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TCH Submitted Comments in Response to the CFPB’s ANPR Regarding Consumer Access to Financial Records

TCH filed a comment letter in response to the CFPB’s ANPR on data aggregation and consumer-authorized access to financial records. The letter begins by expressing support for consumers to be able to safely and securely obtain information about their ownership or use of a financial product or service from their product or service provider. In its letter, TCH urges the CFPB to develop additional guidance that is consistent with the CFPB’s Principles for Consumer Authorized Financial Data Sharing and Aggregation, rather than engage in a full rulemaking, and TCH suggests improvements to current CFPB policies. TCH also recommends, in the letter, that the CFPB continue to rely on private sector market-led efforts for technical standard setting of the kind engaged in by FDX, and suggests that if the CFPB does undertake rulemaking, that such a rulemaking be holistic in its approach and address a number of specific issues, including risks associated with credential sharing, credential storage, and screen scraping, limitations on when a company can access consumer data, and developments of disclosure requirements.

To read the full comment letter click here.