In a comment letter last week, the American Bankers Association urged the Consumer Financial Protection Bureau to operate transparently in its collection and use of data and to adopt safeguards to ensure it does not order the production of data that is overly broad, voluminous or duplicative. The letter was submitted in response to the bureau’s request for information on its data collections and data governance program — the latest RFI in the CFPB’s feedback initiative.
Before making demands for data, ABA noted that the bureau should weigh the benefits to the agency and the costs to regulated entities of obtaining the data. It should also exercise care when considering “reusing” data and make available to the public anonymized, de-identified data that it relies upon for policymaking decisions, ABA said. The association also encouraged the bureau to implement the Inspector General’s recommendations to address vulnerabilities in its information security program, and reiterated its calls for the CFPB to withdraw its proposed HMDA guidance.