Produced in partnership with the Financial Health Network, Flourish Ventures, and Mitchell Sandler, this working paper provides a detailed summary of the current U.S. federal legal framework governing consumer financial data.
The working paper elaborates on the legal and regulatory background in our previous reports on the use of cash-flow data in credit underwriting by describing relevant private sector participants in the financial data ecosystem, the primary regulatory agencies responsible for their oversight, and the main bodies of U.S. federal law governing consumer financial data. The legal summaries explain the types of entities and data covered, nature of regulatory oversight, and substantive requirements pertaining to financial data. Commentary sections highlight open issues, areas of ambiguity, and other timely topics related to the application of current law and regulation to the rapidly evolving financial services landscape.
The paper is intended to lay a foundation for stakeholders’ future policy analyses and discussions. To provide feedback on the draft report, please email comments to datalandscape@finreglab.org.
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