CBA Comments on Department of Education’s Checking Disclosure RFI

On Thursday, June 8, 2017, CBA and ABA submitted a comment letter in response to the Department of Education’s (DOE) “Request for Information Regarding Disclosures for Student Financial Accounts.”  In May the DOE issued the RFI requesting comment on using a model disclosure very similar to that of the recently enacted model short-form disclosure for prepaid cards.  In our comment, we strongly support transparency to ensure students make informed choices about their financial accounts, and will continue to work with the DOE to achieve that goal.  However, the proposed model disclosure for accounts not subject to the prepaid account disclosure requirements of Regulation E (which implements the Electronic Fund Transfer Act) are inappropriate for checking accounts such as T2 accounts, and will not enlighten or assist students in comparing or selecting checking accounts.  Rather, they will distract and potentially confuse or mislead students. 


We argue the model disclosure appears singularly focused on oversimplified, and at times inapplicable, terms, some of which are inapplicable to of campus checking accounts.  We believe that this approach will fail to achieve the stated objectives of the Department to enable students to evaluate the variety of deposit products and services that insured depository institutions offer.  Moreover, they will add costs that ultimately will be are reflected in the price students pay.