The American Fintech Council (AFC) has submitted comments to the California Privacy Protection Agency (CPPA) regarding its proposed Accessible Deletion Mechanism regulation. The AFC, representing fintech companies and innovative banks, supports consumer control over personal data but raises concerns about potential negative impacts of the current proposal.
Phil Goldfeder, CEO of the American Fintech Council, stated, "AFC members are committed to responsible data management, but California’s proposed rule introduces ambiguity that could disrupt consumer access to safe and responsible financial services." He emphasized the need for improvements in the regulation to better protect consumers and support innovation.
The proposed rule aims to establish a centralized Delete Request and Opt-Out Platform. However, it expands the definition of "data broker" in a way that may misclassify companies collecting information directly from consumers. This could lead to operational changes confusing consumers and increasing regulatory burdens without enhancing consumer protection.
Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC, expressed concern: “The CPPA’s goals are important, but the current proposal risks causing more harm than good.” He noted issues such as misclassification of providers, lack of robust verification requirements, and formatting mandates potentially affecting data integrity.
The letter also addressed specific concerns about a proposed 50% match threshold for deletion requests. This threshold might result in mistaken deletions harming consumers and creating liability risks for providers. Additionally, data formatting requirements were criticized for potentially compromising data accuracy and cultural representation.
AFC is a trade association representing major fintech companies and innovative banks offering embedded finance solutions. Its mission is to promote a transparent financial system by supporting responsible innovation in financial services.