The CFPB Is Reconsidering Personal Financial Data Rights Rule Under The Dodd-Frank Act

On August 22, 2025, the Consumer Financial Protection Bureau (CFPB) issued an advance notice of proposed rulemaking seeking public comment on potential revisions to its Personal Financial Data Rights Rule (the Rule) under Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Specifically, the CFPB is seeking comments on four issues:

1. Section 1033 of the Dodd-Frank Act defines a "consumer" to include an individual or an agent, trustee, or representative acting on behalf of a customer. The CFPB is requesting comment on whether representatives must be fiduciaries or whether non-fiduciary third parties can also qualify.
2. The Rule prohibits data providers from charging Consumers or third parties fees for providing access to data. The CFPB is requesting comment to determine the optimal approach to whether reasonable cost recovery should be allowed and whether caps should be imposed if fees are permitted to defray the costs