The Consumer Financial Protection Bureau ("CFPB") proposed amendments to its 2012 "Encourage Trial Disclosure Programs" policy (the "Policy"). The Policy is intended to encourage companies to create tailored consumer disclosures that may be more effective than those required by law.

The proposed revised Policy would:

  • streamline the application process for companies and reduce unnecessary burdens;
  • provide additional guidance to companies with regard to the testing timeframe;
  • clarify the procedures for requesting an extension of waivers for successful trial disclosure programs; and
  • coordinate with other regulators that have similar programs to further consumer-beneficial innovation.

Comments must be submitted by October 10, 2018.

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