CFPB should write a data sharing rule that can evolve with the market

The Consumer Financial Protection Bureau’s recent Regulatory Agenda indicates that the bureau plans to commence a rulemaking in November to implement the data sharing provision in Section 1033 of the Dodd-Frank Act. For that rulemaking to enable consumers to enjoy the benefits of more open data, the CFPB should heed Director Rohit Chopra’s recent call to eschew “highly complicated rules that have long been a staple of consumer financial regulation” and instead develop a principles-based approach that addresses the most significant pain points in the data ecosystem today and will allow the market to evolve over time.