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Letter to CFPB on Overdraft Survey

The Consumer Financial Protection Bureau (CFPB) is reviewing the current model form disclosure associated with financial institutions’ overdraft programs to identify whether alternative content or designs of the form may better support consumer comprehension and decision-making. 

Missouri Credit Union Association (MCUA) understands that the CFPB is currently in the pre-survey stage and sent a comment letter on November 3, 2015. MCUA appreciates the Bureau's assurance that once the survey has been developed, the CFPB will solicit input via a subsequent rulemaking. It is critical that the public—including consumers—have the opportunity to review the survey before it is administered. Further, MCUA encourages the CFPB to continue to study overdraft so that it can gain a better understanding of the benefits consumers derive from this product, and the differences between the overdraft products offered by credit unions and other financial institutions.