As reported in Top Stories a few days ago, CFPB is contemplating revising Regulation E's model form A-9 and has released four prototypes for public consideration. Press release with link to prototypes Any of the four is a dramatic improvement over the current version, primarily because you can't fall out of a hole. I read the current version the day it was published (before reading the regulation) and simply had no idea what it was talking about. Even though the Fed claimed to have used outside consultants in drafting it, it is nothing short of unintelligible.

I know of two banks that modified the current version and succeeded in making it easier to understand. Both were criticized by their regulator and forced to re-run their opt in program using the model form with no modifications.

It's good that Pollyanna is joining the party, but it's a few years too late to do most consumers any good as most banks no longer solicit opt-ins from existing customers.

P.S. It's worth noting that all four prototypes require the consumer's signature, a logical requirement, but a substantive change to current practices.

Will all 4 of these be available for use, or will they require all FIs to use the same form? You're right, all are a huge improvement. My preference would be form #3.

One of the purposes of putting the four prototypes out for comment is to see if there is a hands-down favorite. There certainly should be choice, IMHO, but there may not be if the Bureau doesn't hear comments suggesting there be a choice. I think that, depending on a bank's program, any one of the samples could be the optimal one for that bank.

So if you have a favorite, tell the Bureau so. If you think that banks should be able to use any one of the four (or two, or three), say so.

And don't forget that consumers will be commenting, too. In fact, they are likely to be the largest group of commenters.

While it's true that the heavy use of the form is history, a disclosure still has to be provided for new accounts if a bank offers an OD Program that offers optional coverage for card-related transactions. It's just too bad that the Fed did such a half-baked miserable job in crafting the current form.