OLA Provides Comments on Enhanced BCFP Trial Disclosure Program

Recently, the newly created Office of Innovation at the Bureau of Consumer Financial Protection (BCFP) announced changes to its “Trial Disclosure Program”. Under Dodd-Frank, the BCFP was given the authority to allow companies the ability to conduct trial disclosure programs and to provide a safe harbor (or waiver) from the corresponding applicable regulatory requirements. The BCFP published the original trial disclosure policy in October 2013, but the program failed to attract industry participation. It is the Bureau’s hope that the efforts to streamline the program will encourage new industry interest.

In commenting on the new policy, OLA requested that the Bureau provide additional details on the portion of the proposal allowing trade associations the ability to apply for waivers on behalf of their members. Also stressed in OLA’s comments was the need to ensure that the protection companies receive under the program extend beyond BCFP to include other federal and state regulators.