As the first generation to rely on 401(k)s nears retirement, large swaths of Americans don’t have enough saved. Was the “do-it-yourself” approach to retirement savings a mistake?

This Memorandum is submitted in support of intervenor Financial Technology Association’s opposition to plaintiffs’ and defendants’ motions for summary judgment and in support of intervenor’s cross-motion. Amici are non-profit organizations dedicated to advancing the financial health of American households.

Consumer’s ability to access and electronically share their financial data has already demonstrated considerable financial health benefits. But our research among consumers, their financial app providers and data aggregators reveals seven “pain points” impeding data access and preventing consumers from sending their data where it can do them the greatest good. The Bureau’s pending rulemaking under Section 1033 of Dodd Frank can best serve financial health by incorporating a few basic principles that will enshrine consumers’ data access rights.