Joint Trades Letter to CFPB on 1033 Compliance Dates

Dear Director Chopra:

The Bank Policy Institute, The Clearing House Association, the Consumer Bankers Association, and the American Bankers Association are writing to provide additional information relevant to the Bureau’s Proposed Required Rulemaking on Personal Financial Data Rights issued pursuant to section 1033 of the Dodd-Frank Act and the proposed compliance dates set forth therein in light of more recent implementation planning efforts of our members and the CFPB’s recent issuance of a final rule setting forth the procedures under which a standard-setting body may apply for and obtain CFPB recognition.

Our members are already engaged in planning and preparation to comply with the final rule, but given the novelty of the regulation and complexity of the proposed regime, we would like to reemphasize our comments that a compliance date of at least 2 years from the issuance of a final rule would be most appropriate to enable even the most sophisticated data providers to be fully compliant and to minimize any customer disruption. As the associations and their members have continued to review and analyze the proposal to plan and prepare for implementation, it has become even more clear than we had previously articulated in our comment letters that, once a final rule is issued, banks likely will have to make complex and time-intensive changes to their systems and processes to implement, and create associated controls to ensure ongoing compliance with, the requirements of a final rule.

Download the joint comment letter to read the full text.