Financial access

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FDATA North America Responds to Banking Trade Associations’ Petition Urging CFPB Supervision of Data Recipients

Contact: Kerrie Rushton, (202) 365-6338, [email protected] 

August 2, 2022, Washington, DC -In response to the recent petition from several banking trade associations urging the Consumer Financial Protection Bureau to supervise both data aggregators and data recipients, FDATA is releasing the following statement:

“FDATA and its members have long advocated for the CFPB to supervise data aggregators as part of its 1033 rulemaking. The joint trades petition, however, calls for the Bureau to supervise aggregators and data recipients. This would require the Bureau to supervise thousands of additional entities — including scores of community banks and credit unions that are today acting as data recipients but are currently exempt from CFPB supervision.

FDATA continues to believe that the most appropriate path for the Bureau to oversee the consumer-permissioned data spec is to supervise aggregators and to promulgate third-party guidance laying out the CFPB’s expectations for the aggregators’ clients: the data recipients.”

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FDATA North America Submits Comments to Canada’s OSFI on Draft Guideline B-10: Third Party Risk Management

Contact: Kerrie Rushton, (202) 365-6338, [email protected] 

June 29, 2022, Washington, DC -The Financial Data and Technology Association of North America today submitted comments in response to Canada’s Office of the Superintendent of Financial Institutions’ (OSFI) public consultation on Draft Guideline B-10: Third Party Risk Management.

The comment letter focused on the interplay between this draft consultation and the concurrent development of Canada’s open banking framework, particularly the importance of clearly distinguishing third-party providers from open banking providers that will be accredited under the new OB system. 

The letter also stressed that since it is OSFI’s mandate to keep FRFIs and, by extension, Canada’s financial system, safe, sound, and secure, it is critical to distinguish third-party providers who directly work with Federally Regulated Financial Institutions (FRFIs), from providers serving consumers whose only relationship with a FRFI is accessing data about that consumer to provide the customer with the benefit of their product or service. For example, an FRFI may have a relationship with the data aggregator who is performing the function of data portability on behalf of that customer, but it most likely does not have a relationship with that budgeting application, and therefore could not reasonably oversee or be responsible for its operations. 

The letter also expressed appreciation for OSFI’s clarification provided by a footnote at the end of the consultation, which recognizes that this draft guideline is not intended to impede the establishment of open banking, but stressed that this footnote alone does not satisfactorily address the need to ensure coordination of accreditation for open banking providers. We therefore suggested to OSFI that the most appropriate amendment to address this critically important issue would be to make unambiguously clear that accredited open banking providers under Canada’s open banking system are exempt from OSFI’s third-party risk management framework.

We also urged OSFI to create a specific carveout from B-10 for all accredited open banking providers under Canada’s open banking framework as part of this consultation, and before the new open banking system is implemented. 

A copy of the letter is available here: FDATA NA Submission to OSFI on Draft Guidance B.10

ABOUT FDATA NORTH AMERICA
FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGO, Codat, Direct ID, Envestnet Yodlee, EQ Bank, Experian, finansystech, Fiserv, Flinks, Hank Payments, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, RocketMortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

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FDATA North America Responds to CFPB Request for Information (RFI) on ‘Junk Fees’

Contact: Kerrie Rushton, (202) 365-6338, [email protected] 

April 8, 2022, Washington, DC – The Financial Data and Technology Association (FDATA) of North America submitted a comment letter today to the Consumer Financial Protection Bureau (CFPB) in response to its Request for Information (“RFI”) regarding fees assessed by financial services companies. FDATA used this opportunity to once again urge the CFPB to finalize a regulation under Section 1033 of the Dodd-Frank Act, an action which would create a long-overdue consumer data right in the United States. 

The letter states that FDATA believes the most practical remedy to reducing predatory fees in the financial ecosystem is to implement an open finance regime in the United States, stressing that “the center of such a framework must be an unambiguous and legally binding customer financial data right, which would ensure that consumers and small businesses could easily shop for financial services and products among scores of potential providers in an open, transparent marketplace.”

The lack of a customer financial data right in the United States reduces competition in data-driven financial services, artificially stifles consumer choice and creates an environment in which fees charged to end users may stay stagnant – or even increase – over time. To tackle these thorny challenges, FDATA North America once again encouraged the CFPB to utilize the authority vested in it under Section 1033 of the Dodd-Frank Act to promulgate, by rule, a customer financial data right that will “spur greater financial services innovation and competition, lower fees, and improve financial access and inclusion.” 

To further demonstrate how a consumer data right could help address the issues raised in the RFI, the letter makes note of CFPB Director Rohit Chopra’s remarks during a press call regarding overdraft fees in December of last year, where he astutely noted that “If America can shift to an open banking infrastructure, it will be harder for banks to trap customers into an account for the purpose of fee harvesting.” 

The letter also shared information on the successful implementation of open finance regimes in other countries which demonstrate the wide-ranging economic and consumer benefits that can be delivered by a final 1033 rule. A copy of the letter is here: FDATA CFPB Junk Fee RFI Letter April 2022

ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGO, Codat, Direct ID, Envestnet Yodlee, EQ Bank, Experian, finansystech, Fiserv, Flinks, Hank Payments, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, RocketMortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

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FDATA NA and Paytechs of Canada Release Landmark Survey on Canadian Consumer and Small Business Attitudes Toward Financial Sector and Open Banking

Contact: Steve Boms ([email protected]); Alex Vronces ([email protected])

April 4, 2022, Toronto and Washington, DC: More than half of Canadians feel stress when interacting with Canada’s financial services sector and believe they would benefit from increased competition and transparency in the financial services market, according to a landmark survey commissioned by FDATA North America and Paytechs of Canada. The findings indicate this is especially true among women, young people, and new Canadians. Among the biggest sources of dissatisfaction are high fees and a lack of choice.

The findings are derived from two surveys conducted by Pollara Strategic Insights. One was of a randomly-selected sample of 2,001 Canadians 18 years of age or older. The other was of a randomly-selected sample of 600 Canadian small business owners. In each, respondents were asked about their experiences with Canada’s financial services sector. 

“As the government advances critically important initiatives to modernize Canada’s financial services market, including open banking and payment modernization, the voices of consumers and small businesses must be at the center of the conversation,” said Steve Boms, Executive Director of FDATA North America. “These first-of-their-kind surveys clearly demonstrate Canadians’ hunger for a more competitive, transparent, and innovative Canadian financial system.” 

“At a macro level, we’ve long known that the Canadian financial services sector isn’t as productive as it could be because of barriers to competition and innovation, which is part of the reason why the government is modernizing its approach to financial sector policy,” said Alex Vronces, executive director of Paytechs of Canada. “These surveys shine a light on the often-neglected human cost of less competition and innovation for consumers and businesses.”

“The survey findings show that navigating the financial services sector is a stressful experience for about half of Canadians and small business owners.” said Dan Arnold, Chief Strategy Officer at Pollara. “So it is not surprising that both audiences see the potential benefits that reforms to the sector could bring.”

Key Findings:

  • About half of Canadians (52%) and small business owners (51%) feel stress when interacting with the financial services sector. Those who operate larger small businesses (10+ employees) are significantly more stressed (72%). Moreover, the majority (54%) of these larger small business owners feel the amount of time they spend dealing with the financial services sector is getting in the way of them actually running and growing their business, twice the overall level among small business owners (26%). Immigrant small business owners are more likely to be stressed by their interactions with the sector.
  • Over two-thirds of Canadians believe more competition in the financial services sector would lead to a greater choice in products (70%) and lower financial services fees (67%). Moreover, small business owners are over four times more likely to agree than disagree with the sentiment that Canadian small businesses would benefit from increased competition in the financial services sector (64% vs. 14%).
  • Among specific changes tested, Canadians are most likely to feel they would personally benefit from easier ways to “shop around” to get the best possible rate (75% would benefit), easier ways to transfer money quickly and securely (73%), and tools that help make personalized investment decisions (69%). 
  • Among specific changes tested, small business owners are most likely to feel they would benefit from easier ways to “shop around” to get the best possible rate (73% would benefit), better ways to transfer funds between different accounts (68%), and alternatives to credit cards with lower interchange fees for merchants (62%). 
  • There is widespread agreement among the users of Non-Bank FinTech Apps that they are easy to use (91%), have lower fees (82%), and help save money (73%).

To access the full survey data, click here.

For media enquiries or interviews, please contact:

Steven Boms

Executive Director, FDATA North America

[email protected]

Alex Vronces

Executive Director, Paytechs of Canada

[email protected]

About FDATA North America

FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based financial tools to better manage their finances.

About Paytechs of Canada

Paytechs of Canada is a not-for-profit association that provides a harmonized voice for technology companies that move money. Our mission is to make Canada’s financial sector more competitive and innovative, without compromising its safety and soundness. Serving millions of Canadians on a daily basis, our membership includes payment processors, financial technology companies, and financial institutions, among others.

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FDATA North America Applauds Choice for Canadian Open Banking Lead

Contact: Kerrie Rushton, (202) 365-6338, [email protected] 

March 22, 2022, Washington, DC – The Financial Data and Technology Association (FDATA) of North America today issued a statement following the announcement that Abraham Tachjian will serve as Canada’s Open Banking Lead. In its August 2021 report, the Minister of Finance’s Advisory Committee on Open Banking recommended the appointment of an Open Banking Lead who would report to the Associate Minister of Finance Canada as a critical first step in the delivery of open banking in Canada.

Executive Director Steve Boms said:

“Today represents an important step forward in Canada’s efforts to deliver open banking by 2023. We are encouraged by this action and look forward to working with Open Banking lead Tachjian to ensure a competitive, customer-centric open banking ecosystem in Canada that boosts financial access and inclusion.

“Consumers and small businesses also should be pleased with this forward momentum. Around the world, open banking regimes have led to greater financial access and competition, lower pricing, improved financial outcomes. Canadian consumers have increasingly moved toward digital financial services, particularly throughout the pandemic. Today’s announcement is a meaningful step towards the realization of an innovative, customer-centric financial services system in Canada.”

In a letter to Freeland sent in early November 2021, FDATA said the Open Banking Lead should be responsible for working with industry to create the policy and governance standards under which open finance can be delivered in early 2023 as set forth in the report.

ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Basis Theory, Betterment, BillGo, Codat, Brian J. Costello, Direct ID, Envestnet Yodlee, EQ Bank, Experian, finansystech, Fiserv, Flinks, Hank Payments, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, RocketMortgage, SaltEdge, Trustly, ValidiFI, Vaultree, VoPay, Wealthica, Xero, and others.

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Member Spotlight: TransUnion

TransUnion has been on the cutting edge of consumer data technology for more than half a century and is one of the world’s leading global information and insights companies. TransUnion serves consumers in more than 30 countries on five continents. In the United States alone, more than 166 million people have received free access to their credit information through TransUnion or its partners.

Information for good is TransUnion’s mission and the company is focused on using data to enhance financial inclusion. Helping individuals who too often have been left behind by traditional systems, the company’s alternative data assets can help create a more complete picture of a consumer’s risk profile. To date through trended and alternative financial data, TransUnion has helped 35 million credit invisible or credit-disadvantaged people gain greater access to credit. If scaled, the company estimates that the inclusion of alternative financial data could help an additional 60 million people gain access to credit.

TransUnion has long been an advocate for the use of alternative financial data. The company’s President & CEO, Chris Cartwright remarked “If alternative data is widely captured on credit reports and used by lenders in credit underwriting, the benefits would cascade across generations and all corners of America.” Because of that “more families would be able to flourish in the financial ecosystem, constructing legacies of prosperity they can pass along to their children,” he added.

As financial institutions look for new ways to support financial inclusion, TransUnion remains committed to doing their part to create a better future and more fair society. They recognize this important work is just beginning and their goal will be met once equity and credit access is an integral part of an economy where no American is left behind.

For more information on TransUnion, please visit www.transunion.com

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Member Spotlight: Petal

Technology has changed the way people bank, invest, and manage their money. Petal takes a new approach to consumer credit, enabling customers to use their own bank account data – rather than a traditional credit report – to access safe and affordable financial products and services and to build credit, avoid debt, and spend responsibly.

Traditional banks often rely on outdated measures of creditworthiness, such as traditional bureau-based credit scores, in determining which consumers get approved for a new loan or line of credit. This approach has resulted in the tens of millions of Americans with thin or no credit files being unable to access financial products such as car loans, credit cards, or mortgages. To address this problem, Petal offers credit cards (issued by WebBank) to consumers based on “cash flow underwriting” – using a customer’s bank transaction history to evaluate their creditworthiness, examining income, savings, and spending patterns. The insights gained from cash flow underwriting have allowed Petal to expand access to the financial system to many American consumers who otherwise would not have received credit and enable these consumers to build credit profiles to help them access additional products and services. The majority of Petal members had little to no credit history when approved, and more than 40% were previously denied credit by a major bank or card issuer. Petal members with no prior credit history achieve an average credit score of 680 after just a few months of responsible use.

The Petal card goes beyond providing access to credit: it has numerous features designed to help members succeed financially. Petal’s Leap program provides a clear pathway for members to qualify for a credit limit increase, while also promoting responsible financial behavior. Customers enrolled in Petal’s Leap program that make six on-time monthly payments in a row and maintain a healthy credit score are guaranteed a credit limit increase. The Leap tab on Petal’s mobile app provides a convenient platform for customers to track their progress and includes customized suggestions for members to improve their financial health and build their credit profile. In addition, Petal distinguishes itself from other credit cards by encouraging customers to pay their full balance each month. Mainstream credit cards, meanwhile, often put consumers on a more expensive path by making “pay the minimum” the starting point. Petal members who cannot pay the full balance can use the Petal app’s payments calculator to easily understand exactly how much interest they will owe. Petal has also offered incentives, including a chance to win up to $500, to encourage members to pay more than the minimum on their monthly statement. Finally, to further encourage financial responsibility, Petal provides qualifying members with extra cash back on purchases – beyond the standard 1% – when they establish a history of making on-time monthly payments.

In April 2021, Petal launched Prism Data, a new company that enables banks, fintechs and other business customers to translate consumer-permissioned bank account data into useful insights and a CashScore that can help determine creditworthiness. By integrating Prism Data into their lending applications, users can improve their ability to reach consumers that have been left out of the mainstream financial system – particularly those who are credit invisible. Prism Data was founded on the belief that open banking and access to consumer-permissioned bank account transactional data will change the way consumer finance works. When announcing Prism Data, Jason Gross, Petal CEO and co-founder, said, “Prism Data is the next great step in furthering Petal’s original mission to democratize access to credit, now by empowering other organizations to serve more customers, build better products, and make smarter decisions.”

Petal’s success at reaching traditionally underserved consumers has demonstrated that open banking policies can help expand financial inclusion. In a June 2019 op-ed co-written with FDATA North America, Gross argued that bringing open banking to the United States could help policymakers address the fact that:

  • 45 million Americans cannot access the modern credit system because of a lack of information in their credit report;
  • 4 in 10 American adults don’t have savings necessary to cover a $400 emergency; and
  • American consumers face up to $34 billion in overdraft fees annually.

For more information on Petal’s advocacy for open banking, you can read Petal’s written statement provided as part of the CFPB’s February 2020 symposium on consumer access to financial records, as well as Petal’s submitted comments to CFPB as part of the1033 rulemaking process and a Medium post by CEO Jason Gross published earlier this year titled “Your financial data belongs to you, not your bank.”

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FDATA North America Submits Comments to US Financial Regulators’ Request for Information on Financial Institutions’ Use of AI and ML

June 29, 2021, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America submitted comments to the US financial regulators as part of their Request for Information (RFI) on financial institutions’ use of artificial intelligence (AI), including machine learning (ML). The Federal Reserve, Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (NCUA), National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC) sought comments on the use of AI by financial institutions and their products and services to consumers.

Throughout the submission, FDATA North America Executive Director Steve Boms discussed the importance of embracing new technologies that improve customer experience and foster innovation. Additionally, Boms noted that “as nations around the world adapt to modernized open finance regime in which the consumer and small business have the unfettered ability to access and share their financial data with companies of their choosing, financial institutions and service providers are quickly embracing AI to attract and retain their customers, expand access to credit and improve financial access, and combat financial crime.”

Boms concluded by underscoring that “the promulgation of a legally binding financial data right is a critical first step towards broader deployment of AI-enabled financial tools that can meaningfully improve financial access and wellbeing,” along with more clarity from the agencies regarding the application of existing supervisory expectations on third-party bank partners that utilize AI-enabled tools for various financial products and services.

Image result for paperclip iconFDATA North America Submission to Financial Regulators’ AI/ ML RFI

 

ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances.

Members include air (Alliance for Innovative Regulation), APImetrics, Betterment, BillGo, Codat, Direct ID, Envestnet Yodlee, EQ Bank, Experian, Fiserv, Flinks, Interac, Intuit, Inverite, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, SaltEdge, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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FDATA North America Responds to US CFPB ANPR on Consumer Access to Financial Records

February 3, 2021, Washington, DC – Today, FDATA North America submitted comments to the US Consumer Financial Protection Bureau (CFPB) in response to its Advanced Notice of Proposed Rulemaking (ANPR) regarding consumer access to financial records, or Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

In the submission, FDATA North America Executive Director Steve Boms praised the CFPB for formally beginning the process of crafting a rule in this critically important area following many years of careful examination of the customer-permissioned data access and financial services ecosystems. “FDATA North America strongly supports the authority given to the CFPB by Congress in 2010 to promulgate, by rule, a consumer financial data right that will spur greater financial services innovation and competition and improve consumer financial access and inclusion,” Boms noted.

Boms concluded the association’s submission by encouraging the Bureau “to fully utilize its Section 1033 authority to create a customer financial data right to allow consumers and small businesses to have unrestricted access to technology-based tools that can help them improve their financial wellbeing, along with other important bedrocks of an open finance regime.”

Image result for paperclip iconFDATA North America CFPB ANPR Submission

ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances. Existing FDATA North America members include: air (Alliance for Innovative Regulation), API Metrics, Betterment, Direct ID, Envestnet Yodlee, EQ Bank, Experian, Fintech Growth Syndicate, Fiserv, Flinks, Interac, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, ValidiFI, VoPay, Wealthica, Xero, and others.

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