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September 30, 2015
NAFCU, trades raise concerns about CFPB overdraft survey
NAFCU and four other financial trade associations expressed their concern in a letter Wednesday about CFPB's request for permission to conduct a national survey of consumers on their use and understanding of overdraft protection services.
"We appreciate the Bureau's consideration of consumers' experience with and understanding of overdraft services," the signers wrote. "However, we are concerned that the Bureau did not include in its submission to the Office of Management and Budget (OMB) a draft survey instrument on which the public could comment, despite OMB guidance requiring publication of the survey simultaneous with the Bureau's request for comment."
Other signers to the letter included the American Bankers Association, the Consumer Bankers Association, the Financial Services Roundtable and the Independent Community Bankers of America.
The signers asked that CFPB re-submit the request with the draft survey instrument, as required by the Paperwork Reduction Act.
NAFCU Director of Regulatory Affairs Alicia Nealon met with CFPB staff last month about the bureau's pursuit of data on overdraft programs. NAFCU has raised concerns that the costs of the data collection will impact credit unions indirectly. The association has also emphasized that credit unions offer responsible overdraft protections and that credit union members are happy with their overdraft services.
NAFCU has been the only credit union association to consistently defend access to overdraft programs for credit unions.
"We appreciate the Bureau's consideration of consumers' experience with and understanding of overdraft services," the signers wrote. "However, we are concerned that the Bureau did not include in its submission to the Office of Management and Budget (OMB) a draft survey instrument on which the public could comment, despite OMB guidance requiring publication of the survey simultaneous with the Bureau's request for comment."
Other signers to the letter included the American Bankers Association, the Consumer Bankers Association, the Financial Services Roundtable and the Independent Community Bankers of America.
The signers asked that CFPB re-submit the request with the draft survey instrument, as required by the Paperwork Reduction Act.
NAFCU Director of Regulatory Affairs Alicia Nealon met with CFPB staff last month about the bureau's pursuit of data on overdraft programs. NAFCU has raised concerns that the costs of the data collection will impact credit unions indirectly. The association has also emphasized that credit unions offer responsible overdraft protections and that credit union members are happy with their overdraft services.
NAFCU has been the only credit union association to consistently defend access to overdraft programs for credit unions.
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