CFPB Awkwardly Finalizes A Portion Of Its Personal Financial Data Rights Rule

As we discussed in the fall over a series of articles (Part 1, Part 2, Part 3, and Part 4) and reported on further in January, the Consumer Financial Protection Bureau ("CFPB") is on a mission to allow consumers to more easily change financial services providers so that they may experience so-called "open banking", allowing more "opportunities for smaller financial institutions and startups" to get into the consumer financial services market. The CFPB's proposed Personal Financial Data Rights Rule ("PFDR Rule") conceives to achieve this by requiring regulated banks and licensed financial institutions to allow largely unlicensed big data and tech companies to access and transfer almost all consumer account information from those licensed and regulated institutions with as little of their involvement and oversight as possible. This is all because the CFPB believes that "dominant firms" maintain their market position in part by holding customer information hostage, and