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Iain Melchizedek
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Join date: May 7, 2023
Posts (10)
Aug 28, 2025 ∙ 4 min
CFPB’s PFDR Rule Reconsideration – Questions 2; 3; 4; 5; 6; and 7.
The CFPB’s reconsideration of the Personal Financial Data Rights Rule raises several questions about how Section 1033 of the Dodd-Frank...
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Aug 26, 2025 ∙ 3 min
CFPB’s PFDR Rule Reconsideration – Questions 18 & 28 Response
In August 2025, the Consumer Financial Protection Bureau (CFPB) reopened its Personal Financial Data Rights Rule (PFDR Rule) under Docket No. CFPB-2025-0037. Safe Passage Strategies, LLC submitted this response to Questions 18 and 28, which concern information security and the costs and benefits of restricting screen scraping. I. No Empirical Basis for Prohibition The Bureau prohibited credential-based screen scraping on the ground it is “inherently less secure” than API access. Yet the...
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Aug 26, 2025 ∙ 4 min
CFPB’s PFDR Rule Reconsideration - Question 1 Response
In August 2025, the Consumer Financial Protection Bureau (CFPB) reopened its Personal Financial Data Rights Rule (PFDR Rule) for...
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