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Credit unions are less likely to participate in the CFPB's trial disclosure program since it puts the cost and burden on individual credit unions to design new disclosures, NAFCU President and CEO Fred Becker said Thursday.

In a comment letter to the agency, Becker noted the association's concerns with the structure of the program, which allows for limited-time exemptions from federal disclosure laws so financial institutions can develop trial alternative disclosures. Those disclosures must meet certain standards and be approved by the CFPB. But Becker pointed out that the CFPB's rules for eligibility in the program "make it very time consuming and expensive with little benefit for the credit union or the consumer."

More specifically, Becker expressed concerns about the CFPB's authority to revoke any approved waiver. That could mean credit unions end up taking on the costs for not one, but two disclosure requirements – an initial trial disclosure and a second disclosure if the first one is waived.

A better way of structuring the program, Becker said, would be offering grants to participating credit unions or allowing a group of credit unions to work and participate together in the program. "The CFPB should also consider other methods of gathering consumer understanding of disclosures such as small focus groups," Becker said.

• Comment letter