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CFPB’s Trial Disclosure Program Open for Comment

Posted in Regulatory and Compliance

The CFPB is currently seeking comment on its proposed “Policy to Encourage Trial Disclosure Programs.” The Policy is intended to “encourage banks, thrifts, credit unions, and other financial services companies to innovate by proposing and conducting” trial consumer disclosures for limited test periods, subject to the terms and conditions approved by the CFPB. The trial programs would allow banks and other companies to research and test new and innovative consumer disclosures, after which the company would share the results of the program with the CFPB to help improve disclosure rules and model forms.

The Policy itself is organized into four sections: (1) eligibility requirements for participation in the trial program; (2) factors for approving proposals; (3) terms and conditions under which the proposal may be conducted; and (4) public disclosure of information regarding the trial program. The CFPB has requested comment on any aspect of the proposed Policy, including in particular the information to be submitted to the CPFB by any company seeking approval to participate in the trial disclosure program.  Comments must be submitted by February 15, 2013.