Compliance Question of the Week
November 14, 2011
November 15, 2011
What’s up with the Pew Model Disclosure Box for Checking Accounts?
Senator Richard Durbin, D-Ill., has received a lot of press this month by advocating for the use of a model disclosure box for checking accounts that was developed by the Pew Charitable Trusts.
In letters written to Raj Date of the Consumer Financial Protection Bureau (CFPB) and the Presidents and CEOs of all the Illinois financial institution trade associations, Durbin urged the adoption and requirement for financial institutions to provide customers with and post on their websites the standardized, concise and consumer-friendly disclosure form created by Pew Charitable Trusts.
While transparency is very important with disclosures, the adoption of the model forms in their current form would not satisfy any other regulatory disclosure requirement that credit unions already face. The model forms are missing key elements required by the Truth in Savings Act. Can you say “APY?”
In essence, the adoption of the current model forms would be like a good faith estimate for checking accounts.
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