CUNA reiterated that the Consumer Financial Protection Bureau (CFPB) should recognize that many consumers utilize overdraft services knowingly and intentionally. The letter was sent in response to a bureau request to the Office of Management and Budget to conduct an online survey of ATM/point of sale overdraft practices and policies, specifically the overdraft disclosure form.
“Credit unions offer overdraft programs as a convenience and accommodation to their members. As the bureau proceeds with its inquiry into whether changes are needed in the area of overdraft, we urge it to engage in a thorough analysis to ensure it has obtained all relevant information,” the letter reads. “Further, we encourage the CFPB to continue to study overdraft so 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.”
The CFPB released reports in 2017, 2014, and 2013 on overdraft, all of which relied on transaction-level data from 2011 and 2012 provided by a small number of large banks.
In the letter, CUNA cautioned the CFPB on over-reliance on survey results as it continues exploring possible overdraft changes.
“While we believe it is critical that the CFPB receive substantive input on overdraft directly from consumers, we urge it to consider such feedback as part of a comprehensive study involving all stakeholders,” the letter reads.