CFPB Proposed Policy: Trial Disclosures
The Consumer Financial Protection Bureau (CFPB) recently issued a proposed policy, which can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-12-17/pdf/2012-30159.pdf to encourage trial disclosure programs. Comments are being taken on this proposed policy until February 15, 2013.
The CFPB is allowed, pursuant to subsection 1032(e) of the Dodd-Frank Act, to provide a legal “safe harbor” to companies conducting disclosures trials. Or in other words, the CFPB will “deem a participating company ‘‘to be in compliance with’’ or ‘‘exempt from’’ otherwise applicable federal disclosure requirements for a defined period.” 77 FR 74626
The CFPB hopes to facilitate innovation in improving consumer protection in financial products and services by encouraging financial services companies, including credit unions, to propose and conduct “in market” testing.
The proposed policy discusses how programs will be considered eligible for a temporary waiver, the factors that the CFPB may consider when approving a waiver, procedures for issuing a waiver and how the CFPB will disclosure information about the proposed programs.
Should you have any questions or concerns on this or any other compliance topic, please do not hesitate to contact Amy Kleinschmit at email@example.com or 701.214.9721.