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.