Last week, Barbara Mishkin posted generally on the CFPB’s overdraft fee initiative. I found the CFPB’s prototype “penalty fee box” particularly interesting and have a few comments: 

• While it is certainly possible that the CFPB will both require targeted disclosures and sharply circumscribe consumer choice, I take some hope from the penalty fee box disclosure that the CFPB will focus on requiring clear disclosure and continue to allow consumers a considerable measure of autonomy.