The NAI & IAB Comment on CFPB ANPRM
On October 20, 2025, the Network Advertising Initiative (NAI) and the Interactive Advertising Bureau (IAB) submitted joint comments to the Consumer Financial Protection Bureau (CFPB) emphasizing the essential role that responsible, data-driven advertising plays in promoting economic growth and competition. The reasonable use of data allows companies of all sizes, particularly small and medium-sized businesses, to effectively reach audiences, compete with larger firms, and support millions of jobs nationwide.
Our comments respond to the CFPB’s Advance Notice of Proposed Rulemaking under Section 1033 of the Dodd-Frank Act, which grants consumers the right to access their personal financial data. While recognizing the Bureau’s intent to strengthen consumer protections, we are highlighting several unintended challenges associated with implementation, including questions around third-party data access, cost assessments, and potential privacy and security risks. The joint comments focus on two key concerns within the Personal Financial Data Rights (PFDR) Rule: (1) Reauthorization requirements, which may create unnecessary friction for consumers and businesses and (2) Restrictions on consumer consent, which could limit consumers’ ability to authorize trusted third parties to use their data.
Read the full set of comments here:
