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Personal Financial Data Rights Reconsideration

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Cato Institute filed 1 comment on this docket between Oct 21, 2025 and Oct 21, 2025. 58 other organizations filed here. The comment window closed 280d ago.

What Cato Institute filed (1)

Oct 21, 2025· Comment from Cato Institute· CFPB-2025-0037-13441

October 21, 2025 PERSONAL FINANCIAL DATA RIGHTS RECONSIDERATION c/o Legal Division Docket Manager Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Docket No. CFBP-2025-0037 Personal Financial Data Rights Reconsideration Dear Acting Director Vought: My name is Solveig Singleton, and I am a policy analyst for consumer financial services at the Cato Institute's Center for Monetary and Financial Alternatives. I welcome this opportunity to comment on the Personal Financial Data Rights Reconsideration of the Consumer Financial Protection Bureau (CFPB or the Bureau), which addresses financial data sharing obligations—or "open banking"—under Section 1033 of the Dodd Frank Act. The Cato Institute is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets, and peace. The Center for Monetary and Financial Alternatives identifies, studies, and promotes alternatives to centralized, bureaucratic, and discretionary financial regulatory systems. The opinions I express here are my own. As I explain in greater detail in the attached comments, the Bureau must amend the Final Rule to make it consistent with the language of the Dodd-Frank Act, and to avoid unauthorized, unnecessary, and harmful intervention in financial services markets. The best policy would be for the Bureau to revise the open banking rules to narrow their scope to fiduciaries and/or to allow data providers to charge commercially reasonable fees, without price regulation. Thank you for this opportunity to contribute to the CFPB's reconsideration of the rules for personal financial data rights. I am happy to answer questions or participate further in the discussion of this topic. Sincerely, Solveig Singleton Policy Analyst Center for Monetary and Financial Alternatives Cato Institute ssingleton@cato.org 202-218-4603

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Abstract

SUMMARY: The Consumer Financial Protection Bureau (CFPB or Bureau) is seeking comments and data to inform its consideration of four issues related to implementation of section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). These issues are: the proper understanding of who can serve as a “representative” making a request on behalf of the consumer; the optimal approach to the assessment of fees to defray the costs incurred by a “covered person” in responding to a customer driven request; the threat and cost-benefit pictures for data security associated with section 1033 compliance; and the threat picture for data privacy associated with section 1033 compliance. ADDITIONAL INFORMATION: For more information about commenting on CFPB’s Notices, please visit us at: https://www.consumerfinance.gov/rules-policy/notice-opportunities-comment/commenting-on-notices/

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