Consumer Financial Data Aggregation: Identifying Key Concerns and the Potential for Regulatory Intervention

April 30, 2018 3:45pm

Stanton R. Koppel
Of Counsel
Bryan Cave Leighton Paisner LLP

Heidi Wicker
Schwartz & Ballen LLP (Washington, DC)

  • Examining the various ways that consumer financial data aggregators obtain, maintain, use and disclose consumers’ financial data
    • Screen scraping
    • Application Program Interfaces (“APIs”)
    • Product aggregators
  • Assessing the latest policy debates and regulatory activity surrounding these practices, both here and abroad
  • Understanding the divergent interests between banks, aggregators, Fintechs and regulators
    • What are the banks’ major concerns with aggregators’ business models?
  • Taking a close look at the CFPB’s outlined principles for consumer-authorized financial data sharing and aggregation
    • What do these points indicate about the CFPB’s future enforcement or supervisory initiatives in this space?
  • Analyzing the regulatory approaches to data access in the EU and UK
  • Best practices for operating in an uncertain regulatory environment in the near term
    • Key components of an effective self-regulatory system