ARTICLE
13 September 2018

CFPB Proposes To Revise "Encourage Trial Disclosure Programs" Policy

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Consumer Financial Protection Bureau ("CFPB") proposed amendments to its 2012 "Encourage Trial Disclosure Programs" policy (the "Policy").
United States Consumer Protection

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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