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ICBA submitted a letter in response to the Consumer Financial Protection Bureau’s proposed rule on implementing Section 1033 of the Dodd-Frank Act. ICBA urged the CFPB to expand the exemption for small banks, restrict data sharing to third parties acting in the consumer’s best interest, permit reasonable cost-recovery fees, and strengthen oversight of third-party data recipients. Additionally, ICBA recommended addressing liability for data breaches, maintaining a technology-neutral approach, and providing tiered compliance timelines that will support community banks while promoting consumer protection.