The Financial Health Network Comment Letter to the CFPB Regarding the Required Rulemaking on Personal Financial Data Rights
The Financial Health Network submitted a comment on the CFPB’s Outline of Proposals and Alternatives Under Consideration for the rulemaking regarding personal financial data rights. In its comment, the Financial Health Network offers its recommendations for implementing data rights so as to maximize the benefits to consumer financial health while minimizing the risks to consumers and the expense to data providers and third parties. The comment advocates, among other things, for expanding the coverage of the rule beyond that suggested by the CFPB’s outline and defining the processes through which consumers can authorize (and deauthorize) data sharing so as to avoid frictions that would interfere with consumers’ ability to access products and services that can help them better manage their financial lives.
Seven Pain-Points in the Consumer Financial Data Ecosystem: Priorities for the CFPB’s Rulemaking Under §1033 of the Dodd-Frank Act
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.