Comment on Proposed Regulation

Thank you for taking the time to complete this short survey. Your answers will be compiled and formatted by NAFCU and submitted to the governing agency before the deadline.

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* 1. Please enter your email address.

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* 2. What are the most significant challenges associated with developing dedicated interfaces (e.g., APIs) for the purpose of granting third parties access to covered data?

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* 3. In the absence of any specialized framework for resolving disputes involving misuse of data, how will your credit union protect itself and members from downstream entities that lack appropriate security controls? Is it feasible to review the security information of every authorized third party requesting data access?

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* 4. How will proposed data access rights impact your credit union’s ability to offer competitive and affordable products and services?

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* 5. Do you agree with the CFPB’s approach to granting an exception only to entities that do not offer online banking interfaces? Are there are alternative exemption standards that should apply?

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