As previously reported in last week’s edition of the Bottom Line, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) containing the Personal Financial Data Rights rule to implement Section 1033 of Title X of the Dodd-Frank Act. In connection with the proposed rule, the Bureau released a Fast Facts summary of the proposed rule on November 1. Fast Facts is designed to provide an executive summary of the topics covered in the proposed rule.
The first thing that jumps out of the NPRM and the summary is that a data provider will be required to create a developer interface through which it receives and responds to requests for covered data and to protect the developer interface through an information security program that satisfies the Gramm-Leach-Bliley Act. The CFPB is expected to issue its final rule implementing Section 1033 in the fall of 2024. Comments on the CFPB’s proposed rule are due on or before December 29, and IBAT will submit a comment letter.