Product or service providers that access information and initiate payments should obtain separate and distinct consumer authorizations for these separate activities. - Craig Brown, Co-founderOur work is licensed under a Creative Commons Attribution-Share Alike 3.0 License. 4 CFPB, Prepared Remarks of CFPB Director Richard Cordray at Money 20/20 (Oct. 23, 2016), https://www.consumerfinance.gov/about- 8 Mayer Brown | Whose Data Is It? Some people have argued that the rulemaking clause only permits the Bureau to issue rules that limit a financial institution’s obligations under Section 1033—not to require the financial institution to do anything.

To view this article you need a PDF viewer such as On October 18, 2017, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released guidance that is intended to provide the Bureau’s “vision for realizing a robust, safe, and workable data aggregation market that gives consumers protection, usefulness, and value.”1 Many companies in the “fintech” space have developed products that provide a user interface that allows customers to access information about accounts at other financial institutions that have no relationship with the fintech provider—and even to initiate transactions with the account at the unrelated financial institution. Certain language in the data sharing principles may require further clarification. Security practices should be adapted to encompass new threats as they emerge. • Will third parties be required to provide the financial institution with information that the financial institution determines that it needs in order to effectively monitor for suspicious transactions? CFPB Releases Consumer Protection Principles for Consumer-Authorized Financial Data Sharing and Aggregation 6. The principles also suggest that product and service providers must allow a third party authorized by the consumer to access that consumer’s financial information.13 Both of those suggestions impose significant obligations on service providers that may be in conflict with commonly accepted market practices and legal rights concerning consumer information and, in the case of mandatory sharing with consumerauthorized third parties, may add security concerns relevant to the required sharing of data with third parties.
Trump has called the Bureau “a total disaster,” and the “worst of Dodd-Frank” because “financial institutions have been devastated and unable to properly serve the public” (this “alternative fact” is completely fake, as banks have made With Trump’s blessing, Mulvaney has been disastrous for consumers by removing the CFPBWhat’s the latest Trump administration ploy at internally dismantling the Bureau? 111–203, §1033, 124 Stat.
Commercial participants should prevent, detect and resolve unauthorized access and data sharing, unauthorized payments conducted in connection with or as a result of either authorized or unauthorized data sharing access, data inaccuracies, insecurity of data and failures to comply with other obligations, including the terms of consumer authorizations. "Trump Administration War on CFPB Is Bad News for Communities of ColorBecause of people like you, another world is possible. And there are some significant AML and sanctions compliance issues that financial institutions need to consider: • How does a financial institution ensure that the third party has a user authentication mechanisms that is sufficiently robust to reasonably assure that the party accessing the account is the customer or authorized user whose identity the financial institution verified and periodically sanction-screens?

The identity and security of each such party, the data they access, their use of such data and the frequency at which they access the data should be reasonably ascertainable to the consumer throughout the relevant access and storage period. And Trump’s latest move will make things even worse.By mandating the Bureau’s creation in the Dodd-Frank Wall Street Reform and Consumer Protection Act, the U.S. government sought to prevent another financial catastrophe by designing an independent agency to protect consumers by cracking down on unethical practices by banks, mortgage servicers, credit unions, payday lenders and other financial service providers.The Bureau’s vigilance and investigations were particularly important for consumers of color because it refused to be race-blind in its oversight. Revocations should be implemented by providers in a timely and effective manner and, at the discretion of the consumer, provide for third parties to delete personally identifiable information. 4. 10 CFPB, Consumer Protection Principles: CFPB’s Vision of Consumer Protection in New Faster Payment Systems (July 9, 2015), http://files.consumerfinance.gov/f/201507_cfpb_consum er-protection-principles.pdf. It’s unclear.