CFPB Proposes Allowing Companies To Run Trial Disclosure Programs

The CFPB has announced its proposed policy to allow companies to test new consumer disclosures on a case-by-case basis. As part of its Project Catalyst initiative, and in line with its statutory authority, the CFPB’s goal is to encourage banks, credit unions, and other financial services companies to propose and conduct trial disclosure programs.

Under the proposed policy, the Bureau would approve individual companies, on a case-by-case basis, for limited time exemptions from current federal disclosure laws in order for those companies to research and test informative, cost-effective disclosures. The companies involved will then share the results of their trial disclosure with the CFPB. The CFPB will use that information to improve its disclosure rules and model forms. The public will have input through the rulemaking process.

When deciding whether or not to grant a company a waiver from current disclosure requirements, the Bureau proposed policy would evaluate a number of factors including:

  • Consumer Understanding: The Bureau will assess how effectively and efficiently the proposed trial will test for potential improvements to consumer understanding about the costs, benefits, and risks of products and services.
  • Cost Effectiveness: The Bureau will evaluate how the proposed trial will help develop more cost-effective disclosure rules or policies.
  • Minimizing Consumer Risk: The Bureau will evaluate the extent to which the program is designed to mitigate any risk to consumers.

Check frequently for updated information on the JOBS Act, the Dodd-Frank Act and other important securities law matters.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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