Ladies and Gentlemen:
The undersigned financial services trades[1] welcome the opportunity to comment on the Consumer Financial Protection Bureau’s Outline of Proposals regarding its rulemaking on Personal Financial Data Rights. We jointly write to elevate a necessary and foundational precept in any rulemaking undertaken by the CFPB under section 1033 of the Dodd-Frank Act. Our paramount concern is that any final rule promulgated by the CFPB must take a principles-based approach that is broad enough to accommodate quickly evolving advancements in the market in the same way as the CFPB’s 2017 Consumer Protection Principles on Consumer-Authorized Financial Data Sharing and Aggregation.
A rulemaking that codifies these key CFPB principles would serve the CFPB’s and the industry’s consumer protection goals: (1) consumers will have control over where, how, and the extent to which their data is shared, (2) information will be secure and protected with bank-like security, and (3) entities that cause either direct or indirect harm to consumers will be responsible for making it right. The industry has relied on these principles, which have given industry the flexibility to make incremental and necessary adaptations over time in the consumer-authorized financial data sharing ecosystem.
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[1] Please see the Annex for a description of the associations.
