Comment on CFPB-2012-0046-0001

This comment is excerpted from something I posted on the Consumer Law and Policy Blog at http://pubcit.typepad.com/clpblog/2012/12/cfpb-announces-proposed-policy-for-letting-companies-test-disclosure-programs.html: This proposal sounds like a good idea. After all, the companies who deal with consumers directly may know things the Bureau doesn't about how and what to tell consumers. But I wish that the Bureau included in its evaluation criteria that it will also assess whether consumers use the disclosures. Disclosures that clearly convey information but are ignored do consumers little good, and we've had far too many of those (does anyone really know the differnce between a full warranty and a limited warranty under the federal Magnuson-Moss Warranty Act, for example?). Maybe that's implicit in testing for consumer understanding, but I would rather see it made explicit.