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NAFCU Regulatory Affairs Counsel Kavitha Subramanian expressed concerns in a letter Monday to CFPB about the lack of detail in the bureau's request for permission to conduct a national survey on consumers' use and understanding of overdraft protection services.

"While NAFCU and our members appreciate the CFPB's effort to understand consumer activity in this market prior to engaging in any rulemaking, we are concerned that this [Paperwork Reduction Act] notice failed to include the actual survey questions for public comment," Subramanian wrote. "NAFCU firmly believes the validity and usefulness of the survey data hinges on the form and substance of the questions."

Subramanian requested that the bureau publish its consumer survey for public comment before beginning its data collection effort.

She also noted credit unions' track record of working closely with their members on any concerns regarding overdraft fees by highlighting NAFCU's June 2015 Economic & CU Monitor survey, which found that nearly every respondent (97 percent) will reverse an overdraft charge on a case-by-case basis.

NAFCU Director of Regulatory Affairs Alicia Nealon met with CFPB staff in September about the bureau's pursuit of data on overdraft programs. Last month, NAFCU and four other financial trade associations wrote the bureau expressing their concern about the survey.

NAFCU has been the only credit union association to consistently defend access to overdraft programs for credit unions.