NAI Submits Comments to CFPB on Financial Advertising

On December 29, 2023 the NAI submitted comments on the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) Notice of Proposed Rulemaking (“NPRM”) and the Proposed Rule on Personal Financial Data Rights (“Proposed Rule”) under section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. In summary, the NAI opposes the inclusion of targeted advertising in activities not reasonably necessary for consumer needs, suggesting that consumer consent is needed for such practices, rather than a blanket prohibition.