The Consumer Financial Protection Bureau — which is in a multiyear potential rulemaking process on overdraft protection and disclosures — today released a qualitative study of consumers’ experiences with overdraft. The study is not based on survey methodology but rather on personal interviews with 88 consumers who had experience with overdrafts or non-sufficient funds fees in the previous two years.
The bureau is in the process of receiving regulatory approval for a larger-scale survey of 8,000 consumers’ experiences with model overdraft disclosures. It cautioned that the kind of study it released today “cannot reveal systematic patterns in the way that quantitative analyses can.” For example, “it does not indicate how prevalent a particular consumer experience is [and]consumers may not recall particular facts of their overdraft experience, but rather provide their overall impression or recollection of the events.”
In fact, the bureau said “the study was not designed to evaluate the accuracy of participants’ recollections about their experiences with overdraft. Instead, the study focused on participants’ perceptions of their experiences. In some cases, the events that consumers in the study reported may differ from their financial institutions’ accounting of the transactions that were assessed fees, which the researchers conducting the study did not observe.” The American Bankers Association is reviewing the study and will comment on the CFPB’s plans for a larger survey. For more information, contact ABA’s Jonathan Thessin.