The Clearing House Association, joined by the American Bankers Association, the Consumer Bankers Association, and the Bank Policy Institute sent a letter to CFPB Director Rohit Chopra reasserting our comments regarding the need for an ample compliance period with the forthcoming Section 1033 final rule on consumer financial data sharing.  The letter requests a meeting with the CFPB to discuss the complex and time-intensive changes to bank systems and processes, and associated controls, to ensure compliance with the final rule.  Similarly, the CFPB’s recent final rule establishing the procedures for CFPB recognition of a standards-setting body, and process to issue rule-compliant consensus standards, will also likely take many months after the final rule.  An appropriate period of at least two years after the issuance of the final rule should permit these actions to be completed by  the largest financial institutions.  The subsequent compliance dates for the other tiers of data providers also should be extended by a similar 18 months.

A copy of the letter may be found here.