Overview
Title
Privacy Act of 1974; System of Records
Agencies
ELI5 AI
The Consumer Financial Protection Bureau wants to make their record-keeping simpler by combining two record systems into one. They are inviting people to share their thoughts about this change before it happens in February 2025.
Summary AI
The Consumer Financial Protection Bureau (CFPB) plans to eliminate the "CFPB.003 Non-Depository Institution Supervision Database" system of records. This system's records have been incorporated into the modified "CFPB.002 Supervision and Examination Records" to create a single system for supervisory information. The change aligns with the Privacy Act of 1974 and Office of Management and Budget guidelines, streamlining records management. Public comments on this proposal are accepted until February 3, 2025, with the rescindment set to take effect on February 12, 2025, barring any contrary comments.
Abstract
Pursuant to the Privacy Act of 1974, and Office of Management and Budget (OMB) Circular No. A-108, the Consumer Financial Protection Bureau (CFPB) proposes to rescind existing system of records "CFPB.003 Non-Depository Institution Supervision Database." Records maintained under this system of records have been consolidated into the modified "CFPB.002 Supervision and Examination Records."
Keywords AI
Sources
AnalysisAI
The Consumer Financial Protection Bureau (CFPB) has announced its plan to eliminate the "CFPB.003 Non-Depository Institution Supervision Database." Records from this database are now consolidated into an updated system called "CFPB.002 Supervision and Examination Records." This consolidation is meant to streamline record-keeping processes in accordance with the Privacy Act of 1974 and guidelines from the Office of Management and Budget. The public is invited to comment on this proposed change until February 3, 2025, with the final decision taking effect on February 12, 2025, assuming no major objections arise.
Significant Issues or Concerns
The document raises a few notable issues:
Transparency and Justification: While the proposal states that the change will help streamline management, it provides little detail on why consolidation is necessary beyond administrative efficiency. Explanations about specific benefits or outcomes could enhance transparency and understanding.
Data Privacy and Security: The proposal does not address how consolidating the records affects data privacy or security for individuals whose data is in the system. This could be a significant concern for stakeholders worried about their personal information.
Familiarity with Terms: The document uses specific terms and acronyms like SORN (System of Records Notice) and CFPB without explaining them. Readers unfamiliar with these terms might find it challenging to fully grasp the document's implications.
Preference for Electronic Comments: While the CFPB encourages electronic submission of comments over physical mail, it does not explain why this preference exists. A brief clarification could help the public understand logistical or efficiency-related reasons behind this choice.
Justification for Efficiency: There is limited explanation regarding how the consolidation will make the system more efficient compared to maintaining separate records for different types of institutions. Additional insights into these management improvements could help justify the change.
Impact on the Public
The consolidation of record systems may indirectly impact the public by potentially improving the efficiency and effectiveness of the CFPB's supervisory role. If the integrated system leads to better oversight of financial entities, it could enhance consumer protection in the financial sector. However, if not managed carefully, it might also raise privacy or security concerns that could affect individuals whose data is part of this system.
Impact on Stakeholders
Potential Positive Impacts:
Financial institutions and their affiliates that fall under CFPB's supervision might benefit from the streamlined system. The consolidated records could lead to more coherent and consistent regulatory oversight, reducing administrative burdens related to separate systems.
Potential Negative Impacts:
Individuals concerned about privacy might view the consolidation skeptically, especially without clear assurances on data safeguards. Similarly, stakeholders with a vested interest in maintaining distinct supervisory systems may perceive the change as an unwanted consolidation of power or oversight.
In conclusion, the CFPB's proposal to consolidate record systems aims to improve its regulatory framework, though it brings forth several considerations that merit further discussion and analysis. Public feedback during the comment period will play a crucial role in shaping the final decision and addressing outstanding concerns.
Issues
• The document does not provide a detailed explanation of why the consolidation of records is necessary beyond promoting 'streamlining and management.' Additional context or justification could be beneficial for transparency.
• The document does not specify how the consolidation of records will affect data privacy or security. It may be important to address these potential concerns for those whose data is part of the system.
• The document assumes familiarity with specific terms and acronyms (e.g., SORN, CFPB), which might not be clear to all readers. Including a glossary or brief explanation could aid understanding.
• The method of submitting comments through physical mail is discouraged, but no explanation is provided for why electronic submissions are strongly preferred. Clarifying this could be helpful.
• There is a lack of detailed information about how the consolidation into CFPB.002 will specifically improve management and efficiency over maintaining separate systems. Additional information could be provided to justify the change.