The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (“CFPB”) regarding its Request for Information regarding the data broker market (the “RFI”).1 Financial data plays a critical role in the modern economy. Financial services companies use this data to provide consumers better, more tailored products and to reduce risk for consumers and the market. Data about customer usage and preferences
may inform targeted offers, for example, that help provide customers the best products for their circumstances, or contribute to underwriting processes that open further opportunities to underserved borrowers.
Data brokers make these data-driven services possible and consequently play an important and established role in the financial services market, as they do in other markets. Data brokers are already subject to numerous legal requirements. While business models and relevant legal frameworks differ across the data broker industry, laws governing data brokers include the Fair Credit Reporting Act, the Federal Trade Commission Act, and the Consumer Financial Protection Act, and the Gramm-Leach Bliley Act at the federal level, as well as statutes in the individual states.