March 15, 2019
Chairman Mike Crapo & Ranking Member Sherrod Brown
Members of the United States Senate Committee on Banking, Housing and Urban Affairs
534 Dirksen Senate Office Building
Washington, D.C. 20510
RE: Improving Data Privacy, Protection and Collection Practices in Financial Data
Dear Chairman Crapo and Ranking Member Brown:
The Center for Democracy & Technology (CDT) is a non-profit, non-partisan technology advocacy organization based in Washington, D.C., that works to promote democratic values by shaping technology policy and architecture, with a focus on the rights of the individual. CDT supports laws, corporate policies, and technological tools that protect privacy and security online. We write today to offer several ideas for where the Committee might explore how current legal and regulatory tools are advancing financial data privacy and access.
The Committee has asked several questions as to what should be done through legislation, regulation, or implementation of best practices that would improve disclosures made to consumers (Question 2) and their subsequent control over the use of financial data (Question 3). Separately, it asks what should be done about data brokers (Question 5). Our comments address these three key issues.