The U.S. Consumer Financial Protection Bureau (CFPB) is issuing an Advanced Notice of Proposed Rulemaking to solicit comments and information that will assist the development of proposed regulations under Section 1033 of the Dodd Frank Act dealing with consumer rights to access financial records.
Questions include:
- What are the benefits to consumers from authorized data access?
- To what extent does direct access to consumer data pursuant to Section 1033 raise any privacy concerns that should be considered by the Bureau?
- To what extent do such movement, use, storage and persistence of authorized data align with reasonable consumer expectations or preferences, including privacy expectations or preferences?
- What steps, if any, should the Bureau take to improve the effectiveness of existing laws that bear on data security in the context of data access?
- What should the Bureau learn about the costs and benefits of authorized data access from regulatory experience in state jurisdictions or in jurisdictions outside the United States?