Banking and Finance Law Daily CFPB seeks comment on its sources and use of data
Wednesday, September 26, 2018

CFPB seeks comment on its sources and use of data

By Nicole D. Prysby, J.D.

The Consumer Financial Protection Bureau announced the release of a report and Request for Information (RFI) regarding the Bureau’s sources of data and how the data are used. According to the Bureau’s press release, the report (Sources and Uses of Data at the Bureau of Consumer Financial Protection) describes what data the CFPB collects, the sources of the data, and the access and reuse of the data within the CFPB. The CFPB’s data collection policies are governed by a Data Governance Board, which assesses data risks and provides recommendations on data policies. There are also separate groups assigned to provide guidance for data intake (Data Intake Group), management (Data Stewardship), and disclosure (Data Release Group). Data governance is audited by third parties. The CFPB has five main external sources of data: public sources, government agencies, commercial vendors, financial institutions, and consumers. The report publishes the full text of the CFPB’s internal data governance policies and charters.

The RFI seeks comments on the efficiency and effectiveness of the CFPB’s data governance program, its data collections, and whether any changes would be appropriate. The RFI will have a 90-day comment period once it is published in the Federal Register, which is expected shortly. Specifically, the CFPB seeks comment on:

  • best practices for data governance that the Bureau should adopt;
  • data collection practices related to privacy, such as use of direct identifiers and notice to consumers of data known to be related to them;
  • potential changes to the use of scope of data collection;
  • how data should or should not be reused—for example, the use of confidential investigation information to inform other functions of the CFPB;
  • ways to improve the data reporting burden;
  • changes that could be made the data collection to more effectively meet the objectives of the Dodd-Frank Act; and
  • areas where additional data collection would be beneficial.

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