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ARTICLE · 08 MAY 2024

CFPB Uses Laboratory Experiments To Attack Junk Fees

Hogan Lovells Cadwalader
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On April 30, 2024, the Consumer Financial Protection Bureau ("CFPB") published a report called "Price Complexity in Laboratory Markets" that concluded...

United StatesFinance and Banking

On April 30, 2024, the Consumer Financial Protection Bureau ("CFPB") published a report called "Price Complexity in Laboratory Markets" that concluded that the financial services industry should keep pricing for financial services and products simple. Using actual people in a laboratory setting at the Gettysburg Lab for Experimental Economics, the CFPB conducted a series of experiments that had the participants interact with various market models through private, networked computer terminals. "Participants earned 'tokens,' and at the end of each session, tokens were exchanged for dollars."

"While not expected to exactly mirror real-world transactions, the CFPB found in these experiments that more complex pricing generally led to more detrimental outcomes for consumers." The CFPB's accompanying press release highlighted outcomes from the experiment that appeared to advocate for sellers not having any choice in being able to offer more than one price because when the

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