CUNA generally supports the Bureau of Consumer Financial Protection’s policy to encourage Trial Disclosure Programs (TDP) but recommends any bureau-approved programs be narrow in scope and not excessively deviate from traditional disclosure standards.
The TDP policy outlines how the bureau, would grant a company a waiver on a case-by-case basis from federal disclosure requirements, in order to allow those companies to test trial disclosures.
In the five years the current TDP policy has been in place, the bureau has not approved a single one, which CUNA believes shows a lack of interest in the current policy. The proposal was issued to codify several improvements to streamline the application process, provide certainty for approval timeframes and making the bureau’s liability statement more prominent.
In the letter, CUNA: