A new generation of fintech providers is offering products that allow customers to access and aggregate information about accounts at other financial institutions that have no relationship with the fintech provider, raising new questions around the privacy, security and accuracy of consumer financial data, as well as concerns around improper payment authorization and consumer dispute mechanisms. On October 18, 2017, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released guidance that is intended to provide the Bureau’s “vision for realizing a robust, safe, and workable data aggregation market that gives consumers protection, usefulness, and value.” This Legal Update provides background on the issues the guidance addresses, details on the guidance and observations one what it may mean for consumers, fintech companies and the financial services industry as a whole.

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