Letter to CFPB on the Digital Governance Standards Institute Application

Dear Director Chopra,

The American Bankers Association (ABA) appreciates the opportunity to comment regarding the Digital Governance Standards Institute application for recognition pursuant to 12 CFR Part 1033. We write to oppose the application due to its deficiency in two main areas: 1) the application fails to meaningfully address any of the standards in the rule, or the organization's relationship with them; and 2) the application fails to demonstrate a significant nexus between the organization and the US data sharing ecosystem. The lack of this context in the application renders it impossible to assess the Digital Governance Standards Institute's fitness for recognition as a standard-setting body under 1033.

In June 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) finalized a portion of its 1033 rule related to a recognition process for standard-setting bodies to offer evidence of compliance with certain substantive regulatory requirements. The partial final rule includes an appendix providing a step-by-step guide on how organizations can apply for recognition under Part 1033.

In order to receive recognition by the Bureau, the partial final rule codified at 12 CFR 1033.141 requires a standard-setting body to demonstrate that it satisfies the following attributes: openness, balance, due process and appeals, consensus, and transparency.

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