The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (“CFPB”) regarding its Notice of Proposed Rulemaking for the Required Rulemaking on Personal Financial Data Rights (the “Proposed Rule”).
CCMC welcomes the CFPB’s work to implement section 1033 of the Dodd-Frank Act. We strongly support maintaining secure consumer access to financial information, consistent with section 1033. Industry participants take their consumer data access, privacy, and security obligations seriously, and have invested significant time and money in developing technology to help consumers access data in secure ways. In doing so, regulated financial institutions have met stringent data privacy and security requirements that prioritize consumer protection. Stakeholders with diverse interests have also risen to the challenges inherent in the increasingly digital marketplace. For example, the Financial Data Exchange (“FDX”), a consortium of data providers, data aggregators, data recipients, and other key industry participants has spent significant time and resources creating a framework for sharing information through application programming interfaces (“APIs”) that have notably enhanced both data security and ease of use for participants and their customers.