Economic Security: How Should We Take Charge of Our Future?

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For many banks, their core provider is the heart of their IT infrastructure. Without the support of these core providers, it would be impossible for community banks to offer the API access or permissioning systems that the market demands today. ABA has engaged with the core providers through its banker driven Core Platforms Committee, made up of community and mid-sized banks, in an effort to strengthen relationships between banks and cores.


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One of the key priorities that this committee has identified is data access. Community banks often struggle to quickly and easily access the data held in their core platforms, much less facilitate access for third parties. For community banks to remain competitive, it is critical that the core providers engage in industry efforts and adopt technologies that facilitate the secure data sharing that customers demand. To ensure consumer financial information is properly secured, it is subject to laws related to privacy, data protection, and restrictions on data use and accessibility.

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For example, the Gramm-Leach-Bliley Act of GLBA imposes on financial institutions obligations to respect customer privacy and to safeguard financial information. Consumers should expect that their financial data is protected whether it is held by a bank or a data aggregator. This assures that data protections apply consistently regardless of where the data originated, where it is transferred, and the type of company is using or storing the data.

In other words, GLBA clearly applies to data aggregators. While we believe it is clear that GLBA applies to data aggregators, any confusion in the market could stifle the progress toward moving to more secure methods of data sharing.


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By the nature of their business, data aggregators hold a tremendous amount of consumer financial data. It is estimated that data aggregators hold the consumer login credentials for tens of millions of customers. In most cases consumers do not have a direct relationship with these companies and must trust that their data is being handled appropriately.

As discussed in above, ABA believes that data aggregators are subject to GLBA, but their compliance with its privacy and security obligations is not clear and, more important, is not subject to supervision or regular examination. Proactive supervision is critical to identifying risks before any harm is done to consumers.

ABA believes that establishing accountability across all providers of comparable financial products and services is a fundamental mission of the Bureau. This is especially important for data aggregators, given the sensitive consumer financial information they store and process.

The bulk of the data processing in this area is managed by a select group of large companies. Once the Bureau has imposed supervisory authority over the larger data aggregators, the CFPB can better monitor — and react to — risks to consumers in this rapidly evolving marketplace. As service providers, they are liable for unauthorized transactions under Regulation E as well as certain other provisions.

Imposing liability for unauthorized transactions under these circumstances is appropriate and fair.

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The data aggregator is in the best position to control the risk of unauthorized transactions conducted through its system. This approach is consistent with payment system laws which generally assign liability to the party that is in the best position to avoid a loss and manage the risk of a loss. Indeed, it is for these reasons that Regulation E assigns liability to service providers.

Moreover, other provisions related to service provider responsibilities support classifying data aggregators as service providers under Regulation E. These include requirements related to error resolution, disclosures, the prohibition against the issuance of unsolicited access devices, and change in terms notices. ABA believes that data aggregators providing electronic fund transfer services are service providers under Regulation E.

To avoid any ambiguity, Congress shold urge the Bureau to confirm this in the regulation or official commentary. Notably, data aggregators are authorized by and act on behalf of bank customers, not the bank. Section 7 of the Bank Service Company Act BSCA requires banks to notify their regulators of contracts or relationships with certain third-party service providers and undertake due diligence on these partners. This is intended to capture relationships where banks partner with third parties to deliver experiences to their customer.

In the case of data aggregators, there is no such partnership. Such a contract should not result in the data aggregator becoming a third-party service provider to the bank. Rather, the relationship should be regarded as a customer-aggregator relationship.

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A lack of clarity about the applicability of the BSCA to contracts with data aggregators could stifle adoption of more secure technologies that provide additional protections for customers. Learn more about our updates. Give Us Feedback. Create your own user feedback survey. For Investors Personal Finance. Determining Your Credit Score So, how do credit bureaus determine your credit score?

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This component encompasses your payments on credit cards, retail accounts, installment loans such as automobile or student loans , finance company accounts and mortgages. Public records and reports detailing such items as bankruptcies, foreclosures, suits, liens, judgments and wage attachments also are considered. A history of prompt payments of at least the minimum amount due helps your score. Late or missed payments hurt your score. Amounts Owed or Credit Utilization reveals how deeply in debt you are and contributes to determining if you can handle what you owe.

If you have high outstanding balances or are nearly "maxed out" on your credit cards, your credit score will be negatively affected. Paying down an installment loan is looked upon with favor. Length of Credit History refers to how long you have had and used credit. The longer your history of responsible credit management, the better your score will be because lenders have a better opportunity to see your repayment pattern.

If you have paid on time, every time, then you will look particularly good in this area. These critics assume that alliance formation proceeds in strict accordance with realist logic and that regime type plays no role. Democracies, however, may have found themselves allied to one another against nondemocracies because they share a commitment to democratic values and want to defend them against threats from nondemocracies. Indeed, if the democratic peace proposition is only partially valid and if it is at least dimly understood by decisionmakers, democracies will find other democracies less threatening than nondemocracies and therefore will tend to align with them against nondemocracies.

This argument is consistent with Stephen Walt's balance-of-threat theory, which identifies offensive intentions as element of threat. Second, the tendency of democracies to ally with one another is further evidence of the special characteristics of democratic foreign policy. Instead of being a refutation of the democratic peace, the tendency of democracies to ally with one another is actually an additional piece of confirming evidence.

Third, Maoz does an interesting test, examining whether states were allied before they became democracies or allied only after they became democracies. He finds that "Non-aligned democracies are considerably less likely to fight each other than aligned non-democracies. The Argument: Some critics of the democratic peace proposition claim that democracies have not fought one another because they have not had the opportunity.

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Until recently, there were relatively few democracies in the international system. Many were geographically remote from each other.

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Response: The most sophisticated statistical analyses of the evidence for the democratic peace take these variables into account and still conclude that there is a strong relationship between democracy and peace. The Argument: Skeptics suggest that, if the democratic peace proposition is valid, we should find that pairs of democracies behave in crises in way that reveals that shared democracy, not considerations of power and interest, caused them to avoid war. For example, tracing the process of how events unfolded should reveal that the publics in democracies did not want war with other democracies, that leaders did not make military threats against other democracies, and that democracies adopted accommodating behavior toward other democracies.

Response: Proponents of the democratic-peace proposition do not deny that considerations of power and interest often motivate states. Thus evidence that democracies are sensitive to power and interest does not refute the democratic-peace proposition. In addition, critics of the democratic-peace proposition have not tested it fairly; they have not deduced the full range of predictions that the normative and institutional model makes about how democracies will avoid war. More comprehensive tests would also deduce and test hypotheses about how many political and diplomatic aspects of crises between democratic states differ from other crises.

Such tests would also compare pairs of democratic states to mixed and nondemocratic pairs. John Owen has conducted such tests and finds considerable evidence to support the democratic-peace proposition. The Argument: One of the most important arguments against U. Edward Mansfield and Jack Snyder make this argument and support it with statistical evidence that shows a correlation between democratization and war.

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