More details and background about the “disclosure sandbox” proposed Sept. 10 by the Bureau of Consumer Financial Protection) BCFP are offered by the agency in a blog post dated Thursday, including an outline of revisions it said will “effectively encourage companies to test new disclosures.”
According to the blog post, the new disclosure policy will:
- Streamline the application and review process to focus on the quality and persuasiveness of the application.
- Grant or deny applications within 60 days of submission.
- Establish an expected two-year time frame for the testing of disclosures.
- Specify procedures for permitting companies to continue to use disclosures that test successfully.
- Coordinate with state regulators so that entities within state “regulatory sandboxes” may be able to participate in the bureau’s “disclosure sandbox” without applying separately to the bureau.
The bureau also said in the post that the sandbox is the first action to come from its new Office of Innovation, announced in July by Acting Director John (“Mick”) Mulvaney. “Other initiatives may be released in the coming months,” the blog post states.
The post also notes that the bureau proposed the sandbox through revisions to its existing policy, established in 2013, to “encourage trial disclosure programs” – although the agency acknowledges that no trial disclosures have yet been approved.
“The revised policy is based on the same statutory authority as the existing policy, which allows the Bureau to deem a covered person conducting a trial disclosure program to be in compliance with or exempt from a requirement of a Bureau rule or certain federal laws,” the agency states.