Rick Fischer, Oliver I. Ireland, and Amanda J. Mollo
Banking + Financial Services, Financial Institutions + Financial Services, Financial Services Litigation, Financial Services Enforcement, Financial Services, Financial Technology, and Mobile Payments
On August 4, 2017, the Consumer Financial Protection Bureau released four “prototype” model overdraft disclosure forms styled under its “Know Before You Owe” initiatives with a press release. The CFPB said the forms were designed to clarify the risks and costs of overdraft coverage for consumers. The press release and forms were accompanied by a report entitled Data Point: Frequent Overdrafters, highlighting the habits of the small group of consumers who initiated the most overdrafts per year.
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