From: CU Press
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Survey Content for Public Comment
NAFCU appreciates the CFPB’s consideration of consumers’ use and understanding of overdraft services prior to proposing any regulations in the market. Any premature regulation in the market could disrupt consumer access to important and transparent financial services. NAFCU and our members are concerned that the Bureau did not include in its submission to the Office of Management and Budget (OMB) a draft survey instrument on which the public could comment.
As NAFCU communicated to the Bureau in our letter on September 30, 2015, we remain disappointed that the CFPB declined to include a draft survey instrument in its submission to the Office of Management and Budget (OMB). Failure to include this instrument denies credit unions the opportunity to provide comments on questions being asked about credit union programs. As member-owned cooperatives, credit unions design their overdraft programs to best meet the needs of their members within the regulatory requirements. Without seeing the survey instrument first, NAFCU and our members are concerned that credit unions will be unable to conclude if the Bureau has considered the unique programs that credit unions tailor for their individual memberships. Further, without seeing the questions, NAFCU and our members are unable to offer suggestions about how the Bureau can account for a credit union’s unique structure in its survey. Therefore, NAFCU strongly urges the Bureau to re-submit its information collection request with the draft survey instrument to be in compliance with the OMB guidance.
NAFCU firmly believes the public must see the form and substance of the survey questions prior to circulation in order to ensure that they are neither biased nor misleading. Because the data to be collected from the proposed consumer survey will likely affect any proposed regulations the bureau may issue regarding overdraft disclosure, NAFCU believes it is vital that the public be given an opportunity to comment on the form and substance of the survey.