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CFPB Trial Disclosure Program Now Effective




by:
Robert E. Bostrom
Greenberg Traurig, LLP - New York Office

Peter L. Cockrell
Greenberg Traurig, LLP - McLean Office

Brett M. Kitt
Greenberg Traurig, LLP - Washington Office

Gil Rudolph
Greenberg Traurig, LLP - McLean Office

J. Scott Sheehan
Greenberg Traurig, LLP - Houston Office

 
November 15, 2013

Previously published on November 14, 2013

On October 29th, the CFPB’s Notice of Policy regarding its Trial Disclosure Program was published in the Federal Register, thus making the Policy effective.1 Section 1032(e) of the Dodd-Frank Act permits consumer financial service providers to “conduct a trial program that is limited in time and scope, subject to specified standards and procedures, for the purpose of providing trial disclosures to consumers.” Also pursuant to Section 1032(e), the CFPB is permitted to “establish a limited period during which a trial disclosure program shall be deemed to be in compliance with, or exempted from, a requirement of a rule or an enumerated consumer law.” The Policy fulfills this statutory provision.

The goal of the Policy is to encourage “banks, thrifts, credit unions, and other financial services companies to innovate by proposing and conducting [trial disclosure programs].” The Policy contains four sections:

  • Section A describes which proposed programs will be considered eligible for a temporary waiver;

  • Section B lists factors the CFPB will consider in deciding which eligible programs to approve for such a waiver;

  • Section C describes the CFPB’s procedures for issuing waivers; and

  • Section D describes how the CFPB will disclose information about these program



1   The Notice of Policy is available at http://www.gpo.gov/fdsys/pkg/FR-2013-10-29/pdf/2013-25580.pdf.

 

The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.
 

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Author
 
Robert E. Bostrom
Peter L. Cockrell
Brett M. Kitt
Gil Rudolph
J. Scott Sheehan
 
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