comment letter

Joint Trades Submit Letter ahead of House Markup of Privacy Legislation


Dear Chairman Bilirakis and Ranking Member Schakowsky:

The primary privacy and data security consumer protection law for financial institutions is Title V of the Gramm-Leach Bliley Act (GLBA). We support legislation to put in place a national privacy standard, but that standard must recognize the strong privacy and data security standards that are already in place for the financial sector under the GLBA and other financial privacy laws (e.g., the Fair Credit Reporting Act and Right to Financial Privacy Act) and avoid provisions that duplicate or are inconsistent with those laws.

As currently framed, Title I of the American Privacy Rights Act of 2024 (APRA) does not include clear language for financial institutions to understand their exemption from the requirements of the bill. Section 120(b)(3) only excludes data subject to the GLBA, as opposed to exempting financial institutions subject to the GLBA.

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