Removing Barriers Blog

CUNA Writes to the Bureau on their Proposal on its Policy to Encourage Trial Disclosure Programs
Posted October 10, 2018 by CUNA Advocacy

CUNA filed a comment letter to the Bureau of Consumer Financial Protection on October 10th regarding their proposed policy to encourage Trial Disclosure Programs (TDPs). CUNA is generally in support of the revised TDP policy and the Bureau's big-picture focus on supporting innovation in the financial services sector. They did, however, make a few recommendations on the proposal including considering a 30-day timeframe for denied TDP approvals; allowing a 90-day timeframe for extension requests on approved TDPs; a statement on how the agency will address State law considerations, "including whether preemption may apply or if the Bureau intends to engage in state-by-state arrangements, such as memorandums of understanding (MOUs), related to liability."