Thoughts on consumer data access

Plaid’s role in connecting financial institutions, fintech developers, and consumers places us in a unique position in the ongoing discussion around consumer data access in financial services. These issues could have a big impact on consumers and developers, which is why we regularly engage with and learn from others in the ecosystem. Given our role as a trusted intermediary to the financial services ecosystem, we think it’s critical to invest in information sharing.

We’ve taken this ecosystem approach in our response to the Consumer Financial Protection Bureau’s (CFPB’s) Request for Information on consumer financial data access. Given our experience working with parties from across the industry, we wanted to share with regulators and other parties our learnings. We also thought it important to help give a voice to the members of the fintech community who aren’t often represented in policy discussions. The takeaway for us is that these voices are more often than not in agreement with those at traditional financial services.

To achieve our goals, we took two separate approaches to the RFI. We wrote an industry cover letter, signed by nearly sixty members of the fintech community, outlining key principles that developers and technologists believe the industry should embrace to govern consumer data access. We also submitted a technical and policy response of our own, which expanded on the principles outlined in the cover letter and reflects approaches we’ve adopted.

Among our key beliefs:

• Data access must be protected, above all else. Consumers of all financial institutions should have an ability to grant permission to meaningful financial data access in the platform of their choice

• Incentives are aligned across the ecosystem to enable this access in a secure, thoughtful manner. In fact, the technology is readily available to enable the next generation of consumer-permissioned data access for the financial services industry

• Cooperation will be essential to the future of consumer-permissioned data access. That’s why we proactively engage with our financial institution partners and others to implement the technology needed to create even better consumer experiences

We hope that the perspectives we’re privy to can help bridge information gaps, and we look forward to continuing our work to build a more inclusive financial infrastructure for all.