The American Financial Services Association (AFSA) has announced the submission of comments to the Consumer Financial Protection Bureau's (CFPB) Personal Financial Data Rights Reconsideration Advance Notice of Proposed Rulemaking (ANPR). The comments address key implementation and consumer-risk questions, as said on AFSA's blog.
According to Consumer Finance, the CFPB reopened its Personal Financial Data Rights Rule, which implements Dodd-Frank §1033, through an advance notice of proposed rulemaking in August 2025. This move aims to reassess open-banking issues and definitions while inviting public input after litigation paused elements of the 2024 final rule. AFSA’s filing focuses on several areas including who may act for consumers, how costs are allocated to covered persons, potential consumer harms from data-sharing in a high-threat environment, risks of inadvertent disclosures, and possible competition benefits from consumer-authorized transfers.
The original compliance dates for the Personal Financial Data Rights were staggered from April 1, 2026, through April 1, 2030, based on entity size. Following the Bureau’s reconsideration move, a federal court stayed compliance dates by 90 days pending the new rulemaking trajectory. This has added uncertainty for firms planning technology and vendor integrations.
Cybercrime indicators highlight AFSA’s caution regarding data-sharing risks. The Federal Bureau of Investigation's Internet Crime Complaint Center (IC3) logged 859,532 complaints in 2024 with reported losses amounting to $16.6 billion—a 33% increase year over year—with older Americans experiencing significant losses. Elevated breach and fraud levels complicate secure transmission and storage by third parties in open-banking flows.
Founded in 1916 and headquartered in Washington, D.C., the American Financial Services Association is the national trade association for the U.S. consumer credit industry. AFSA advocates for access to credit and consumer choice, representing a broad membership across vehicle finance, installment lending, and other credit providers.