Consumers Should Own Their Financial Data: MX Comment to the CFPB

Jane Barratt — Chief Advocacy Officer at MX

We believe that modern connectivity to financial data is the foundation for increased innovation in the financial industry and long-term financial health for consumers. Without reliable and secure data access, consumers have little transparency or insight into what is going on in their financial lives. By having secure access to their own financial data, they'll be able to make more informed decisions about their own finances.

Last October, the Consumer Financial Protection Bureau (CFPB) asked for comments on the Advanced Notice of Proposed Rulemaking (ANPR) regarding financial records data access under Section 1033 of the Dodd-Frank Act. Read our response.

We believe that the time is now for the CFPB to move the U.S. into the next chapter of fintech innovation. We believe a clear, cross-agency regulatory framework will accelerate adoption of open finance and improve the financial health of millions of Americans. 

To accomplish this, we propose that the CFPB do the following:

• Create a consumer data right that assigns clear ownership of financial data to the consumer
• Establish minimum data standards defining data that companies must share upon permissioning, based on the Financial Data Exchange (FDX) standard, with clear guidelines on exceptions
• Provide regulatory oversight of data aggregators and intermediaries such as MX, to ensure consistency across the ecosystem
• Set clear guidelines on liability in tandem with Regulation E modernization

These steps are mandatory for creating a fintech ecosystem of the future that puts consumer protection above all and in turn provides greater competition for market participants, legal protection for parties involved, and allows the U.S. and its companies to compete on a global stage.

We want all Americans — regardless of where they choose to bank, make payments, or borrow —  to have access to modern connectivity that safeguards their data and their deposits. This means having secure access to all of their financial data and the ability to share it with the providers of their choice, ensuring the best solutions for them and their families.

We look forward to continuing the conversation and working closely with the CFPB, fintechs, and banks to move the industry forward.To set up time to learn more about MX’s progress to date in open finance, please email us at OpenFinance@mx.com