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Joint Trades Comment on CFPB FCRA SBREFA Outline
To Whom it May Concern:
The Bank Policy Institute, The Clearing House (TCH), and the Consumer Bankers Association (CBA), appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (the CFPB) Small Business Regulatory Enforcement Fairness Act (SBREFA) outline concerning consumer reporting (hereinafter “SBREFA outline”).
The SBREFA outline represents the first proposed discretionary amendments to Regulation V, which implements the Fair Credit Reporting Act (FCRA), since authority was transferred to the CFPB in 2010. The SBREFA outline cites several reasons the CFPB is engaging in this rulemaking, including concerns about consumer privacy in the “collection, assembly, evaluation, dissemination, and use of vast quantities of often highly sensitive personal and financial data.”7 We share the CFPB’s goal of protecting consumer privacy, and we understand the CFPB is concerned about the ways in which consumers’ data is used outside of the banking context. However, we want to make the CFPB aware that several of the proposals under consideration may have unintended consequences, particularly for banks and bank customers.