North America

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Video Member Spotlight: ByAllAccounts

This member spotlight features Brian Costello, Head of ByAllAccounts Data Aggregation Strategy and Governance, Morningstar Wealth. Brian tells us how ByAllAccounts’s role in providing connectivity of consumer-permissioned financial data is critical in realizing the full potential of this data and explains ByAllAccounts’s high level of engagement with policymakers to promote finalization of the Dodd-Frank Section 1033 rulemaking.

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FDATA North America Sends Letter to Wyoming Governor Mark Gordon and Wyoming Legislators Urging Revision of Open Banking Legislation

Contact: Laine Williams, (202) 897-4757, [email protected] 

March 15, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) today sent a letter to Wyoming Governor Mark Gordon and Wyoming legislators including Representative Cyrus Western, Representative Daniel Singh, Representative Mike Yin, Senator Alfie Ellis, Senator Tara Nethercott, and Senator Chris Rothfuss, highlighting concerns about a Wyoming bill (HB 145) that was recently enacted into law and offering to provide input into Wyoming’s open banking regulations and financial innovation agenda.

As a leading advocate for consumer-permissioned, third-party access to financial data globally, our letter underscored the importance of aligning Wyoming’s open banking framework with global best practices, which provide complete control to consumers and small businesses over what data they decide to share with third parties. We pointed out that HB 145 deviates from this important open banking tenet.

As the Consumer Financial Protection Bureau moves to implement a federal open banking framework later through rulemaking later this year, we offered to engage in further discussions with Governor Gordon and the legislators to explore solutions that would make Wyoming’s open banking regulations a model for consumer empowerment and market competitiveness.

A full copy of the letter is available here.

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FDATA North America Submits Comments to Canada’s Consultation on Strengthening Competition in the Financial Sector

Contact: Laine Williams, (202) 897-4757, [email protected] 

February 28, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) today submitted comments to Canada’s Department of Finance as part of its consultation on strengthening competition in the financial sector. Our submission underscored the necessity for the enactment and realization of several previously announced initiatives that will provide increased competition in Canada’s financial sector once delivered.

FDATA NA’s feedback highlighted four cornerstone initiatives, each critical to fostering a more inclusive, innovative, and competitive financial ecosystem:

  1. Consumer-Driven Finance (CDF): We advocated for the swift advancement of CDF including the pivotal adoption of an open banking regime. This approach is designed to empower consumers and small and medium-sized enterprise (SMEs) with enhanced control over their financial data, serving as a catalyst for broadening the range of financial products and services available. Such a framework is indispensable for stimulating market competition and driving innovation.
  2. Real-Time Rail (RTR): Our comments emphasized the urgent need for the accelerated deployment of the RTR to modernize Canada’s payment infrastructure. This development is key to enabling instant payment processing capabilities that will benefit both consumers and SMEs, thereby encouraging innovation and improving efficiency across the financial sector.
  3. Retail Payment Activities Act (RPAA) Implementation: We stressed the importance of promptly implementing RPAA regulations to cover approximately 2,500 payment service providers (PSPs) within a comprehensive and robust regulatory framework. This initiative aims to significantly enhance the security, efficiency, and competitive nature of Canada’s payment systems.
  4. Canadian Payments Act (CP Act) Amendments: FDATA NA called for essential amendments to the CP Act, allowing regulated non-bank payment providers direct access to Canada’s payment rails. This strategic move is expected to democratize the financial services marketplace, lower transaction costs, and foster a more vibrant and competitive landscape.

Through the enactment and realization of these initiatives, FDATA NA envisions a fundamental transformation within Canada’s financial sector. Leveraging models of success from international jurisdictions, we highlighted the potential of our recommendations to significantly boost the sector’s competitiveness, inclusivity, and innovation. The ultimate beneficiaries of these reforms that will deliver a more competitive financial ecosystem will be consumers, small and medium-sized enterprises, and the broader Canadian economy.

A full copy of the submission is available here.

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FDATA North America Submits Comments to Canada’s Department of Finance Pre-Budget Consultations 2024

Contact: Laine Williams, (202) 897-4757, [email protected] 

February 9, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) submitted comments to Canada’s Department of Finance as part of its pre-budget consultations in advance of Budget 2024. Our submission emphasized the necessity for Canada to build upon the inclusion of consumer-driven banking (CDB) in the 2023 Fall Economic Statement, moving towards a fully realized Canadian open finance framework. The letter underscored the significance of CDB as a foundational step towards financial empowerment for consumers and small and medium-sized enterprises (SMEs), fostering a more innovative and competitive financial services marketplace in Canada.

Our letter urged the Canadian government to:

  • Legislate a CDB Framework: Introduce specific language in Budget 2024 to legislate the CDB framework, empowering consumers and small- and medium-sized enterprises (SMEs) with secure access to their financial data, thus ensuring Canada remains competitive in the global financial ecosystem.
  • Establish a Robust Governance Entity: Allocate funding for the creation of a new, neutral, and transparent governance entity to oversee the CDB framework. This body should be capable of making quick, binding decisions and be accountable for its actions, ensuring the framework’s success and longevity, and should be tasked with framework management, API auditing, accreditor oversight, technical standards oversight, liability apportionment, and dispute resolution.
  • Outline a Vision for Open Finance: Beyond CDB, Budget 2024 should detail the government’s approach to open finance, the next evolution in financial services, which promises to unlock unprecedented market innovation and competition for the benefit of Canadian consumers and SMEs.

In the submission, we also asserted that any CDB governance entity in Canada must be neutral (i.e. not controlled by any particular stakeholder(s) with commercial interests in the ecosystem), transparent (i.e. it invites and considers stakeholder input and subjects its decisions to an open, publicly visible process), nimble (i.e. capable of making binding decisions relatively quickly and without undue bureaucracy), and accountable (i.e. explain its decisions and actions and be subject to judicial oversight and administrative law processes) with all stakeholders in the system agreeing to comply with the decisions and determinations made by the open banking governance entity as a condition of being active in the market.

A full copy of the submission is available here.

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FDATA North America: Comment Letter Submitted on CFPB’s Section 1033 NPRM

Contact: Laine Williams, (202) 897-4757, [email protected] 

December 27, 2023 Washington, DC – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than 30 financial technology companies and consumer-permissioned data access platforms in Canada and the United States, today filed a comment letter in response to the Consumer Financial Protection Bureau’s (CFPB) Notice of Proposed Rulemaking (NPRM) on personal financial data rights, which will implement Section 1033 of the Dodd-Frank Act.

Steve Boms, Executive Director of FDATA, released the following statement:

“We are pleased to comment on the CFPB’s proposed personal financial data rights rulemaking, which once implemented, will create a legally binding consumer financial data right in the United States. Under this open finance regime, consumers will have the right to access and securely share their financial data electronically with third-party providers of financial tools, products, and services, heralding an era of improved competition and greater consumer control in the U.S. financial services marketplace. Beyond the obvious benefits to consumers, FDATA views this rulemaking as a crucial step forward for U.S. competitiveness in a global economy in which many other countries have already developed and implemented open finance regimes.

Our comments to the CFPB underscore areas for potential improvements in the final rule. We believe these changes will more effectively align the rule with the vision the CFPB presented when announcing its pursuit of this rulemaking, as well as with the open finance regimes implemented by other jurisdictions globally. FDATA looks forward to continued engagement with the CFPB as it works to finalize this pivotal rule in 2024.”

A FDATA member company released the following statement alongside the submission of FDATA’s comment letter.

Brian Costello, Head of Data Aggregation Strategy and Governance at Morningstar Wealth, a member of FDATA, stated:

“Morningstar Wealth actively champions the interests of both investors and the professionals who serve them as the U.S. Open Banking landscape transitions from a commercially managed ecosystem to a regulated financial data right for consumers. The CFPB’s Notice of Proposed Rule Making underscores the Bureau’s strong commitment to addressing this pivotal issue, which holds significant implications for millions of Americans. FDATA’s response letter draws upon the collective expertise of its diverse membership of responsible innovators to provide practical guidance and recommendations essential for the seamless adoption and execution of the final rule. As long-standing members of FDATA, we are pleased to contribute our perspective and experience to this response.”

Click here to read FDATA’s full comment letter.

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FDATA North America Statement on Deputy Prime Minister Freeland’s FES Implementing Consumer-Driven Finance Directives

Contact: Laine Williams, (202) 897-4757, [email protected] 

November 21, 2023 Washington, DC – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than 30 financial technology companies and consumer-permissioned data access platforms in Canada and the United States, today applauded the inclusion of consumer-driven finance in the 2023 Fall Economic Statement (FES).  

Steve Boms, Executive Director of FDATA, released the following statement:  

“We are greatly encouraged by Deputy Prime Minister and Finance Minister Freeland’s commitment to advance consumer-driven finance in Canada. The inclusion of consumer-driven finance in the FES marks a significant step for the financial empowerment of consumers and for small and medium-sized enterprises, for fostering a more innovative Canadian financial services marketplace, and for promoting a fairer and more inclusive financial services ecosystem. It reflects a global trend towards consumer-centric financial services, and brings Canada in line with the regimes established by nearly every other G-7 nation.  

We applaud the comprehensive consumer-driven finance framework announced in the FES and look forward to working closely with the Government of Canada as it delivers consumer-driven finance through next year’s budget to benefit all Canadian consumers and businesses.” 

Additionally, we have received supportive comments from our member groups, highlighting the significance of these developments. Tanya Woods, Head of Government and Regulatory Affairs & Policy Counsel at Questrade Financial Group, a member of FDATA, stated

“We welcome today’s announcements on open banking which will give Canadians more power over their financial wellbeing. These are positive developments towards a fulsome and competitive open finance framework which we will continue to advocate for.” 

Faye Pang, Canada Country Manager, Xero, provided the following statement: 

“We are incredibly energized by the language in the FES that supports the progress of open banking and applaud Deputy Prime Minister and Finance Minister Freeland for their support. A fair, fast, and efficient open banking system can not only open up new avenues of capital, but help small business owners focus on what’s important: running their business. Today’s commitments noted in the FES take us one step closer to achieving this vision.” 


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Submission by FDATA North America To the House of Commons Standing Committee on Industry and Technology (INDU) Regarding the Study of Bill C-27

October 31, 2023 – The Financial Data and Technology Association of North America (“FDATA North America”) is the leading trade association advocating for consumer-permissioned access to financial data in both Canada and the United States. Our members include firms with a variety of different business models that collectively provide more than six million Canadian consumers and small- and medium-enterprises (“SMEs”) with access to vital financial services and products. Utilizing the products, services, and tools, that FDATA North America’s members provide, Canadian consumers can, for example, access more competitive banking services, including more affordable credit, utilize more efficient payment options, and benefit from technology to better manage their finances and grow their wealth. Canadian small businesses across the country depend on FDATA North America member companies to manage their accounting and credit needs and more easily send and receive payments.

FDATA North America was founded in early 2018 by several financial technology firms whose technology-based products and services allow consumers and SMEs to improve their financial wellbeing. Regardless of their business model, each FDATA North America member’s product or service shares one fundamental and foundational requisite: the ability of a consumer or SME to actively permission access to some component of their own financial data that is held by financial services providers.

We are strong advocates of Canada’s implementation of an open finance regime, which was first outlined as a government priority in Budget 2018. The core idea of open finance is this: a Canadian consumer or SME should be able to safely and securely share access to their data held at one provider with another provider that offers a better financial product, service, or tool. Whether it’s a chequing, savings, business, brokerage, pension, mortgage, or auto loan account, or data held by a payroll or benefits provider, open finance is the straightforward notion that the customer should have the right to use that data for their own benefit. Once built, open finance in Canada will put consumers and SMEs in full control of their financial data, facilitating a more transparent and competitive Canadian financial services marketplace that provides safe and secure data portability. FDATA North America views the data portability right and data privacy framework included in Bill C-27 as fundamental cornerstones of this modernized approach to financial services.

Following the pandemic, a period of economic uncertainty and rising inflation, one thing is obvious: Consumers and entrepreneurs are demanding access to financial solutions in new and novel ways that better meet their needs. Digital financial services, typically offered by non-bank financial technology (“fintech”) companies can help meet those needs. In a 2022 survey of consumers in the U.S. and U.K., two-thirds said fintech helped them weather economic challenges.
Half of respondents said fintech helped them feel more in control of their finances. And nine in ten users saw benefits from using fintech tools.

A survey of Canadians commissioned last year by FDATA North America and Fintechs Canada found similar results. That data showed that half of Canadians feel stress with interacting with Canada’s existing financial services sector and that more than two-third of Canadians believe more competition in the financial services marketplace would lead to a greater choice in products and lower financial services fees. Ninety percent of Canadians indicated they found fintech products easy to use, with more than eighty percent reporting they paid lower fees to fintechs than to their
banks for similar services or products.

Open finance results in more choices and better experiences for consumers and SMEs, as banks and nonbanks compete aggressively to win over customers. Canadians deserve access to these alternatives, just like their neighbors in the U.S. and U.K.

As the committee has heard from other witnesses, Canada lags significantly behind virtually every other G-20 country with regard to open finance, data portability, and data privacy. The United Kingdom, Australia, New Zealand, Singapore, Japan, Brazil, the European Union and other jurisdictions have all enacted some version of government-led open finance under which consumers and SMEs have legally binding data access rights and data privacy protections afforded to them to access a more competitive and vibrant financial services marketplace.

In contrast, today, Canadian consumers and SMEs have no legal right to access or share access to their financial data. Unlike the overwhelming majority of other developed countries, in Canada, a consumer’s or SME’s bank is empowered to determine whether their customer may share elements of their data with a third-party provider of financial services to get a better deal, access a new product or tool, or avoid paying exorbitant fees. And, to the extent that a bank does allow its customers to share access to their financial data, there are generally onerous and, in some cases, restrictive terms dictating the limitations under which customers are able to do so.

While Canada has taken important steps towards a more open, consumer-directed finance (CDF) regime, significant work remains to reach implementation. Abraham Tachjian was appointed as Canada’s open finance lead in March 2022, and FDATA North America commends him for establishing working groups for some of the most crucial issues associated with the introduction of open finance in Canada.

Unfortunately, the efforts of these working groups have yet to come to fruition, as concrete progress towards implementation of open banking has stalled. The 18-month timeline the government had established is now out of reach, which should be a concern to Canadian policymakers, consumers and SMEs alike.

Earlier this month, the United States formally launched its own open finance regulatory regime with a Consumer Financial Protection Bureau (“CFPB”) rulemaking. Recognizing that incumbents in the financial services market would not on their own deliver a more competitive, customer-centric ecosystem for U.S. consumers and SMEs, the Director of the CFPB noted in announcing the U.S. rules that the CFPB’s open finance rule will “supercharge competition, improve financial products and services, and discourage junk fees.” Like Bill C-27, the CFPB rule would provide data portability rights to consumers and would require those firms that access, with their express consent, end users’ data to abide by strict data privacy and security provisions.

To advance its open finance regulations, the CFPB had an advantage in the United States that the Departments of Finance (“Finance Canada”) and Innovation, Science, and Economic Development (“ISED”) currently do not: strong statutory authority to do so. Finance Canada has been studying how to deliver open finance in Canada for the better part of five years. FDATA North America views enactment of Bill C-27 as a critical element of a transition from open finance ideation to implementation. Once consumer and SME data portability have been enshrined in law, ISED and
Finance Canada will have the statutory tools required to finally deliver open finance in Canada.

Consumers and SMEs in Canada are being left behind as the rest of the G-20 build and deploy open finance frameworks that facilitate competition, enable greater access to and inclusion within the financial services marketplace, and provide their citizens with appropriate data protections when utilizing a legally binding data portability right. The data portability and data privacy provisions included in Bill C-27 represent integrally important statutory tools that ISED and Finance Canada will need to help Canada catch up – and to foster a safer and more competitive
financial services sector for all Canadians.

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FDATA North America Statement On The CFPB Proposed Rule Implementing Section 1033

October 19, 2023, Washington, DC – The Financial Data and Technology Association of North America (FDATA), a trade association representing three dozen financial technology and open finance companies, today celebrated the release of the Consumer Financial Protection Bureau’s proposed rule implementing Section 1033 of the Dodd-Frank Act.

Steve Boms, Executive Director of FDATA, released the following statement:

“Today, we’re celebrating a moment that our members – and millions of consumers across the country – have been waiting for: the CFPB’s release of its proposed rule creating a legally binding consumer financial data right. We strongly support the proposed rule, which will put consumers in full control of their financial data and empower them to choose the financial provider best suited to meet their unique needs. The proposed rule will create more competition and choice in the financial services marketplace, ultimately leading to better consumer outcomes.

We are also pleased that the proposed rule creates strong data security and privacy standards to ensure that consumers are protected wherever they choose to manage their finances.

The long-awaited rulemaking commenced with the issuance of the CFPB’s Request for Information regarding Section 1033 of the Dodd-Frank Act in 2016. While the need for this rule was clear then, with hundreds of millions of consumers now relying on digital financial tools, it is imperative today. We look forward to working with the CFPB as it seeks to finalize this rule next year and bring U.S. consumer financial data rights on par with many other nations across the globe.”

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Coalition of leading industry stakeholders voice continued support for vital Canadian Payments Act amendments

OTTAWA, October 11, 2023 — The Fall Economic Statement presents an opportunity to modernize the Canadian Payments Act to strengthen financial competition, innovation, consumer protection and economic stability.

Leaders across Canada’s payment industry continue to demonstrate unified support for amendments to the Canadian Payments Act to expand Payments Canada’s membership. This support was previously expressed through various pre-budget consultation submissions, a joint letter to the Minister of Finance and a 2018 Department of Finance consultation.

Expanded membership eligibility is essential to broaden safe access and participation on Payments Canada’s infrastructure. By broadening access to include payment service providers, credit union locals, and operators of financial market infrastructures that meet regulatory and legislative requirements, the Government of Canada will foster competition and innovation and help ensure the future of digital payments happens within — and not outside — the regulatory system.

“Payments are changing at an unprecedented rate,” said Tracey Black, President and Chief Executive Officer of Payments Canada. “Canada must evolve its payment systems and supporting legislation in parallel to deliver continued financial stability, to support increased competition and innovation and to ensure Canada remains globally competitive.”

“Payments Canada, and the regulatory framework that underpins the organization, has a long, proven history of serving Canadians’ best interests by getting money to where it needs to be, safely,” said Garry Foster, Chair of the Board of Directors of Payments Canada. “But the world is changing. Payments are changing. And innovation is happening no matter what. If we want to continue to serve Canadians in a way that reflects the level of safety and security expected from Canada’s financial system, we need to modernize the Canadian Payments Act.”

Currently, Payments Canada membership is limited to banks, credit union centrals, and select other financial institution types, including securities dealers. Membership is required to access Payments Canada’s infrastructure as a participant. Proposed changes to the Canadian Payments Act would expand membership eligibility to include payment service providers registered with the Bank of Canada, provincially regulated credit unions, and operators of financial market infrastructures designated by the Bank of Canada. To gain access to the payment systems, a Payments Canada member must meet the risk-based access and participation requirements set out in Payments Canada’s by-laws, rules and standards.

Contributed quotes

“As new technology and services continue to transform the way payments are made and processed, amending and broadening access to the Canadian Payments Act can help modernize Canada’s payment landscape. Allowing for a more diverse group of financial service providers can ensure the path is open for innovation and encourage the development of new user-friendly, accessible and cost-efficient payment solutions for small businesses. It can also foster competition within the industry, which can drive costs down and improve financial services.”
Dan Kelly, President and Chief Executive Officer
Canadian Federation of Independent Business (CFIB)

“The most important benefits we can offer Canadian consumers are greater choice and competition within the context of a safe and well-regulated payment system. A measured approach to broadening access to Payments Canada membership, which includes effective rules and robust consumer protection, can help to create a more innovative and competitive marketplace that is good for everyone.”
Elizabeth Mulholland
Prosper Canada

“Canada has a strong record of payment innovation. At the same time, we know we must continue to update policy and regulatory frameworks to ensure they meet the needs of Canadians and support growth and competitiveness in the market. Interac supports updating the Canadian Payments Act to enable broadened participation in national payments infrastructure and will continue to work with industry stakeholders to advance opportunities for increased access on our network and products.”
Kirkland Morris, VP Enterprise Initiatives & External Affairs

“Making the financial sector work harder for its customers is a necessary part of solving Canada’s affordability crisis. Expanding access to payment systems would promote responsible competition in the financial sector, letting Canadian consumers and businesses keep more of their hard-earned money in their pockets.”
Alex Vronces, Executive Director
Fintechs Canada

“Expanding membership to Payments Canada will allow fintechs to serve on the front lines of bringing the benefits of faster payments to consumers, merchants and the economy.”
Scott Talbott, SVP, Government Affairs
Electronic Transactions Association (ETA)  

“The payment fintech industry in Canada has made commendable strides in introducing new and innovative concepts. However, there are still some elements hindering the overall progress of the sector. The lack of representation and access to these fintechs in Payments Canada’s membership is presenting certain obstacles in the discussions surrounding crucial policies and infrastructure. To overcome these hurdles, we firmly believe that expanding membership criteria is necessary. This will enable innovative fintechs to offer Canadians superior products and services, foster healthy competition, and promote innovation. Ultimately, this will help Canada remain competitive in the global fintech landscape. At Fintech Cadence, we wholeheartedly support the idea of extending membership eligibility to Payment Canada’s membership.”
Layial El-Hadi, Executive Director
Fintech Cadence

“Canada must act now to modernize payments. The amendments to the Canadian Payments Act are long overdue and necessary to enable non-bank access to the payment system. Allowing a broader group of financial service providers like Wise to become members of Payments Canada will lower payment costs while increasing speed, competition, innovation, and consumer adoption. Payment modernization will allow Canada to go from a global fintech laggard to a leader.”
Nick Catino, Global Head of Policy & Social Impact

“It is evident that the most significant innovations in payment services within Canada have been pioneered by organizations that, unfortunately, do not qualify for membership within Payments Canada. This exclusion has placed payment service providers (PSPs), such as Telpay, and their valued customers, in a highly disadvantageous position. The inability to participate in the Payments Canada network has stifled competition and hindered progress within our industry. This has resulted in a glaring disparity in access to essential payment infrastructure, directly impacting the ability of PSPs  to offer reliable and flexible solutions to their clients. We firmly believe that broadening access to these systems is not only a matter of fairness but also of economic necessity. It is our assertion that providing greater access will not only empower PSPs but also benefit end-users — both payors and payees. A more inclusive approach to payment systems will foster innovation, enhance competition, and drive the demand for more reliable and flexible payment solutions.”
John Zajic, Vice President, Corporate Policy & Compliance

“Implementation of open banking and amendments to the Canadian Payments Act that allow a broader set of stakeholders to safely and securely gain access to Canada’s payment systems will facilitate a consumer-centric 21st century financial services marketplace. The Fall Economic Statement provides a unique opportunity to meaningfully advance both of these important initiatives and to promote innovation, competition, and a more inclusive Canadian financial services system.”
Steve Boms, Executive Director
Financial Data and Technology Association of North America

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FDATA North America Responds to CFPB Data Broker SBREFA Memo

September 21, 2023, Washington, DC Steve Boms, the Executive Director of the Financial Data and Technology Association of North America, a consortium of financial technology companies united behind the notion that consumers and small businesses should have full control over their financial data, today released the following statement in response to the Consumer Financial Protection Bureau’s (CFPB) outline of proposals and alternatives under consideration by the agency ahead of its “data broker” rulemaking:

 “We welcome the CFPB’s close scrutiny of companies that collect and sell consumers’ data, often unbeknownst to the consumer, and use that data for marketing and advertising purposes.

At the same time, we are concerned that the CFPB did not distinguish in this outline between entities that collect consumer information without consumers’ informed consent and third-party providers of financial products and tools that access consumers’ data at their express direction and consistent with the CFPB’s forthcoming Section 1033 Open Banking rule. 

Entities that enable consumers to access and share their own personal financial information – at consumers’ express direction – are at the heart of open banking and empower consumer choice and control, and improve consumers’ ability to manage their financial lives. These companies should be appropriately regulated under Section 1033, including adhering to the privacy principles FDATA North America members released in March of this year.

The same principles that led to the enactment of the Fair Credit Reporting Act in 1970 – transparency and control for consumers over their financial data – are the hallmarks of customer-permissioned data access marketplace today. Accordingly, as it contemplates a proposed rule in this space, we encourage the CFPB in the strongest possible terms to distinguish between “data brokers” and third-party financial providers that access consumer data based on a consumer’s affirmative request to do so.”

FDATA North America previously responded to the CFPB’s Request for Information (RFI) Regarding Data Brokers and Other Business Practices Involving the Collection and Sale of Consumer Information, submitting a comment letter in June stressing in the strongest possible terms, that third-party providers of financial services that rely on consumer-permissioned data are not data brokers, and therefore should be exempt from any Bureau rulemakings, guidance, or other actions it may consider in the data brokerage space.