Good afternoon,
Attached please find NAFCU Regulatory Affairs Counsel Andrew Morris's letter to the Consumer Financial Protection Bureau regarding the agency's request for information (RFI), titled “Consumer Access to Financial Records.”
In the letter, Morris wrote, "NAFCU is supportive of the CFPB’s efforts to promote consumer access to new technologies and financial services through the cultivation of an innovative and competitive marketplace. However, NAFCU does not think that financial aggregators and so-called fintechs should be able to take advantage of their special status to shift the burdens of data collection onto account providers like credit unions."
In regards to data security, Morris noted, "NAFCU believes that companies that request access to consumer financial records should bear the burden of ensuring that the transfer and retention of such information is secure and conforms to consumer expectations of privacy. Accordingly, NAFCU asks that the Bureau develop a robust set of data security principles for record-seeking entities which would serve as a prerequisite for access to consumer data. Such an alignment of cybersecurity responsibilities will help credit unions and other financial institutions offset the costs of an otherwise expensive vetting process for aggregators and other companies who intend to extract consumer financial data."
Morris also discussed data sharing and the CFPB consulting with the NCUA before issuing any proposal governing access to consumer financial records.
Morris concluded, "Any regulatory framework that requires credit unions to build, maintain and secure structured data streams to support the operations of data aggregators would unfairly compromise credit union service and leave members more vulnerable to potential fraud. NAFCU believes that the CFPB should ensure that access to consumer financial records is predicated upon a fair distribution of costs and data security responsibilities, which should be born primarily by record-seeking parties."
If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.
Thank you.
Falen Taylor
Communications Coordinator
National Association of Federally-Insured Credit Unions
Phone: 703-842-2235
ftaylor@nafcu.org