Does the CFPB's New Integrated Disclosure Rule Preempt New York State Law?

This reform is a product of the Dodd-Frank Act of 2010, which directed the CFPB to “simplify the technical nature of the disclosures” by “utilizing readily understandable language.” See 12 U.S.C. ' 2603(a); 15 U.S.C. ' 1604(b). The revised disclosures must use “plain language comprehensible to consumers” and “a clear format and design” to “succinctly explain[] the information that must be communicated” to the borrower. See 12 U.S.C. ' 5532(b)(2). The new disclosures must be “validated through consumer testing,” and must be informed by “available evidence about consumer awareness, understanding of, and responses to disclosures or communications about the risks, costs, and benefits of consumer financial products or services.” See 12 U.S.C. ” 5532(b)(3), (c).