Letter to the Bureau on its Overdraft Research Report, "Data Point: Frequent Overdrafters"

The American Bankers Association (ABA) writes in response to the Bureau of Consumer Financial Protection’s (Bureau) publication on August 4, 2017, of the overdraft research report, “Data Point: Frequent Overdrafters” (Data Point),and its release of four prototype overdraft disclosure forms (Prototype Disclosures or Prototypes). ABA appreciates the Bureau’s recognition of the need for adequate study of consumer experiences with overdraft protection as central to its consideration of the consumer value of any particular regulatory action. As we have done in the past, we offer in this instance comments on the Data Point and the Prototype Disclosures and make suggestions for additional data development and analysis, with the shared goal of promoting the use of constructive and representative information that fairly represents consumer experience with debit overdraft products.

Download the letter to read ABA's full comments.