The CFPB announced a proposed policy on December 13 called Project Catalyst that would allow financial institutions to develop and test new consumer disclosures on a case-by-case basis. As part of the project the CFPB would approve limited exemptions from federal disclosure laws to allow institutions to research and test informative, cost-effective disclosures to inform the CFPB’s rulemaking process.

Nutter Notes: When deciding whether or not to grant a waiver from current disclosure requirements, the CFPB project would consider how effectively and efficiently the proposed trial will reveal potential improvements to consumer understanding about the costs, benefits, and risks of financial products and services, and mitigate risks to consumers.