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CBA Joint Comment Letter on the CFPB's Proposal on Trial Disclosures
Dear Ms. Jackson:
The Consumer Bankers Association, the American Bankers Association, and the American Bankers Insurance Association (collectively, the “Associations”) appreciate the opportunity to submit comments on the Proposed Policy (“Proposal”) to exempt individual companies, on a case-by-case basis, from current federal disclosure requirements in order to test “trial disclosures.” The Associations generally support the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) which seek to “promote consumer access and innovation” and improve “consumer awareness, understanding of, and responses to disclosures or communications about the risks, costs, and benefits to consumer financial products or services.” In addition, we applaud the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) on its effort to promote in-market testing involving companies and consumers in real world situations, rather than simulated or focus-group testing, and for encouraging financial services companies to propose alternatives to existing disclosures.
To read the full Comment Letter, download the PDF.