The Financial Technology Association (FTA) appreciates the opportunity to provide feedback on the Consumer Financial Protection Bureau’s (CFPB) request for information (RFI) on data brokers and other business practices involving the collection and sale of consumer information.

FTA members provide various types of financial products and services, including data aggregation or consumer-permissioned collection and sharing of data with a third party. Data aggregators empower consumer choice by providing them with the ability to control and share their financial data in order to more conveniently and efficiently view and manage their money and shop for new, more tailored, and lower-cost financial products and providers. Unlike data brokers, this sharing is consumer-permissioned, and FTA members, including data aggregators, do not sell financial information. They also do not have the ability to correct the information that is shared with the data provider.

Therefore, FTA believes that data aggregation is significantly different from data brokering and should not be conflated in any upcoming Fair Credit Reporting Act (FCRA) rulemaking given its focus on the reporting and accuracy of financial information. Instead, FTA supports the CFPB’s efforts to implement Section 1033 of the Dodd-Frank Act to establish a formal open banking regulatory framework in the United States, with attending compliance, data security, and privacy standards.

Read FTA’s full comment letter in response to the CFPB’s request for information here.