CFPB seeking approval for national web survey on overdraft disclosures

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The CFPB has published a notice indicating that it is seeking approval from the Office of Management and Budget to conduct “a national web survey of 8,000 individuals as part of its study of ATM/debit card overdraft disclosure forms.”

The CFPB states in the notice that the survey “will explore consumer comprehension and decision-making in response to revised overdraft disclosures.” The survey will also explore “financial product usage, behavioral traits, and other consumer characteristics that may interact with a consumer’s experiences with overdraft programs and related disclosure forms.” The CFPB also states that the survey will include a representative sample of the U.S. adults that hold checking accounts and oversample respondents who are more likely to have experience with overdraft fees.

Comments are due by November 3, 2015. In its Spring 2015 rulemaking agenda released in May 2015, the CFPB stated that it planned “to release the results of further studies on overdraft programs and their effects on consumers. The CFPB is also considering whether rules governing overdraft and related services are warranted, and, if so, what types of rules would be appropriate.” The Spring 2015 agenda gave an October 2015 date for further prerule activities, which presumably include the web survey.

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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