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March 13, 2012 – NAFCU needs members' input by April 6 to its official response to the Consumer Financial Protection Bureau's inquiry into overdraft protection programs.

The CFPB is working to identify industry practices that drive up consumers' costs, mislead consumers and negatively affect low-income and young consumers. The CFPB, in its inquiry, is focusing on four key areas:

• transaction re-ordering that increases consumer costs;
• missing or confusing information;
• misleading marketing materials; and
• disproportionate impact on low-income and young consumers.

The bureau is looking specifically for input on how overdraft protection programs are set up, how they are marketed and who uses them.

The request for information about these programs includes no proposed revisions to current rules. However, the CFPB is testing a model disclosure form for overdraft protection programs. Comments are due to the CFPB April 30. For more, see NAFCU Regulatory Alert 12-EA-07 (login required).

NAFCU is also taking members' input on NCUA's advance notice of proposed rulemaking on the use of derivatives as a tool to hedge interest-rate risk. That input is due March 20; NCUA is taking comments until April 7. For more, see Regulatory Alert 12-EA-06.