Overview

• An Advance Notice of Proposed Rulemaking published August 21–22 invites public comments through October 21 on targeted revisions to the Section 1033 framework.
• The CFPB asks who should qualify as a consumer’s authorized “representative,” including whether the role should be limited to fiduciaries or include broader third parties.
• The Bureau is reconsidering its ban on data‑access fees and is seeking input on potential cost‑recovery approaches, including whether caps on charges are appropriate.
• The notice requests evidence on whether current information security safeguards are sufficient and what it costs institutions of different sizes to build secure data‑sharing systems.
• The CFPB is also evaluating the adequacy of privacy protections, including informed consent and the prevalence of licensing or selling consumer data, and it plans a separate proposal to extend existing compliance dates while the original rule remains stayed.