Removing Barriers Blog

CUNA & Trades Request Extension from Bureau on Proposed Policy to Encourage Trial Disclosure Programs
Posted September 12, 2018 by CUNA Advocacy

CUNA joined other trade organizations requesting an extension of the comment deadline for the Bureau of Consumer Financial Protection’s proposed policy to encourage trial disclosure programs. Specifically requesting the comment deadline be extended an additional 45 days beyond the current October 10th deadline.

“We believe that a limited, 30-day comment period may preclude the development of a sufficiently broad and complete factual record necessary to develop optimal policy action,” the letter reads. “We respectfully recommend that the Bureau extend the comment period 45 days to November 23, 2018.”

The bureau’s proposal would revise its policy in order to more effectively encourage companies to conduct trial disclosure programs, with the following goals:

  • Reducing the application burden and review time frame;
  • Increasing guidance regarding the testing time frame;
  • Specifying procedures for extensions of successful trial disclosure programs; and
  • Providing for coordination with existing or future programs offered by other regulators designed to facilitate innovation.