The Financial Technology Association (“FTA”) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) request for information regarding the collection, use, and monetization of consumer payment and other personal financial data. As discussed in the request, the goal of the collection of this information is to “determine whether additional actions are warranted to protect consumer privacy.”
FTA believes that consumer choice, trust, and protection are the cornerstone of financial services. FTA’s payments companies comply with numerous federal and state data collection, use, privacy, and security requirements, including the Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations. Appropriate and consistently-applied protections for consumer financial data are essential and support a more fair, accessible, and competitive financial system capable of better serving all American consumers and small businesses.
This submission provides an overview of the key federal and state laws and regulations that govern payments companies’ collection and use of personal information, in an effort to better inform any additional policy actions undertaken by the Bureau. It is important to note that in addition to the various privacy laws listed below, payment companies are also subject to other laws governing the use of consumer information, including the Bank Secrecy Act and its implementing regulations which requires financial institutions to identify and verify customers.
Read FTA’s full response to the CFPB’s request for information on consumer payments data privacy here.