Keypoint: As leadership at the CFPB shifts, responses to the CFPB’s Notice of Proposed Rulemaking to implement Section 1033 of the Dodd Frank Act looms.

More than a decade ago, the Dodd Frank Act created the Consumer Financial Protection Bureau (CFPB) and gave it authority to promulgate rules implementing Section 1033 of the Act. Under Section 1033, upon request, a financial services provider “shall make available to a consumer information in its control or possession concerning the product or service that the consumer has obtained, including information relating to any transaction, series of transactions, or to the account including costs, charges and usage data. The information shall be made available in an electronic form usable by consumers.”