For more infomation >> Suzuki Swift 1.3 Limited - Duration: 1:01. 
For more infomation >> Audi A4 Avant 2.4 V6 *Stoelverwarming Distributieriem vervangen* - Duration: 1:00. 
For more infomation >> Train Simulator 2017. Jylland 2000 - Duration: 6:36:34. 
For more infomation >> Cette astuce naturelle supprime le psoriasis, les champignons, l'herpès, l'acné - Duration: 4:57. 
For more infomation >> Trap Beat 2017 / Rick Ross X Meek Mill Instrumental - No Regrets - Free Type Beat / Dope Rap Beat - Duration: 3:39. 
For more infomation >> Dàmaris Gelabert - La tardor que jo conec (Videoclip Oficial) - Duration: 1:12. 
For more infomation >> O Gato Preto (The Black Cat, 1941), filme completo e legendado, clássico de terror com Bela Lugosi - Duration: 1:10:21. 
For more infomation >> Kia cee'd Sporty Wagon 1.6 X-TRA AIRCO/CV/SPORTIEVE AUTO - Duration: 0:58. 
For more infomation >> Volkswagen Passat (8) GTE Connected Series Plus Passat 1.4 160 kW / 218 pk PHEV Limousine 6 versn. D - Duration: 0:58. 
For more infomation >> [HD][VOSTFR] BP Rania - Breathe Heavy - Duration: 3:49. 
For more infomation >> EVERYTHING STARES ft. Jaymoji & Viantastic「Tumble Seed🌱」 - Duration: 55:54. 
For more infomation >> Tudo Sobre: Lápis de Olho - Duration: 2:55. 
For more infomation >> Jean Dujardin, nouveau roi des nuits parisiennes - Duration: 3:05. 
For more infomation >> EMPIRE
For more infomation >> MAN 8.153 L/(F) L84F 4-Paards Veewagen, APK! - Duration: 0:54. 
Welcome to the Consumer Financial Protection Bureau's meeting of its Credit Union Advisory
Council, or CUAC. The Consumer Financial Protection Bureau is an independent federal agency whose
mission is to help consumer finance markets work by making rules more effective, by consistently
and fairly enforcing those rules, and by empowering consumers to take more control over their
economic lives. My name is Zixta Martinez. I serve as the
associate director for the External Affairs Division at the Consumer Bureau. Today's meeting
is being held at the Consumer Bureau's headquarters in Washington, D.C. This is the Advisory Council's
second meeting of the year, and, as always, we have a packed schedule. Today's meeting
is being livestreamed at ConsumerFinance dot gov, and a recording will be made available
on the Bureau's website. You can also follow CFPB on Facebook and Twitter.
Let me spend a few minutes telling you about what you can expect at today's meeting. First,
I'll introduce the Bureau's CUAC members. Then, the Consumer Bureau's director, Richard
Cordray, will provide opening remarks. Following the director's remarks, CUAC Chair David Seely
will conduct the meeting. Chair Seely will introduce Gregory Evans, Senior Counsel in
the Office of Regulations; David Low, Economist in the Office of Research; Gary Stein, Deputy
Assistant Director in Card, Payment, and Deposit Markets; and Eva Nagypal. The four will lead
a discussion about the Bureau's Know Before You Owe work related to overdraft protection.
Following the discussion, the Advisory Council will hear from Daniel Dodd-Ramirez and Olivia
Calderon, respectively the assistant director and chief strategist for special populations
for the Office of Financial Empowerment. The two will lead a discussion about the Bureau's
financial empowerment initiatives. The meeting will then adjourn at approximately 5:15 p.m.
The Bureau established a Credit Union Advisory Council to include representatives of credit
unions from across the U.S. The CUAC is charged with providing substantive information, analysis,
operational expertise, knowledge of their communities, and feedback to inform the Bureau's
work. Today's public meeting and -- and discussion is in support of this important responsibility.
As a reminder, the views of the CUAC members are their views. They're greatly appreciated
and welcome, yet they do not represent the views of the CFPB.
So, let's get started with an introduction of our CUAC members. The chair is David Seely.
He is the president and CEO of Kirtland Federal Credit Union in Albuquerque, New Mexico.
The vice chair is Katey Proefke. She's the assistant vice president and compliance officer
for Chevron Federal Credit Union in Oakland, California.
Faith Lleva Anderson is senior vice president and general counsel at American Airlines Federal
Credit Union in Fort Worth, Texas. Kayce Bell is chief development officer at
Alabama Credit Union in Tuscaloosa, Alabama. Daniel Berry is the CEO of Duke University
Federal Credit Union in Durham, North Carolina. Jack Fallis is president and CEO of Global
Credit Union in Spokane, Washington. Patrick Harrigan is chief risk officer and
general counsel at Service Credit Union in Portsmouth, New Hampshire.
Ricardo Ledezma is corporate compliance assurance manager at Credit Human, a federal credit
union in San Antonio, Texas. Sarah Marshall is CEO of North Side Community
Federal Credit Union in Chicago, Illinois. Dayatra Matthews is senior vice president
of legal and compliance at the Local Government Federal Credit Union in Raleigh, North Carolina.
Amy Nelson is CEO of Point West Credit Union in Federal -- in Portland, Oregon.
Carrie O'Connor is chief lending officer for Heritage Credit Union in Madison, Wisconsin.
Thomas O'Shea is president and CEO of Aspire Federal Credit Union in Clark, New Jersey.
Luis Peralta is chief administrative officer at Kinecta Federal Credit Union in Manhattan
Beach, California. James Spradlin is president and CEO of Park
Community Credit Union in Louisville, Kentucky. David Tuyo is president and CEO at University
Credit Union in Los Angeles, California. And Raynor Zillgitt is vice president of risk
management and general counsel at Lake Trust Credit Union in Brighton, Michigan.
We also have with us Matt Cameron, Senior Advisor for the Bureau's Office of Advisory
Board and Councils, and David Silberman, the Consumer Bureau's acting deputy director and
associate director for the Research, Markets, and Regulations Division.
I'm now pleased to introduce Richard Cordray. Prior to his current role as the Consumer
Bureau's first director, he led the CFPB's Enforcement Office. Before that, he served
on the frontlines of consumer protection as Ohio's Attorney General. In this role, he
recovered more than two billion for Ohio's retirees, investors, and business owners,
and took major steps to help protect its consumers from fraudulent foreclosures and financial
predators. Before serving as attorney general, he also served as Ohio state representative,
Ohio treasurer, and Franklin County treasurer. Director Cordray?
Thank you, Zixta, and welcome to this meeting of the Credit Union Advisory Council. We created
this body about 5 years ago because we wanted to have a consistent way to hear directly
from credit unions about what they're seeing and hearing in their communities.
We do not, of course, supervise credit unions that have less than $10 billion in assets,
which means we only conduct examinations on about a handful of the thousands of credit
unions around the country. The CUAC, as we shorthand the term, fills this gap in our
day-to-day experience and helps ensure the channels of communication and the insights
they provide can remain open at all times. So, we've found that over the years, the more
perspectives we have about our Advisory Council members' experience in the consumer financial
marketplace, the better we'll be able to figure out what, if anything, we should be doing
in response. We've found great value in the dialogue we have with our CUAC members, whose
perspectives and information influence our thinking. We talk to them about our work,
and they consistently provide essential feedback that helps us understand how their institutions
operate. Today, before we hear from our subject matter
experts in more detail, I want to talk to you about two important efforts underway at
the Consumer Bureau. The first is the work we're doing in the checking account space,
specifically on overdraft services and the data point we recently published. The second
is the work of our Office of Financial Empowerment, which seeks to help empower economically vulnerable
consumers to make better-informed financial decisions.
As to overdraft, in our fast-moving, modern economy, it's increasingly common for consumers
to use debit cards the way they used to use cash. They also write checks and arrange for
money to be taken out of their accounts through an increasing variety of channels that clear
and settle in different time frames. This makes it harder to keep track of their checking
account balances from day to day, no matter how diligent they may be about checking their
balances online or by phone. I'm understanding they're not always so diligent, uh, but that's
a choice people make. In particular, consumers living on the edge
can find themselves racking up numerous overdraft charges, and that's the concern. When every
penny counts, people need to understand how overdraft works and whether they want to take
the risk of paying overdraft fees on one-time debit card transactions and ATM withdrawals.
Last month, the Bureau released a study which finds that the 9% of frequent overdrafters
-- that is, consumer accounts with 10 or more overdrafts or non-sufficient funds fees in
a given year -- pay 79% of all overdraft fees. The study also finds that frequent overdrafters
who've opted into debit card and ATM overdraft typically pay almost $450 more, on average,
per year in overdraft fees compared to frequent overdrafters who have not opted in. So, that's
a big differential just based on the opt-in decision itself.
We also released updated model disclosure prototypes for consumers who are considering
whether to opt in to debit card and ATM overdraft services. These disclosure prototypes, if
adopted, would be intended to help people make more informed choices as to whether they
wish to be subject to debit card and ATM overdraft fees.
An overdraft occurs, of course, when consumers lack the funds in their account to cover transactions,
but the bank or credit union pays it anyway. This practice gives consumers occasional access
to funds and convenience but at a cost. Financial institutions may charge a fee per transaction
for this service, typically now around $34 per transaction, and they require immediate
repayment with subsequent deposits. Consumers who opt in to debit card and ATM
overdraft are often at risk of incurring a rash of fees when they use their debit card
or make a withdrawal at an ATM. Despite recent regulatory and industry changes, consumers
with low account balances and little margin for error continue to pay significant amounts
in overdraft fees. In 2010, new federal regulations began requiring
financial institutions to obtain a consumer's consent, in advance, before charging overdraft
fees on one-time debit card purchases and ATM withdrawals. Consumers who do not opt
in to overdraft would generally have their debit card purchases and ATM withdrawals declined,
with no charge, if the account is short of funds when they attempt a transaction.
This does not apply to checks or ACH bill payments. Here, the bank or credit union can
reject the check or electronic payment and charge an NSF fee if the account lacks enough
money, or, if the financial institution chooses to cover the transaction, it can cover the
payment and charge the consumer an overdraft fee regardless of whether that consumer's
opted in, but, again, only for transactions involving checks or online bill payment.
Given the potential to rack up hundreds of dollars in fees on debit card and ATM transactions,
choosing whether to opt in to overdraft coverage is an important decision for many consumers.
So, the Consumer Bureau has developed model disclosure prototypes that, if adopted, would
replace the existing model form that financial institutions use for consumers who are evaluating
this choice. We believe these prototype forms, like our Know Before You Owe disclosures for
mortgages and prepaid accounts, could better inform consumers to make these important financial
decisions. The prototype forms are designed to show more
clearly the cost of the fees and when they can be charged. They describe key elements
of the institution's overdraft policies in plain language. They explain that the opt-in
decision applies only to one-time debit card and ATM transactions and does not affect overdraft
on checks and online bill payments. They're also designed to make clear that debit card
and ATM overdraft is entirely optional and consumers do not need to opt in to use their
accounts. We developed the prototype forms through interviews with consumers, and we
will now test them more widely. At the same time, the Consumer Bureau is also
considering ways to make it easier and more efficient for banks and credit unions to provide
these improved disclosures to their customers. For instance, the Know Before You Owe overdraft
form, if finalized, would be readily available on our website. Institutions could plug in
their specific information online and then download the customized form for free. This
way, banks and credit unions could use the form within their existing compliance systems
and more easily update disclosures in response to any overdraft program changes or other
innovations. Whether to opt in to overdraft is an important
decision for consumers. They need their bank or credit union to describe the service fully
and accurately, while giving them a reasonable chance to consent. Very simply, they need
to know before they owe. We're working to develop improved disclosures
that can help make this process easier for consumers and industry alike, so that consumers
can better understand the terms of the deal and make an informed choice on whether to
opt in to debit card and ATM overdraft. In the meantime, we will continue to study this
issue to find the best ways to protect consumers. The second issue for today is, I want to update
you on our latest financial education and empowerment initiatives. A key part of the
financial reform law that created the Consumer Bureau mandates that we are supposed to find
ways to help empower consumers to make better-informed financial decisions. We've been working on
helping consumers build financial capability starting from a young age. We're also taking
steps to better understand financial wellbeing and support financial capability for everyone.
I want to highlight the high-quality tools the Bureau has made available to consumers
to empower them and enable them to make sound choices when faced with important financial
decisions. For consumers of all ages, the challenges
to achieving financial capability can be complex, varied, and significant. To overcome these
hurdles, we must start where good education always starts, with our children.
We all know that when we -- what we learn in school can inform and influence us for
the rest of our lives. That may seem obvious enough to everyone here, yet we must recognize
that this country has not done a very good job of providing financial education in our
schools. In our society, financial education should be as fundamental as the education
we all receive in mathematics and the language arts.
Our research has identified a number of important elements to building financial capability
in young people, both in school and outside the classroom. When parents, caregivers, and
early childhood educators support the growth of what is called executive function at an
early age, children are more likely to have an easier time making plans, focusing, remembering
details, and juggling multiple tasks. These skills can enhance their ability to learn
how to manage money and make financial decisions. As our children get older, encouraging positive
financial habits and explaining day-to-day financial decisions made within the family
allows them to have a better concept of how money works in real life. By the time they're
in high school and looking toward adulthood, our students can benefit enormously from a
standalone course on personal finance. Here, it's noteworthy that researchers have
looked at the credit outcomes of young adults who had taken a high-quality personal finance
course in high school and compared them to those of young adults in similar states without
such requirements. They found the students who had taken a high-quality personal finance
course had higher credit scores and less likelihood of credit delinquency later in life.
The work we're doing to help young people become more financially capable must also
be reinforced in adulthood, so to help consumers of all ages, we're studying people's financial
habits, the role of money in their lives, and how they view financial wellbeing. To
complement this research, we've distributed resources and engaged in fieldwork, partnering
with coaches and practitioners on various initiatives aimed at improving the financial
lives of their clients. A growing consensus is emerging that the ultimate measure of success
for financial literacy efforts should be improvement in individual financial wellbeing.
In 2015, for the first time ever, the Consumer Bureau provided a conceptual framework to
help measure success in financial education by creating a consumer-driven definition of
financial wellbeing. To develop this definition, we talked with consumers and those who worked
directly with consumers to identify what financial wellbeing means for them. Based on their responses,
we came up with four elements of financial wellbeing.
The elements of financial wellbeing are, first, feeling in control of their day-to-day and
month-to-month finances; second, being able to absorb a financial shock; third, having
a sense that they're on track to meet their financial goals; and fourth, having the financial
freedom to make the personal choices that allow them to enjoy life.
Based on these four elements, we've released a set of 10 questions that operate as a scale
to measure financial wellbeing. The scale is designed to allow practitioners and researchers
to accurately and consistently quantify, and therefore observe, something that is not easily
or directly observable, and that something is the extent to which a person's financial
situation and the financial capability they've developed provide them with financial security
and freedom of choice. This approach is gaining traction. Our scale
is now being used by the Pentagon, with their financial readiness programs, and it's being
looked at and adopted by financial education professionals in other countries around the
world. To support consumers' ability to improve their
financial wellbeing, the Consumer Bureau's providing toolkits and training for practitioners
in the field to better serve their economically vulnerable clients. Our "Your Money, Your
Goals" toolkit provides training to social service providers to address financial issues
that can hinder their clients from using their services successfully. Nationwide, over 17,000
frontline staff have now been trained to use the toolkit to help hundreds of thousands
of consumers help themselves. For caregivers and others working with older
consumers, we've created the "Managing Someone Else's Money" guides. These plain language
guides are designed to help caregivers carry out their duties and responsibilities in managing
someone else's money, an increasingly common phenomenon of modern life. So far, over 1.2
million copies of "Managing Someone Else's Money" have been distributed across the country.
Through efforts such as these and our collaboration with our CUAC members and other stakeholders,
we're reaching out to consumers wherever we find them, be it at home, in schools, amidst
the community, or in the workplace. Every part of society -- families, schools, government,
employers, financial providers, and many others -- have some role to play in boosting people's
financial capability. The Bureau currently has three companion guides
to the "Your Money, Your Goals" toolkit. One is "Focus on Native Communities," one is "Focus
on Reentry for Justice-Involved Individuals," and one is "Focus on People with Disabilities."
During today's CUAC discussion, we'd like to review the work of the Office of Financial
Empowerment with the Council, receive feedback on the new disabilities companion guide for
"Your Money, Your Goals," and discuss ways we can leverage the Council member networks
to share this information more broadly around the country. Through our work together, we
can help consumers from all walks of life attain greater financial wellbeing. We look
forward to hearing from you today on these important issues to further inform our approach.
Let me finish by first reminding you of something you already know, but you should understand,
we know, as well. Credit unions provide enormous value to millions of people around the country
and are consistent stewards of consumer interests. I believe credit unions and the Consumer Bureau
have much ground in common. We both want to see a world where consumers understand their
options, weigh their choices carefully, and make sound decisions. A more educated consumer
is a central tenet of our mission. We applaud your efforts to advance financial education
within your members, a mission we share. I look forward to engaging in these important
discussions today. Thank you. Thank you, Director Cordray and Zixta. Welcome
to the second meeting of the 2017 CFPB Credit Union Advisory Council. My name is David Seely,
and I will -- and I chair the CFPB's CUAC. I'd like to welcome members of the public,
as well as new and returning members of the Advisory Council.
I've been a part of the Council for a -- a little over 3 years, and I've observed and
participated in what I believe to be informative and productive, uh, exercises in sharing how
rules and regulations of the CFPB impact credit unions. Um, we are also allowed to raise emerging
issues facing, um, credit unions and share our input and perspectives on the Bureau's
work, uh, that protect consumers. During this afternoon's meeting, we will hear
from Council members on two issues that Director Cordray has already introduced, uh, the Know
Before You Owe initiative on overdrafts, as well as the Bureau's work around financial
empowerment. First, we'll hear from CFPB staff Greg -- Gregory Evans, who is chief counsel
of the Office of Regulations; David Lowe, economist for the -- in the Office of Research;
Gary Stein, Deputy Assistant Director, Card and Payment Markets; and Eva Nagypal, Senior
Economist and Acting Chief, Office of Research. So, with that introduction -- and I apologize
to you, Eva, uh, if I've mispronounced your name, but, um, uh --
-- uh, not an everyday common name. But, um, with that, I'll turn it over to, um, this
group to talk about the overdraft rule. Thank you very much, and happy to hear I -- to
hear that I got a promotion, as well.
I'm, uh, senior counsel in Office of Regulations, but I'd be happy to be called chief counsel.
Um, so, we're extremely happy, uh, to be here today to talk about overdrafts and very excited
to hear your feedback and think the best way to do that on this topic is, uh, Dave Low
from our Office of Research and I will provide a fairly short overview of the information
that we released in August, maybe around 15 minutes or so, um, on both the data point
on frequent overdrafters and the overdraft opt-in model form prototypes, and then we'll
reserve the remaining time to have a dialogue and a discussion, uh, hear your -- your reactions
and answer your questions there. So, with that, I'll turn it over to Dave.
Thank you, Greg. This working? There we go. So, I'm going to begin with our data point
on frequent overdrafters. First, let me, uh, explain what we mean by frequent overdrafters.
For the purpose of this research, we're going to define a frequent overdrafter as an account
holder with more than 10 overdrafts, or NSFs, in a 12-month period.
Why do we focus on frequent overdrafters? Well, in our data, they make up less than
10% of accounts but generate almost 80% of overdraft and NSF fee revenue. So, if you
want to understand the market for overdrafts, you need to understand frequent overdrafters.
Uh, what I show in this first table for you here is a breakdown by overdraft NSF group
of overdraft NSF fees and the proportion of accounts. So, you see that, uh, frequent overdrafters,
those with more than 10 overdraft and NSFs, account for less than 10% of accounts but
almost 80% of overdraft and NSF fees. So, let me briefly describe our data and our
plan, uh, for the analysis today. So, our -- our data is deidentified checking account
data from 2011 and 2012, matched with summary credit records, which, uh, includes credit
scores and credit availability. These are data from accounts at several large banks
included in the 2013 and 2014 Bureau publications. Our data is representative of over 40 million
accounts. Uh, what are we going to do with this data?
Uh, we have three, uh, major goals for today. First, we're going to examine frequent overdrafters
in detail to understand a little bit more about who they are, we're -- we're going to
examine distinct subgroups of frequent overdrafters to examine, uh, differences that may exist
among frequent overdrafters, and then we're going to compare frequent overdrafters who
have opted in to overdraft coverage to those who have not to see how outcomes differ among
those groups. So, first, let me show you how frequent overdrafters
compare to other account holders. Uh, in this table, we -- we show selected median characteristics
by overdraft frequency. Um, for example, the -- the -- the uppermost and leftmost, uh,
entry indicates that among those accounts that do not overdraft or NSF at all, the median
end-of-day balance is $1,585. That's how to read that table.
What you see from this table is that frequent overdrafters have low balances, credit scores,
and available credit compared to other account holders. So, for example, the median credit
score, uh, of an account holder with between 10 and 20, uh, overdrafts is 585, while the
median credit score of an account holder with no overdrafts is 747.
You also see, uh, that there seems to be a literal relation between monthly deposits
and overdraft frequency, but once you drop inactive accounts, um, which predominately
have no overdrafts and have very low deposits, then you see that those who overdraft most
frequently have lower deposits than those who do not overdraft. So, that's a brief summary
of how frequent overdrafters compare to other account holders.
Now let's look, very briefly, at, uh, how frequent overdrafters differ among, um, each
other. So, there's a lot more detail in the data point. Unfortunately, I don't have time
to get into that today. We implement, um, a statistical technique called cluster analysis
to differentiate frequent overdrafters by observable characteristics.
Uh, what I show you right here, um, is one result of our analysis. So, on the Y axis,
you see monthly deposits of the account holder, and -- of a -- of a given account holder,
and on the X axis, you see the credit score. And one finding from our research is that
three of the clusters, labeled 1, 2, and 3 on the graph, um, all look fairly similar
to each other. There are differences, but they tend to have low credit scores, low monthly
deposits, um, low end-of-day balances, et cetera.
There's another group, uh, Cluster 4, that looks a fair bit different from the other
frequent overdrafters in that they tend to have, uh, credit scores and, as a result,
more available credit. And there's another cluster, uh, Cluster 5,
which is about 10% of frequent overdrafters, that look very different from other frequent
overdrafters in that they have high monthly deposits and, uh, higher end-of-day balances
even though their credit scores, um, tend to range all over the place.
Plus, another interesting note, um, is that Cluster 3 tends to have about twice as many
overdrafts as all the other types of clusters, um, so they, alone, um, generate about 35%
of overdraft fee revenue. So, they're a remarkable cluster in themselves. Um, but like I said,
um, I'll have to leave more detail, um, for the data point.
Third, today, I want to compare opted-in and not-opted-in frequent overdrafters, and, again,
you have a table, um, that shows median characteristics of frequent overdrafters, this time by opt-in
status. And, for example, you see that the median, uh, not-opted-in frequent overdrafter
has an end-of-day balance of $304, which is very comparable to the median end-of-day balance
of median -- uh, sorry, of -- of opted-in frequent overdrafters, which is $312. They
also have, uh, pretty comparable monthly deposits; uh, those of opted-in account holders are
slightly higher. Um, very similar, um, count of one-time debit card transactions and very
similar credit scores. They also have a similar number of overdrafts.
Um, here, we're excluding NSFs, but we're including both feed and non-feed overdrafts
in this row. You see that opted-in, uh, frequent overdrafters have about four more overdrafts
per year than not-opted-in frequent overdrafters. Where opted-in and not-opted-in frequent overdrafters
differ a great deal is the number of overdrafts with a fee they have per year. So, in the
next row, you see that not-opted-in frequent overdrafters pay about five overdrafts a year
-- overdraft fees a year. The -- the median frequent overdrafter who is opted in pays
19 overdrafts -- overdraft fees per year. That's a -- that's a large difference.
We go into a bit more detail, um, in the data point, um, but again, in the interest of time,
I'm going to have to skip over details. And I'll be happy to take questions, um --
Yeah. Just trying to keep you guys on your toes, I guess.
Um, so what did we find in our data point? Well, just as a summary, we found that frequent
overdrafters have lower account balances and less access to credit than other account holders.
The most frequent overdrafters have very low account balances and credit scores. Some have
higher credit scores, and a few have very high deposits.
Compared to frequent overdrafters who are opted in, those who -- sorry, compared to
frequent overdrafters who are not opted in, those who are opted in look similar along
a number of dimensions. They overdraft only slightly more often. They pay many more overdraft
fees. There's, obviously, uh, a lot I didn't have
time to get into today, um, and I would very much, uh, appreciate any comments or questions
you might have, so please feel free to reach out to me. Uh, my email is David dot Low at
CFPB dot gov. Thank you. Thank you, Dave. So, also quite briefly, uh,
just wanted to provide an overview of, uh, what we also released on August 04th, which
was, um, the, uh, Know Before You Owe opt-in overdraft, uh, model form prototypes.
Uh, so as a brief reminder, as, uh, I'm sure you know, uh, there was a -- a rule in 2010,
known as the Opt-In Rule, that briefly says that before a financial institution is allowed
to charge a consumer, uh, an overdraft fee on a one-time debit card purchase or an ATM
withdrawal, that the consumer must affirmatively consent or opt in to the overdraft fee, and
the rule provides a, sort of, four-step process as to how you obtain that consumer's affirmative
consent. Uh, the first, uh, that we'll focus on today
is that you must provide the consumer with a notice, in writing or electronically, uh,
that describes the overdraft service and its costs. Uh, you also need to provide the consumer
with a reasonable opportunity to affirmatively consent, obtain the consent, and then, also,
there is a -- a requirement for a confirmation. So, in particular, we're going to focus in
on the opt-in notice that describes the service. Uh, so an additional requirement is that the
opt-in notice must be, quote, substantially similar to a model form that was issued by
the Board. Uh, we call this the Model Form A-9, and on the right-hand side here, you
can see what, essentially, the A-9 looks like. This is a version that the CFPB made, uh,
for purposes of consumer testing, and we used a -- a fictitious institution, Ficus Bank.
So, we sort of filled it out, so that a consumer would have a realistic look of what it might
look like at account opening. So, we have, for example, a -- a $34-, uh, per-transaction
overdraft fee, which is around the median. So, on August 04th, uh, we posted 4 of these
model form prototypes to our blog, um, because we wanted to share, uh, with the public and
with you where we were in the testing process, um, and these model form prototypes, you'll
see, in general, um, contain information that's quite similar to what you'd see on the Model
Form A-9 today, so very similar information about fees, uh, and so forth. But you'll notice
that there's, I hope, uh, very significant differences in terms of the way that these
model form prototypes are designed and organized, uh, in an effort to improve consumer clarity
around this decision. Uh, this -- these, uh, model form prototypes
are the results of long-form interviews. We've done one-on-one interviews with consumers,
um, more -- more than 80 of them from across the country.
So, a few other things to emphasize here is that our consumer testing is ongoing. It's
by no means done, uh, but we felt that the prototypes were in a -- a state that was,
uh -- might be helpful to share with the public and get additional feedback, uh, but we want
to emphasize that the Bureau did not issue a proposal. We're not offering additional
guidance. Um, whatever notice that your credit union may be using should still be based on
the Model Form A-9, and there's no, sort of, new interpretation about how those forms should
look today. Uh, instead, we're just sharing, kind of, where we are in that testing process.
Um, if we later propose any kind of modifications to what a model form should look like, we
would, of course, share our complete results of the testing process, and we would invite
comment both on whatever the proposed model form might be as well as the testing process
itself. So, on our August 04th, uh, blog post, we
provided an email address that you can see there. It's the CFPB_Overdraft_Forms at CFPB
dot gov. Uh, please feel free to share that. We welcome any kind of feedback you want to
send to that address and, of course, we're also hoping to hear from you today, uh, about
your reactions and thoughts on -- on the model form prototypes.
And that might be it. There we go. So, uh, quite briefly, here are two examples. There's
-- there's four different, uh model form prototypes that we posted on the blog, but here are,
kind of, two that capture the main design differences.
On the left, you'll see that there's a format that uses a, sort of, two-column approach
to compare, uh, what we, sort of, think of as the setting that the consumer is given
by default, as well as the choice to opt in, and on the right is a different format that
consumers were asked to respond to that, um, emphasizes some of the fees for the service
at the top of the form and then compares the differences between the services a little
bit lower down. Uh, you'll see that there's two other model
form prototypes that I didn't post here, but they're, sort of, variants, uh, within that.
So, I think we did pretty well on time, so at this point, uh, we'd love to open it up
to questions, in particular, uh, questions about either the -- the data point on frequent
overdrafters as well as the model form prototypes. Any que -- Faith?
Uh, yes, um, so the purpose of the -- remodeling the forms, was it to lower the overdraft fees,
um, that customers, members, are charged, or what was the exact purpose of, um, revising
the forms? That's a great question, and, um, you -- we
haven't decided for sure whether to revise the forms, but these were consumer tests with,
uh -- that we undertook with specific goals, and the goals were to ensure that consumers
were able to, uh, make the choice for overdraft services that best conformed with their preferences.
Um, we think that this is an area where consumers are asked to, um, sort of, understand a number
of things. The, kind of, basic point is to understand what the service is that's being
provided and the costs associated with it, and then, of course, in addition, the consumer
also needs to sort of think about, you know, how they value the service and how they anticipate
using their -- their account in the future. So, it's a -- it's a fairly complex question,
and so our primary goal was to see if we could increase consumer comprehension, such that,
you know, when we ask a consumer, you know, in the abstract, "If this happened to you,
and you didn't have enough money in your account and you were trying to make a purchase, would
you prefer that it be declined, or would you prefer it go through and be charged this fee?"
that whatever they select on this form corresponds to what they want.
So, uh, the -- there wasn't, uh, any sort of goal around the amount of the fee or, uh,
you know, the overdraft opt-in rates or anything like that. It was really around consumer preference.
Um, so that's what we're testing for. You -- you mentioned testing. Can -- can you,
um, give us a little bit more, um, details about the work that you're doing and going
about in conducting this testing? What does that look like? Who's participating?
Sure. Um, so as I said, to date, um, we haven't released -- there will be, at -- at some point,
a sort of comprehensive report that describes, uh, the testing process in detail, but the
way it's been done thus far is a sort of two-stage process.
And this -- the results you're seeing today are, uh, the result of that first stage, which
is, we went around the country to consumers and conducted longer, one-on-one interviews,
either a half-hour- or an hour-long interview where consumers were presented with design,
uh, prototypes and asked to make a selection and then were asked a number of comprehension
questions. And that input helps design the prototypes that you see today.
The second phase of the process will be, um, a much larger sample size of consumers who
will see one of these prototypes or, potentially, a version of the A-9, and there'll be a, sort
of, more quantitative comparison of overall comprehension in a shorter setting, so, you
know, an online -- online survey of a much larger group of participants to compare comprehension.
Dan, do -- do you still have a question? You're making an assumption that these are
intentional transactions. I'm going to give you an example where a consumer will actually
go negative and didn't realize it. Whenever you go to a gas pump and you swipe a card
-- everybody uses plastic -- a lot of them hold only a dollar. So, you may have a dollar
in your account, but you get 20 bucks' worth of gas. So, what will happen is, the member
will intentionally go negative -- or, excuse me, unintentionally go negative, because the
hold was only for a dollar and they didn't know.
Yeah, that's helpful. Thank you. We're -- we're aware of these types of situations, and -- and,
um, you know, we're -- we're considering, you know, there's -- there's a lot -- as we
sort of hinted, uh, in terms of the complexity of the payment system, there's a lot of different
types of transactions that hit consumers' accounts. There are sometimes delays in between
authorization and settlement, so, you know, we're aware that there's a lot of complexity
in this space, and we're trying to help consumers navigate and best understand, you know, the
different transactions that are hitting their accounts.
Uh, Sarah? But another way that we're trying to navigate
that a little bit is, uh -- and Gary could speak to this -- is, we've been very much
involved with the Federal Reserve efforts to move toward a faster payment system in
this country, a real-time payment system. Uh, won't quite be there yet, still, although
that is in place in some places around the world.
To the extent transactions are registered more immediately and instantaneously, there
will be less confusion for consumers, less ground for not knowing whether that one, uh,
came before that one or just -- just what. So, uh, that -- that's part of a broader strategy
on this. Sarah?
I had a comment. I'm always in favor of clear disclosures, and I think it's important to
make those available to consumers. I did want to comment, and I commented in our earlier
meeting, that we've chosen not to offer any opt-in feature to any of our members for overdraft,
and that's mostly because of the demographic that we serve. We have not figured out a way
that -- even if a member were to opt-in, that it would be a truly affordable option for
them. What we actually see is that people are using
this as a cash management tool and are more likely to use it that way and that a disclosure
wouldn't necessarily be effective. So, we're not doing it because we feel like the $34
fee, although it could be profitable and is a very profitable product for members who
bring their accounts back into line, uh, would not be the -- to the advantage of our members.
So, until we can figure out a -- a fairer fee structure or something that really takes
into account the way people use the products, uh, we don't feel like we're able to offer
it. Amy?
A quick question regarding, uh, the testing group. Does this also include English-as-second-language
members, community members? So, the testing has been conducted in English.
Uh, we're certainly aware that there are consumers who, uh, may not use that as their primary
language. You'll see on the form in the -- the -- the
section -- it's a little hard to read on this slide, but, uh, in terms of the question mark
section that has a link, uh, one of the -- the things at the very end there is, we were testing
to see if consumers understood that if they went to that consumer finance, uh, address,
that there would be options for them for other languages. So, we tested that, and there was
good comprehension around, you know, understanding that if they went to that website, that native
speakers could find resources in that language. Thank you.
Primary purpose with this slide was to show us the difficulties of dealing with the fine
print.
I -- I -- I can assure you, if -- if you saw one of these forms on an 8-1/2 by 11 sheet
of paper, it's much -- there's a lot more white space than, uh -- than you'll see on
the Model Form A-9, for sure, and, uh, we -- we've used a lot of the resources we have
here in T&I around our design -- folks to help us come up with something that's -- that's
a little bit more readable and better organized. Katey?
Thank you. First of all, I think the form is a huge improvement over the A-9. I think
it's much more attractive, easier to read, easier to understand.
One of the questions that I had is, we, whenever possible, use a model form, because we want
the benefit of a Safe Harbor situation. But one of the things we've seen in California
is that there are some pending lawsuits with, um, institutions that are using this form
because there's not enough information on here to, um, explain the difference between
actual balance and available balance. And so, a lot of institutions don't understand
-- don't know -- I -- I'm unclear as to whether I can add some additional language at the
bottom of this that would clear that up and still have the benefit of Safe Harbor or,
you -- you know -- or maybe you might want to contemplate adding that to the, um -- to
your new forms. Thank you. That -- that's very helpful. And
the, uh -- I mean, the -- the substantial similarity requirement, um, you know, it's
obviously a case-by-case basis, depending on your specific institution and what services
it offers, but that -- that's something that we'll think about.
Um, you know, part of the trade-offs here, too, that we confronted in this form is -- and
I think you'll see that we've tried to sort of keep some white space, keep away from fine
print, but the -- the tradeoff is also, it's hard to convey lots of information if you
just want to sort of keep it to, you know, the two or three big takeaways. So, there's
-- there's always a tradeoff there, and that's something we'll -- we'll keep thinking about.
Yeah, even for people who, uh, know an area extremely well, this is a challenging task
to try to take these things, boil them down into clear and understandable terms, and I
think it's something that, at least from my perspective, I think people at the Bureau
have done very well over -- over the years. And I remember one, uh, different setting.
Uh, we were over for a meeting at the White House, and it was on a -- a Know Before You
Owe version of paying for college forms that we developed, and there were a number of university
presidents sitting there. We were waiting for the meeting to begin. They all start looking
at this form; you know, it's a -- it's a very short form. And of course, they're college
presidents; they all have thoughts about it. You know, well, maybe it ought to say this,
or maybe it ought to say that. You just sit there and let them go on for
about 2 minutes, and -- and -- and then, suddenly, they all begin to realize how hard this job
really is, because they all have different directions they want to go, but it all has
to, ultimately, fit in there, be intelligible, and be clear and -- and keep the key points,
uh, highlighted as key points. It's -- it's really good work, I think, our people do in
all these markets, including, now, this one. Katey, let me, if I can, just, uh, a plug,
I guess, if you will. As Greg said, even if -- even if we decide to move forward with
a rulemaking, it will be a number of years before we'll be able to finalize a rulemaking
and new forms would take effect. We do have the authority, under our act, to,
uh, entertain pilots of alternative disclosures, and if somebody wants to come to us and say,
we have a disclosure that we think will better inform consumers than what's in A-9 or any
other model form, we're very much open for business and would love to be -- have opportunities
to try and learn and test other things and see if there are ways improving that'll -- that'll
inform ultimate rulemaking but will make life better for consumers in the meantime. So,
encourage folks to think about whether there're, uh, disclosures that they think can be improved
on and they'd like to try and try it without waiting for a change in the rule.
The sad thing is, no one has ever done that yet, uh, so we're still hopeful.
I, um -- I think we're trying to address the wrong problem in -- in this approach. Uh,
looking at your data, uh, 10% of, uh, all the users represent almost 80% of all the
actual overdrafts. So, I don't think it's a disclosure issue.
It's more of a either behavioral issue, uh -- There's more underlying issues, uh, on
why they're so frequent users, uh, of that type of, uh, service, and rather than providing
them with clearer disclosures based on, uh, the average deposit that you show -- Uh, they
obviously know these -- all these fees that are happening in their bank accounts, uh,
because, well, they are disclosed in their -- in their bank statements or -- or -- or
their account statements. So, evidently, they are aware that that's
happening, but there's something that is triggering the need for that -- for that service. So,
what are you planning on doing to address, uh, that and hopefully identify solutions
for that 10% that would result the 80% of the -- of the cases?
That's -- that -- that's a great question, and, you know, I think something that we've
been trying to ascertain is, it's -- it's very difficult, uh, from even -- you know,
we have amazing data, this account-level data that, uh, has really provided a lot of insight
into consumer behavior. It doesn't tell us anything about, uh, what the consumer wanted
or what the consumer preferred, um, whether these overdrafts were intentional, whether
the consumer had alternatives, um, and so that's something that we're still, sort of,
looking for additional insight about. So, I think there's, uh, some overlap between
overdraft users and payday users. Uh, CFSI did an analysis, uh, about some of the rationale
behind, uh, the users of payday loans, uh, so maybe that's an approach that you could,
uh, follow, uh, so that once those different profiles are identified, then specific solutions
could be, uh, uh, created. So, yes, uh, thank you very much, uh, for
your comment. Uh, I, um -- certainly, we've -- we've looked some at the -- the overdraft,
uh, payday relationship and -- and, uh, uh, that part, but I wanted to get back to your
earlier point, about whether this makes a difference for frequent overdrafters.
That's exactly what the last -- the third part of our -- our data point, uh, speaks
to, is that, you know, if you look at these frequent overdrafters, just the frequent overdrafters
who make up those 10%, whether you're opted in or not opted in makes a very big, uh, difference
in -- in -- in terms of the fees that you're charged.
So, you're right, there's a lot more, you know, going on in their lives and where, you
know, these income shocks are coming from and what are the opportunities they have,
but we feel that this -- this is an important lever in -- in making sure that they understand
that that choice is -- is really critical. Yeah, I know this. It -- it does make a difference
in the fees that they are charged, but it doesn't make a difference in the actual overdrafts
that they incur in, so. Well, the -- the good news is, I think your
question is outstanding, because you set up the second part of this meeting very well,
when our --
-- financial empowerment folks come in to talk about how we can help consumers take
greater control of their lives. I think, as Eva said, we're -- uh, and -- and
the director and Greg and everybody else have alluded to. I mean, checking accounts have
become so, um, uh -- so, um, powerful in their ability to enable consumers to transact through
multiple different methods, but it does make account management more challenging, um, and
-- and so that's a -- that's a tough tradeoff and one that I don't think can be resolved
in the short term until all the faster payments, um, overtake all the legacy payment systems
through one approach. But as Eva said, I think we have to kind of
strip away at this as best we can in a way that enables consumers to, um, you know, gain
control and -- and -- and help stabilize the market in the process. But I -- I think our
next speakers will also be able to talk to some of your more underlying concerns.
If I can just connect your point with Dan's point, with Eva's point -- In the hypothetical
you posed, of the consumer who went to the gas pump, didn't necessarily intend to overdraft,
swiped, had a $1 authorization, if that person was opted in, that person would have been
charged $34, on average. If that person was not opted in, that person would not have been
charged anything. So, these are not disconnected points.
Day? Not to belabor, uh, Luis's point, but I think
it's a good one, um, because we're a prime example of a government where, um, in contrast
to Sarah's credit union, um, all overdraft, for us, is opt in, all right? So, you have
to opt in to everything. Yet, we still have repeat overdraft, quote/unquote, offenders.
And so, that goes back to the question, is it a matter of disclosure, or is it just,
again, um, bad cash management, if you will, and need? Um, so I do think, again, he makes
an excellent point in that regard. I would love -- I mean, if you can provide
us, um, some, uh, model forms that make it clearer or more simpler, then I -- I would
certainly welcome that and -- and, um, uh, put ourselves down as the -- as the -- the
guinea pig, if you will, since we have opt in for everything, to see if there's any change
in our membership, um, uh, decisions. Quite honestly, I doubt that we would see that.
Patrick? Just briefly, uh, I also agree with, uh, others
here that the new model forms are much clearer, and that's great, and to be able to use them,
to swap out the old forms, swap in the new, is not that big a deal. I am skeptical, as
others have mentioned, about whether or not the -- the use of these will change the consumer
behavior, uh, vis-a-vis the overdraft protection. The other complicating factor that I wonder
if you're -- you're taking account of in your testing or in considering this issue is, when
these forms are given, it's usually at account opening, and you're going through -- which
-- So, you have an account opening form. You'll have all the other disclosures -- Reg E, privacy,
Reg CC. I mean, it's just a -- it's a disclosure fatigue issue. Um, often, these people, when
they're opening the accounts, are also making a -- doing a car loan, so you have all those
going on, you know, and they have to make the credit life/credit disability decision.
There's a -- there are a lot of things going on here. This is not, um, given to a member
or a customer in a vacuum. Uh, there's a lot going on. I don't know if you're taking into
account that factor. Thank you, that's -- that's very useful.
Faith? I just wanted to add, um, so, um, to what
Patrick was just mentioning. What we do is, once they opt in to the, um -- the ATM and
the debit card, we send them a separate letter just to confirm that that's what they wanted.
But also, just like what Sarah had mentioned, if, um, they don't have good credit, or they
have no credit, we offer, um -- we offer a debit card, and they cannot get, you know,
any overdraft, because it's to help them, you know, build credit, so that's what we
do. But I also just wanted to give you some technical
pointers on your form, because I think it's much easier to read, especially the one with
the three columns on the left-hand side, versus the A-9 Form. Uh, but I think it's a little
bit misleading, where you say ATM overdraft fee, um, and debit card you say no fee, because
it's really no fee, transaction denied, and that's really what, um, our members look for.
Is the transaction going to go through, um, or not?
And then, it's also, um, a little bit confusing because, you know, as you just mentioned,
um, for, um, checks and bill payment, they don't have to opt in, but in one of the forms,
you have to say, you know, check to keep as-is, but really, you know, that's what we offer
if they're -- if they qualify. And so, it's really the opt in that's most important.
Thank you, that -- that's extremely helpful. I didn't know if you had any reaction, specifically.
It's not one of the examples we put here, but there's, uh, a prototype that has an example
transaction on the other side. I don't know if you thought that that was helpful --
Uh, yes, that -- -- with answering that.
-- that -- that was helpful. Um, I know -- Uh, yes, I thought that was helpful, also, because
they could better understand. Um, I think if you also said, you know, no fee, transaction
denied, so that they can truly see, well, yes, while my balance is still only $10, I
wasn't able to pay those other transactions that I wanted. Thanks.
Sarah? Uh, so if I'm incorrect, I'd be curious to
-- to know what your thoughts are, but it seems to me like the underlying assumption
is that these overdraft fees is to frequent overdrafters for a combination of different
reasons, maybe it's credit access, maybe it's affordability. Um, and if that is the underlying
assumption, it seems like, perhaps, the disclosure is the wrong conclusion to -- to addressing
the issue. So, I'm -- I'm curious as to whether that's the assumption, uh, as to why the Bureau's
looking at this.
Um, no, I -- I don't -- I don't think that's the case. I think -- and, um -- and I think,
uh, Luis kind of raised a point, and I was thinking about this, too, is that, um, I think
there's a lot of reasons consumers overdraft, and we think that, uh, in some cases, you
know, it might be a critical moment that they are doing it consciously. In other moments,
they probably have some idea that they might be making a payment that's going to settle
and post on or near when their direct deposit or paycheck hits, but they're not entirely
sure, and they kind of take a risk, with some, maybe, incomplete understanding of the odds.
Um, in other cases, they may be entirely surprised. So, I -- I think -- you know, I -- I think
we expect, from the feedback that we've received from many outside the Bureau and our own research,
that there's, um -- you know, uh, there's instances when that courtesy helps consumers
very much, and as the evidence shows, there's people that are overdrafting a lot that have
poor credit, and they may be benefitting from that, uh, some times, but there's also instances
when if they had the total foresight to know what was going to happen with that transaction,
they probably wouldn't have executed that transaction.
And these may be one and the same consumers. You know, sometimes they want the transaction
to go through, and sometimes they don't, um, and as Eva pointed out, you know, we try to
think about, well, what are some of the things that might obscure some of that control. Um,
some of them are inherent in the way that deposit systems work, and payments, and some
of them may be in the way that the choices are presented to them. And so, again, uh,
I don't think we see this as a, you know -- a -- a cure-all for all that ails folks in terms
of overdraft, but it's one way to help consumers be in a little more control.
Carrie? Um, I apologize in advance if I maybe missed
this part, but, um, I'm -- I'm still confused about why there's such a big gap between the
number of overdrafts and the number that they're being feed for, whether they're opted in or
not opted in. I mean, is -- is that saying that financial institutions are more often
waiving fees for people who are not opted in, or, um, I guess what is -- what is driving
that? So, that's an excellent question. Thank you.
Um, we do not have the data to say definitively, uh, why that gap exists. We think there's
a strong argument to be made that is supported by our data that a phenomenon that we call,
uh, APSN -- authorize positive, settle negative -- is responsible for a large part of the
difference. Um, so, for example, if a consumer has, uh,
$50 in her checking account and swipes her debit card for a $20 transaction, um, that
transaction will be approved, um, and then, suppose a $50 check clears her account, brings
it negative, she'll be charged an overdraft fee on her check, no matter what. Um, but
then, the next day, the, uh, debit card transaction posts to her negative balance. If she's opted
in, she can be charged a fee. If she's not opted in, she can't be charged a fee.
Um, so in the data point, we examine this in a bit more detail by looking at overdraft
fees on debit cards, and we see that there is a very stark distinction between opted-in
and -- and not-opted-in frequent overdrafters. So, opted-in frequent overdrafters pay about
12 overdraft fees on debit cards per year, um, and have 1 debit card transaction without
a fee per year, um, compared to not-opted-in frequent overdrafters, who have, uh, obviously,
zero overdraft fees and debit card transactions per year and 12 debit card transactions without
a fee -- debit card overdrafts without a fee per year. So, that's a -- a -- a -- a big
part of the story. So, that does sound like it's more about the
payment system and maybe, even, the banking or credit union systems than it is about,
um, the consumer, to some degree, and -- Yeah, and that, obviously, depends on -- on,
um, a transaction posting order, all sorts of bank policies, absolutely, which we, uh,
suspect consumers don't necessarily understand when they're choosing whether to opt in or
not. Tom?
Uh, one comment and one question. Uh, one of the things that we do -- We -- we work
with employer groups. One of the things that we do for our members is, um, we post their
payroll when we receive the file, not necessarily when payday is.
So, we have one employer that the payday is Tuesday, but we receive the file every Thursday,
prior to payday. So, we post it Thursday night, so they have their money available for the
weekend, and we help minimize it, uh, so when they're shopping food and stuff over the weekend,
they've -- they've got the -- the money available. Um, so my question -- Do you have -- Have
you looked at transaction-level data to understand the types of items that are being overdrawn?
So, if it's, for example, a rent check, a large -- large-dollar item, uh, and this became
their lowest-cost alternative -- because they could go to a payday lender or another, uh,
type of lender, uh, for some money that might be higher cost.
So -- so, from a money-management standpoint and from a, um, ease of use, as well, this
may have been their best value going forward. And is there any way to incorporate that type
of comparison or -- or education in -- in a form like this?
Thank you, uh, that's an excellent idea. Um, that would be very interesting to do.
Uh, as Greg mentioned, our data is very rich in some respects, and in some -- some respects,
we wish it were richer, um, and one of those areas is that we do not, um, see why consumers
are spending their money or where it's going. Um, all we observe are transaction amount
and transaction type. So, we might see a check clearing your account for a large amount of
money at the end of the month. Um, we would not know it's for rent.
Yeah, part -- part of the reason we couldn't get that -- To get that level of detail would
require getting personally identifiable information. Uh, I -- I think we should note, though, that
we do have the ability, as -- as we've kind of implied, uh, to see overdrafts by transaction
channel, and we can see them by transaction size. And so, you know, uh, the debit card
transactions, I think the median value of the transaction was, what, 40?
FETwenty-five dollars. Twenty-five dollars, right. So, uh, you -- you
-- you can infer some of that from that. We only have, uh, time for one more question,
um, so I -- I don't think -- Jim, you haven't asked your question yet, so, uh, let's defer
to Jim. Uh, it -- it's more of a comment. We -- we've
discussed overdraft all 3 years that I've been on the committee, I think, and the thing
that always concerns me when we have this discussion is that, are we setting up a situation
where we're really going to take personal responsibility out of the equation, to where
we're going to give the consumer the right to say, there's so much going on in the payment
systems, there's so much going on, I can't be held responsible for the balance in my
checking account. I'm just going to spend. Make sure you pay everything, and don't fee
me on it; there's no consequences for my actions. So, that's just always a caution I have and
a concern I have when we start talking about this and, um, just something I like to keep
in mind as we're doing it. Okay. Thank you. Um, thank you, Eva, Gary,
Greg, and David. Uh, this was very informative. Uh, hopefully, within the next decade, we'll
have this all figured out and, uh --
-- or the -- the payment systems will just get ahead of this and, uh, uh, everything
will be real-time posted. So, thank you, again. We've actually made a commitment to get this
resolved while you're still chair, David.
Okay, we'll bring up the next, uh, group. Well, you -- you -- as -- So, now we will
move to, um, financial empowerment initiatives, and, uh, for this, um, discussion -- the second
discussion this afternoon, we'll hear from Bureau staff about the important work that
you're doing to empower consumers to take more control over their economic lives.
We have Daniel Dodd-Ramirez and Olivia, uh, Calderon here to, uh -- to speak with us.
Uh, let's see, respectively, they are the assistant director and chief strategist for
special populations -- You can get that all on a business card, I assume, and, um -- in
the, uh, Bureau's Office of Financial Empowerment. Now, that's -- whose title is that? Is that
-- I'm -- I'm the assistant director.
Okay, you're assistant director. I'm the assistant director for the Office
of Financial Empowerment. Okay, and you're the, uh --
Olivia -- Special populations.
Okay. Oh, great. Oh, they're -- they're run together, so I'll -- I'll criticize Matt for
missing a, uh --
-- uh, a comma. So, um, the, uh -- the floor is yours, Daniel and Olivia.
Great. Thank you. Not very often you have an opportunity to criticize Matt, either --
-- so. Um, thank you very much for -- for taking the time to -- to listen to what we're
doing in the Office of Financial Empowerment. Um, we are one of, um, four special population
offices here at the Bureau. I understand that a couple of committees,
um, heard from the Office of Service Members Affairs and the Office of Older Americans
this morning. Um, and so, with the Office of Students, that kind of rounds us out as
far as the four special population offices that focus, um -- that -- that -- that serve
under the Consumer Education and Engagement Division here at CFPB. Our office, in particular,
focuses on low-income and economically vulnerable consumers who -- we define people that are
at the poverty line and at twice the poverty line, so a pretty big, um, group of -- of
Americans that -- that fit that. Um, I'm really, um, again, excited to be here,
talk a little bit about some of the work we're doing. We're going to really focus on one
program in particular, which is "Your Money, Your Goals," um, and I just wanted to mention,
we've had very strong partnerships with, um, credit unions around the country as we've
rolled out "Your Money, Your Goals." Um, the -- the -- the Credit Union, um, Network
of Montana, um, really helped us, at the very initial stages, in -- in -- in piloting "Your
Money, Your Goals," um, and, um, Director Cordray spoke, um, when we launched "Your
Money, Your Goals" in Minnesota, where we had, uh, the Credit Union Network of -- of
-- of Minnesota, which was main -- our main partner in launching "Your Money, Your Goals."
Um, we've also had a lot of participation, even, um, in Mississippi, with Hope Credit
Union, um, in Mississippi. Um, so, we -- and I know that I'm missing quite a few, um, that
we've had a lot of participation from the very beginning, um, with, with this particular
product. I want to take a moment and, um, talk a little
bit about our office before we jump into "Your Money, Your Goals," and, um, Olivia Calderon
is going to talk a little bit about a new product that we've just put out, uh, and a
companion guide for people with disabilities that Director Cordray already referred to,
um, earlier in the opening remarks. I think they all have it.
Okay, great. Thank you. Yeah, you should have it in front of you.
Um, we -- we have, um, our own vision, um, within our office, um, that I've talked a
little bit about our focus, um, and you should have a -- a -- there's a -- a -- there's -- there's
a list of our values. Uh, we are really looking at the marketplace, but then we are really
thinking about how to provide tools, um, you know, that can help consumers to better manage
their finances, something that's already been spoken about by -- by members, uh, of this
-- of -- of this board. Um, and -- and we -- we -- we understand that that's really
important. Um, on the other hand, we've also really worked
looking at products, and we've done -- uh, we've just finished a random control trial
evaluation of a, uh, credit-builder loan, uh, with the St. Louis Credit Union, uh, that
really showed some very, um, exciting results. Uh, I think it's a product that I know that
most of you all, um, get behind and -- and support, and it's been offered at credit unions
and community banks for quite a long time, and we're hoping, um, through the results,
um, that we've just finished with the RCT evaluation that we did, that that will help,
um, to create more products and help to go to scale with -- you know, with things like
this that help low-income and economically vulnerable, um, consumers that are credit
invisible to build credit records. Um, so we are looking, um, in -- in those
three areas, uh, when we look at our work. And here's, kind of, a diagram, um, of -- of,
uh -- with -- if you think about our Office of Financial Education that's doing most of
the work around what's effective within financial education, and they've defined financial wellbeing
in a -- and -- and have got -- got a growing, um, whole body of research for this that supports
that, um, then our office really is thinking about, well, how are we helping to build capacity
with nonprofits, with social service agencies, uh, with different sectors that can help us
to reach scale, um, to -- to reach all the people that are low income, um, and economically
vulnerable to really look at the biggest impact with products, um, and also really identify
policy issues, um, that -- that are out there that might be affecting, um, low-income families,
um, and raise that attention, um, of -- of those sorts of things to the Bureau.
Um, and as we are out there with, um, you know, programs like "Your Money, Your Goals,"
um, we are, um -- we're -- we're -- well, we're -- we're hearing a lot more, um, on
the policy side, um, and people are -- are letting us know when they're -- when they
see areas where low-income families have been unfairly targeted by debt collectors or -- or
-- or whatever, um, and -- and that helps, hopefully, to inform the work that we're doing
at the Bureau. Um, so, uh, I've talked a little bit, uh,
already about these issues. Here are some when I just keep going. Um, "Your Money, Your
Goals" is a, um -- a toolkit, and it's very different from, uh, a curriculum, in that
it was really designed as something that can help people to -- you know, that are already
helping people, um, in different ways. So, maybe you have a, um -- somebody that's
helping to certify or recertify for public benefits, somebody that -- that's working
at a, um, job center that's helping somebody to get a job, um, someone that's helping someone
else to get housing, um, so they're already interacting with consumers in -- in -- in
the many ways that -- that social service agencies do. Uh, we wanted to equip them with,
uh, materials, um, to really look at the intersection with finances.
Um, and so the toolkit has really been designed and was really tested in that kind of way,
to really help people to, um, look at the unique challenges that they're seeing that
very moment. So, maybe somebody can't get a job because their credit report. Uh, we
know employers are looking more and more at credit scores. Um, and so they remember, after
going through a training of "Your Money, Your Goals," that they -- that they've actually
got a toolkit, and they can go back in and pull out that section to help the person improve
their credit, um, make them aware of -- of products and also help them to clean up their
credit. Um, and so it's really very different from
a curriculum in that it's, you know, A to Z. It's really meant to be -- you know, you
come in, you pull what you need out, and you use it at that moment, make copies and give
it to the client, and hopefully, the client can take further steps. Uh, social workers,
frontline workers, are really also encouraged to take time, um, to develop a referral system,
um, for -- to the experts, to people that have deeper knowledge, um, the credit counselors,
the financial coaches that are out there, the counselor -- the HUD counselors that are
out there, you know, for the deeper work. Um, and -- and we've seen that, um, over and
over again. In fact, at the very beginning, we had some credit counseling agencies that
are like, "Well, wait a minute, you're kind of getting into our turf with this," um, and
we said, "Well, actually, you're going to see, uh, you know, hopefully, you know, a
stream -- more -- more people coming through your doors as a result of this," because,
um, we're very clear in the training, uh, with "Your Money, Your Goals," um, that, you
know, you shouldn't be teaching outside of your -- out of -- out of -- out of your expertise
and to develop that referral system. And we've heard that, um, repeatedly, around the country.
Um, we've -- we've, um, also developed companion guides, and we're going to talk about one
of those companion guides, um, and -- and Olivia will spend some time talking about
that. And another thing that I wanted to point out,
um, is, um, a -- a -- a brand-new, um -- a booklet, um, that some of you have probably
seen. I've got some here, and I've got another bundle -- another, uh -- another stack that
are out in the front -- in the front table that you can get. Um, but this was meant to
accompany, um, "Your Money, Your Goals." So, "Your Money, Your Goals" is a pretty big
toolkit, um, and it's about 400 pages, and, um, so it's pretty -- you know, it's -- it's
pretty -- it's pretty -- it's pretty big. And even though somebody goes through a training
-- we all go to trainings, and the material sometimes can stay on the -- on the, um -- on
the bookcase afterwards, and you forget to -- you know, to go back into it. So, this
was meant to be and it was really tested to be kind of a bridge between the bookshelf
and the desk and to be a reminder for the frontline workers as they're working with
clients, um, on, you know, different issues. And, you know, you open it up, and on the
inside is an 8-1/2 by 11 black and white. You can make a copy, give it to the client,
the client can use this -- this particular one here is an income tracker -- um, and,
um -- and it's really, um, set up in that kind of way. This other one here is a spending
tracker. And, again, you know, what we've seen -- Actually put these out, um, um, in
January, and, already, over 200,000 copies have been ordered from around the country
of this particular tool that accompanies "Your Money, Your Goals."
Um, and what we've really been excited about since we've been talking to social workers
-- and not just social workers, but, you know, case workers, um, different types of -- of
folks that are interacting with the public -- is that it brings them back into the toolkit.
So, they remember, oh, yeah, I went through that training. There's a lot more in there
if I want to go deeper. Um, and then, again, I can refer folks to, um, credit counselors
to even do deeper work, uh, if the need be. Um, since we started with "Your Money, Your
Goals" over the last 4 years, we've trained, um, over 20,000 frontline workers that have
reached an estimated, um, 700,000 consumers. This, um, uh, slide actually just lays out
what I was just talking about, so here we are, uh, the CFPB and, um, somebody just pointed
out that these buildings are a little fancy, um, for social service agencies, um, so we
might have to rethink that. Um, um, and those social service staff have,
um, frontline staff volunteers, um, that are interacting with clients every day. They have
relationships, they have access, they have their trust, and so we're -- we're thinking
about how to get financial education, you know, out into the market to, uh -- to try
to help as many people as possible. Um, this is really, uh, our -- our -- our strategy
of scale, um, to -- to reach them. Um, I'm going to take a -- uh, uh, I'm going
to go ahead and pause there and have Olivia come in and talk about, um, the disability
guide, which is the -- the brand-new guide that we just released yesterday.
Thank you, Daniel. Good afternoon, everyone. Again, my name is Olivia Calderon, and I am
so happy to be here with you today to share some of the promising ways that we've been
working to financially empower people with disabilities and their families.
And, of course, we want to see everyone participate fully in the mainstream financial marketplace,
but when it comes to families with disabilities, uh, we know that they disproportionately live
in poverty and that people with disabilities are twice as likely to use non-bank financial
products and services, um, and that four to five adults with disabilities don't have,
um, an emergency fund to turn to in a time of crisis.
Now, these challenges, for us, have created an opportunity for us to identify and for
us to design solutions to spur greater financial inclusion for people with disabilities. We
began this journey a few years ago, and we really, um, were inspired by, uh, and guided
by the advice of the disability community that proudly affirms, nothing about us without
us. And so, we started by bringing together practitioners
and academics and, uh -- and advocates with disabilities, some without disabilities, all
of whom serve the disability community, to share their perspective with us, to look at
"Your Money, Your Goals" and to tell us, uh, what's missing, what should we be including,
and how can we create tools that are really tailored to meet the needs of people with
disabilities. And so, we joined forces with the FDIC and, uh, had a convening last fall
and in the spring. And you know, what we learned from this convening
is that financial empowerment is more than just providing information. It's really developing
and designing tools, like I said, that are tailored to meet the special needs of -- of
individuals. And so, we, um -- we took all of their feedback and, uh -- and we came together
and rolled up our sleeves and started working, uh, to develop a product, um, that would complement
"Your Money, Your Goals," and, uh, yesterday, we officially publicly released it, and you're
the first ones to have it there before you. Um, and so, it is this tool, um, that we've
created, and again, like Daniel said, um, it complements "Your Money, Your Goals." It's
designed for folks who are frontline staff volunteers -- um, it could be a parent with
a disability, anyone -- to really pick up and be able to use it and use it easily.
And so, this companion guide, um, the way we've designed it, um, it's, uh -- it helps
for folks to be able to -- to see that, um, it's not easy to start the money conversation.
You don't even know where to begin, and it's a very sensitive issue. So, we've developed
a questionnaire, and that's how this disability companion guide kicks off, really, um, questions
that you could think about, you know, asking, uh, so that someone opens up. Um, and the
questions come along with responses, suggested responses that, you know, um, help you know
where to turn to. Because this isn't a companion guide. They're
tools. Um, so if an issue of credit comes up or savings or debt or financial abuse,
fraud, and exploitation, you know exactly where to turn to in this guide and where to
go to in the toolkit for additional resources. Now, the design of this, I'm really excited
about is that we've actually developed 11 new tools, and these are tools on everything
from how to help someone start saving. You know, for a long time, people with disabilities
couldn't save because of asset caps that impact their SSI. But now, for the first time ever,
they could save in something like an Achieving a Better Life Experience account, an ABLE
account that allows you save up to $100,000 without fear of losing your public benefits.
And there's a tool there on how to do just that.
Or perhaps it's setting a goal for assistive devices. It's expensive to go out there and
get assistive technology, and so setting up that goal and figuring out ways to finance
it -- There's another tool there. Or maybe it's demystifying that if you work,
that you might lose your public benefit, your SSI. And so, there's an SSI estimator that
shows you that work does, in fact, pay and that you can make more and save more if you
go out and work. Um, and then, again, like I mentioned, there's,
um, the tool there on how to, uh -- I'm trying to click here -- uh, how to identify -- the
last tool, identify financial fraud and abuse, um, and help someone, because oftentimes,
someone could be, you know, afraid or ashamed to go out there and report it themselves.
Um, so, these are all of the new tools. I can go into detail. I mean, I'd love to go
into detail on all of the new 11 tools. I think what I'm really excited about, as well,
is that, you know, all of these tools, um, now live on our website and, um, that they
were designed to be fully dynamic and fully accessible. And what that means is that anyone,
regardless of their ability -- if they're using assistive technology or a screen reader,
uh, can access our tools and use them, uh, and, uh -- and of course, um, it's the first
time that we now have these fully 508-compliant and dynamic accessible tools.
Uh, it has been an extraordinary collaborative experience across the Bureau here to develop
this new, uh, guide and tools, uh, and we're always looking for ways to, um, get feedback,
uh, build on the guide, and improve on these tools. So, I'm really excited to be here and,
uh, get your questions, and looking forward to the conversation. Thank you.
Are we ready for questions? Sure.
Okay, who wants to ask the first question? Uh, Luis?
Well, first of all, I would like to congratulate you for, uh, putting this -- this together.
I think it's -- it's -- it's a great tool, uh, and a great resource for people, uh, to
educate themselves about, uh, these type of, uh, financial, uh, tools and -- and -- and
resources that are available. My question for you is, um, were you able
to test these, uh, with some of the users, or potential users, in terms of how easy to
understand this is and if the format is the right format for them to -- to consume?
Thank you so much for the question. Yes, absolutely. Uh, in May of this year, we met at Gallaudet
University. We brought, um, together, uh, 30 organizations from across the country.
These were nonprofits, um, uh, centers for independent living. They were American job
centers. Um, they were folks from different universities that are working with students
with disabilities. Um, they were leaders of coalitions at the state level. Again, um,
the majority have disabilities themselves, others don't, but they all serve the disability
community. And we were able to take our tools, um, and
share our tools, and, uh -- and really get their feedback, because we wanted to have
that user experience to make sure that, uh, one, we were not missing anything, but it
made sense, uh, and that we could build and -- and -- and improve on that. We did that,
together with the FDIC, and we actually took their feedback, uh, to finalize the tools
and the layout for this. As a matter of fact, it also resulted in an
additional tool that we created, which is, um, the budget tool that you see there. You'll
notice that all of our tools have, for example, icons, um, and graphics, so that folks can
see -- right? -- so that regardless if you have a cognitive disability, for example,
you're able to easily explain what -- what the -- what the item is when you're creating
a budget. Um, but it did really create an easy way for
us to help someone, you know, set up a budget, particularly if you have, um -- if you're
on not only a limited income but if, um -- if you're on public benefits. Um, our toolkit
uses this cashflow budget, but if you know that you have a set, um, income and set expenses,
then a simple budget tool is what they asked for us to develop for them, um, and specifically
for youth and young adults with disabilities. So, yes.
Kayce? Thank you. I use the "Your Money, Your Goals"
toolkit, and I've enjoyed using it very much. Thank you for creating it. I think it creates
a wonderful baseline, and -- and that it's an open toolkit allows us to customize that
as we need in our own markets, and I'm -- I'm grateful for that resource.
When might you plan to launch a mobile app, um, something that's more electronic, obviously,
than the paper toolkit? Yeah, so I can, um, speak to that. So, actually,
the bundle -- or the -- the booklet that we passed around -- um, this actually started
as a digital, um, plan, to be honest with you. Um, we did a lot of testing, um, but
the idea was to do exactly what you just asked for, which was to make "Your Money, Your Goals"
and somehow digitalize it. Um, and we worked with a contractor in order to do that.
Um, through that process, we went through a whole bunch of focus group work with the
people that are using "Your Money, Your Goals," and, um -- and we were really -- I'm quite
surprised to hear back from them that they were not ready for digital. Um, they really
still wanted something that was analog, you know?
And so, uh, they said that, look, they're going out in the field on a regular basis.
Um, uh, they need to have something they can pull out of their -- pull out of their briefcase.
Um, they don't have stable internet connections all the time where they are. Um, they don't
have, you know, real -- I mean, social service, um, um, um, um -- that they -- they don't
always have the equipment that they need -- it depends state by state -- um, in order to
be able to pull it up electronically. And so, we actually ended up going back to -- to
analog with this, um, um, and -- as the solution. Uh, we are looking at, um, um, some steps
to -- to -- to move more, uh -- move back into looking, uh, at -- at digital, um, um,
but that's probably going to start, um, probably the third quarter of this year that we're
going to start to reexamine that. Thank you.
Yeah. Ric?
Just to echo what everybody else has said -- yeah, great, great materials. Um, and then,
one -- one of the things that Olivia mentioned is that it -- it does become difficult to
initiate the conversation, uh, with individuals to talk to them about planning for their future.
Um, you know, we've -- we've done a lot of work in our financial health centers to educate
our staff not to be responsive to offer a product or a service but, quite frankly, just
to listen and understand what's important to the member. And in that process, we often
find is that individuals may be coming in wanting to get a certain product, but there's
something else at the core of it. Um, so we've utilized the CFSI's health scores,
uh, to really understand the type of situation that individuals are in, and oftentimes, some
individuals who are not ready for this, they're in a situation in which, um, they're unable
to think beyond the day, they're in a situation in which they need, um, bigger, long-term
help, uh, and they're unable to objectify themselves and follow a -- a toolkit. Um,
and so, for us, our goal has been to really nurture and develop a longer relationship,
um, in which they can -- we can develop trust, so that we can help them in the long term
and resist the urge to offer them products that they think they need but that might not
be in their best interest. That's right. I mean, that's a really, very,
very good point, and, uh, again, you know, we've been in listening mode from the very
beginning with this toolkit. Um, we -- we tested it with, um, over 1,400 social service
agencies -- uh, I'm sorry, individuals, and actually, we followed up with them with, um,
questionnaires afterwards to find out how many, after they had gone through a training,
had used it, and we were really surprised. It was a high number. It was about 85% that
after 6 months had remembered the training they had gone through and had used it.
What we found was, again, you know, we just didn't -- they -- they were very reluctant
to even have that discussion with folks. Again, we don't want them to go too far, you know,
and they can't, to be honest with you, because they're already doing all the things that
they have to do, um, in their regular day work, right? Um, but we wanted them to have
some confidence, um, and many of them are also lower income, right? Social workers are
not paid a lot of money, and so they -- we found that they have increased their confidence,
um, as far as navigating and understanding the -- these issues, as well. But you're absolutely
right, we have to meet people where they are. David?
They didn't want to let me talk. So, uh, first off, I want to commend you. This is fantastic,
and, um, I, personally, was unaware of the tool, and we will be using it at my credit
union, um, probably in the next month. So, uh, again, just a fantastic tool.
Regarding and talking more about the digital solution, was there a discussion and development
to integrate into current mobile banking providers within the banking and credit union world,
and then, also, the personal financial management tools, as well, that's available? Um, and
so, there's couple of popular players in our space. Um, was that -- was that part of the
discussion and research, and if not, if that's something you're going to do in the future,
I know my credit union would love to be the beta and to help support that initiative.
We -- we would love to talk to you more about that, and actually, we were just recently
at the CFSI conference, and we met with some -- some, uh, different, um, folks from the
private sector, and, uh, many of them indicated a lot of interest in actually taking this
and adapting it. Um, again, this is completely open sourced.
We've heard -- You know, in fact, I had a bank that reached out to me not that long
ago and -- and said, well, can we use this, and can we put our logo on it? And we said,
by -- by all means. That's -- that's what we want. And you've already heard of an example
of -- of -- of -- of -- of one of your colleagues that's actually done that. And so, you know,
we fully would love to see that, and we'd love to be part of that.
Amy? Thank you. Um, to underscore Ric's comment
regarding meeting members where they're at, oftentimes, we are receiving referrals from
community organizations who are, uh, referring a member to us, uh, in a -- in a time of immediate
need, a crisis, and maybe that crisis is, they need $250 to, uh, pay a medical bill
or get tires for the car to get to work or something that really needs to be able to
get them through the day, and then we're circling back, after, regarding financial empowerment
tools. And so, to have the digitization of these
materials really helps build and strengthen a pipeline with -- with the organizations
that we work with, because we are sharing information back and forth to make sure that
this member is taken care of holistically, not just with that immediate cash need but
longer term. Um, and as we're working with these organizations, we are communicating
regarding what kind of financial literacy tools or empowerment has -- has been provided
and received, and -- and are they retaining that information. So, um, you mentioned discussion
is happening third quarter. We support that. Great.
So, whatever next steps can happen, certainly, um, I know from a community organization perspective
and how we work with, uh, local groups, that would be exceptional to have that available.
Wonderful. And I'll just mention, also, that we are currently recruiting, um, new cohort
members every year through our contractor. We will, um, choose about, um, 40 organizations
to work with, and we've worked with organizations from United Way of America to Catholic Charities
to some of the, um, private-sector groups that I mentioned earlier, um, and, um -- and
it really -- it takes that kind of, um -- It's not just that we're training; we're also learning
and hearing from them about how to modify these tools.
So, we would, um, love to see, you know, folks from here that might be interested, um, in
helping to inform that, and I'll follow up with Matt, and, uh, we can follow up with
you when we start to have that discussion. Carrie?
Yeah. First of all, I agree. This is an excellent guide, and it -- it's very practical. I could
see us reaching out to some partners in our community and using it as our curriculum.
And this is, perhaps, a little bit premature, but my follow-up question would be, um, have
you considered offering, sort of, a supplemental guide to people with disabilities who are
not low income? Um, and the reason being is that there are a lot of people in the disability
community who are gainfully employed, who are, financially, relatively stable, but given
those disabilities, there are unique challenges that they also have that wouldn't, maybe,
necessarily, be covered by what somebody traditionally thinks of as -- as a physical disability.
Um, our office, the Office of Financial Empowerment, is focused on economically vulnerable, low-and-moderate
income, um, consumers. Um, however, you'll find that both in the toolkit and also in
this companion guide, there are tools and resources that would benefit everyone, regardless
of where they are on the income scale. Um, and I will say just two points to you,
Ricardo, about how difficult it is sometimes to start the conversation. We find that, you
know, you don't know what you don't know, and that, oftentimes, we need to demystify,
um, and bust a lot of myths that are out there, you know, when it comes to, for example, in
the community, being able to build your savings and going out there and raising awareness
about the ABLE account, um, or when it comes to, you know, working and working pays, um,
and helping folks understand that, um, you can, in fact, do it and not risk, you know,
again, your benefits. Um, the tools that we have -- um, to the point
about going digital, one of the things that are really exciting about it is that they
do live up on our website now, but that they are electronically fillable. They were designed
in InDesign, um, which means they also auto-calculate and, um, you could save them and -- and share
them. So, if you have non-profit organizations that you're partnering with, and others, that
you could save that information and then, you know, um, uh, uh, with the permission,
of course, of the consumer, share it, um, so that you have a more comprehensive way
of serving the individual. Anyone else?
You're -- we're going to end 5 minutes early. Is that okay?
That's --
So, thank you for, uh, your attendance today. Thank you to our, uh, speakers from the CFPB.
Um, have safe travels home. Enjoy the rest of the day, and the meeting's concluded. Thanks
again.
Subscribe to:
Post Comments (Atom)
No comments:
Post a Comment