The CFPB announced that it finalized its policy to approve requests by supervised entities for waivers from consumer disclosure obligations to allow for the testing of alternative disclosures. The Dodd-Frank Act gives the CFPB authority to approve trial disclosure programs. The policy is divided into four sections: (1) Section A describes which proposed programs will be considered eligible for a temporary waiver; (2) Section B lists factors the CFPB may consider in deciding which eligible programs to approve for such a waiver; (3) Section C describes the CFPB’s procedures for issuing waivers; and (4) Section D describes how the CFPB will disclose information about the programs. Some factors the CFPB will consider in determining whether to grant a waiver include improvements to consumer understanding, increased cost effectiveness and decreased consumer risk.
Alert October 15, 2013