CFPB's Personal Financial Data Rights Proposed Rule, Part 4

This final installment of our coverage on the Consumer Financial Protection Bureau's proposed rule regarding “personal financial data rights” builds upon concepts and concerns covered in our earlier posts. For an overview of the rule, read our first installment. To understand what entities would need to comply with the proposed rule, read our second installment. To better understand the obligations and technology requirements of the proposed rule, read our third installment.

As promised, this fourth and final installment picks up on a few issues not already discussed and highlights portions of the proposed rule that are likely to cause great conflict and consternation for the entities subject to the rule. First, and this is an issue that is ripe for conflict, is the compliance timelines included in the proposed rule. As ever, the CFPB continues to push for aggressive compliance timelines and to default on pushing the largest institutions to comply with the proposed