Read DCA CEO’s Comment Letter to Consumer Financial Protections Bureau

Executive Summary

DCA is the premier, multi-industry trade association focused on promoting online-to-offline commerce and card-linking worldwide. DCA possesses broad expertise in the area of online commerce and consumer financial information. DCA’s membership includes leading banks, merchants, payment networks and technology companies.1 As a result, DCA’s voice is distinct from other associations in that it is one that reflects a diverse set of perspectives from multiple industries. Further, DCA’s established presence in the data access ecosystem uniquely positions it as both a subject matter expert and industry leader. Our members play a pivotal role in the world of digital commerce. Before the issuance of the Section 1033 ANPR, DCA’s members have led the way on important initiatives that are designed to protect consumers while also eliminating friction for digital commerce. Such initiatives include establishment of the DCA Consumer Data Transparency Rights.

The ever-evolving data landscape warrants an advanced yet nimble standards body that can swiftly react to technological developments with consumer protection implications. DCA’s multi-industry membership, consisting of the world’s most sophisticated technology providers, publishers, payment processors, payment networks, and retailers creates an inherent system of checks and balances, resulting in standards that are beneficial to all. Sound principles that should be considered include the DCA Consumer Data Transparency Rights. Below, we discuss our Transparency Rights, and how the Bureau can enhance the benefits that consumers receive from accessing financial records.