Iain Melchizedek

For seventeen years, I worked inside military and government systems. I helped build them, operate them, and maintain them. I believed I was contributing to order, protection, and stability. I was wrong about part of that, not because the intent was malicious, but because the foundations were flawed. This is not an exposé. It is a reflection. It is what happens when lived experience meets honest self-examination. Most public-sector systems in use today were not built recently at all. They are...

The CFPB’s reconsideration of the Personal Financial Data Rights Rule raises several questions about how Section 1033 of the Dodd-Frank...

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...