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MCUA Files Comment Letter on CFPB Trial Disclosure Programs

On February 15, 2013, the Missouri Credit Union Association (MCUA) filed a Comment Letter with the Consumer Financial Protection Bureau (CFPB) on the agency’s proposed policy to encourage trial disclosure programs. Under the policy, if the Bureau approves a specific trial disclosure (associated with a federally-required consumer disclosure), then, for the length of an agreed testing period, the agency will deem the financial institution’s disclosure to be in compliance with, or hold it exempt from, applicable federal disclosure requirements, subject to certain terms and conditions that the agency will attach to its approval.

MCUA commends the agency for its initiative, and urges the Bureau to consider adding additional flexibilities under the policy and program to ensure that as many credit unions are able to participate in the program as possible. The regulatory advocacy team will continue to dialogue with Bureau staff and officials and do all that they can in working to minimize the regulatory burden on credit unions.