In a letter to the CFPB, TCH provided experiential insight regarding the facilitation of data access by consumers and encouraged the agency to take a principles-based approach to personal financial data rights. The letter stressed that the approach needs 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 and maintain a consistent approach that is coordinated with other federal financial services regulators. The letter urged the Bureau to ensure that the final rule does not cause a significant disruption or diminish the substantial progress that the private sector has made in creating an infrastructure that facilitates safe, secure data sharing consistent with the Bureau’s previously issued guidance. The letter summarizes observations and recommendations, includes a discussion of the previous foundational work the Bureau has done, describes a series of initiatives undertaken by the private sector to promote and facilitate consumers’ personal financial data rights, and lays out detailed responses to individual questions the Bureau raised in the SBREFA Outline.

To read the full comment letter click here.