FPF Submits Comments on Personal Financial Data Rights Reconsideration

The Future of Privacy Forum (FPF), was pleased to provide comments and recommendations regarding the CFPB’s Advance Notice of Proposed Rulemaking (ANPR) for its Personal Financial Data Rights Reconsideration.

FPF appreciates that the CFPB in its ANPR is exploring certain significant components of the final rule, with a view to improve the regulation for consumers and industry. FPF supports this goal, and has pointed out key areas for improvement in its comment letters and testimony.3 We also understand the criticality of having a final rule that industry can implement without further delays in order to benefit consumers. Regulatory certainty will drive open banking adoption forward as industry can build out to meet deadlines. FPF therefore believes that either the final rule should remain as-is, to be amended over time based on implementation experiences and new products coming on board, or that the CFPB can issue targeted amendments per FPF’s recommendations that will improve the ecosystem and not cause undue regulatory delay.

FPF offers its analysis of each of the topics raised in the ANPR. At the close of each topic, we offer a synopsis of recommendations where we have them.