ABA Comments on the CFPB’s Request to Survey Consumers on Overdraft Disclosure Forms

ABA filed comments to the Consumer Financial Protection Bureau on its notice and request for comment regarding “Web-Based Quantitative Testing of Point of Sale/ATM (POS/ATM) Overdraft Disclosure Forms.” The bureau requested approval under the Paperwork Reduction Act to conduct a national web-based survey of 8,000 individuals as part of its study of overdraft protection services.

ABA urged the bureau to resubmit its PRA request to the Office of Management and Budget with a draft survey, in order to maximize the opportunity for informed public comment. “The Bureau’s decision to withhold the draft survey instrument in its current OMB submission, as well as its prior use of the generic clearance process for other overdraft research, limits the public’s ability to comment and undercuts effective regulatory oversight by OMB,” ABA wrote. For questions, contact ABA’s Jonathan Thessin.