MX’s comments on the CFPB’s proposed rule for personal financial data rights stress the need for broader scope, clearer obligations, and support for innovation. They argue limiting coverage to Regulation E and Z entities excludes key data like loans and investments, which could stifle competition. MX recommends expanding definitions, allowing pro-consumer secondary data uses, and ensuring beneficial data remains available. They also call for clarity on consent, liability, TANs, and non-discriminatory access. With compliance expected to roll out from late 2024 to 2028, MX urges institutions to start budgeting, auditing data flows, and preparing partnerships now.

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