged the CFPB to recognize that services offered by credit unions, such as overdraft programs, have associated costs and therefore it is reasonable for credit unions to assess appropriate fees for such services.