CUNA expressed multiple concerns with Consumer Financial Protection Bureau data collection policies in a recent letter sent in response to a request for information from the bureau on the efficiency and effectiveness of its data collection processes.

“Although the bureau’s authority to collect certain data is clear, CUNA still has concerns regarding the bureau’s data collection, retention, and dissemination policies as well as the resulting obligations and burdens that may fall on credit unions and others involved in data exchange and management efforts,” the letter reads.

The letter went on to outline four main recommendations regarding the collection and use of data.

  • The bureau should only conduct data collections when necessary and ensure those collections are narrow in scope.
  • The bureau needs to maintain robust security procedures for the handing of sensitive consumer financial information and regularly update those procedures.
  • In order to avoid duplication and redundancy, the bureau should first look to the data already being collected by other federal and state regulators prior to engaging in any new potentially-burdensome data collections.
  • The bureau should keep in mind credit unions’ unique place in the market and distinct characteristics when evaluating data related to the entire consumer financial service sector.