Joint Trades Letter to the House Subcommittee on Innovation, Data, and Commerce re: APRA

Dear Chairman Bilirakis and Ranking Member Schakowsky:

The primary privacy and data security consumer protection law for financial institutions is Title V of the Gramm-Leach Bliley Act (GLBA). We support legislation to put in place a national privacy standard, but that standard must recognize the strong privacy and data security standards that are already in place for the financial sector under the GLBA and other financial privacy laws (e.g., the Fair Credit Reporting Act and Right to Financial Privacy Act) and avoid provisions that duplicate or are inconsistent with those laws.

As currently framed, Title I of the American Privacy Rights Act of 2024 (APRA) does not include clear language for financial institutions to understand their exemption from the requirements of the bill. Section 120(b)(3) only excludes data subject to the GLBA, as opposed to exempting financial institutions subject to the GLBA.

This will lead to duplicative and conflicting requirements for financial institutions already subject to oversight by GLBA regulation. As currently drafted, the bill would be disruptive to the financial system, consumers, and the economy. We urge that Title I of the APRA be amended to exempt all financial institutions subject to the GLBA to avoid such disruption.

Sincerely,
American Bankers Association
America’s Credit Unions
Bank Policy Institute
Consumer Bankers Association
Independent Community Bankers of America
Mortgage Bankers Association
Securities Industry and Financial Markets Association