The Innovative Payments Association (IPA) has submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to its Advanced Notice of Proposed Rulemaking (ANPR) on Personal Financial Data Rights under Section 1033 of the Dodd-Frank Act.

The CFPB’s ANPR, published August 22, 2025, reopens several elements of the agency’s 2024 final rule, including how to define a “representative,” how to manage costs associated with data sharing, and how to address privacy and security concerns. The IPA’s letter, filed October 10, 2025, provides feedback on each of these areas on behalf of its members, who represent the broad electronic payments industry—from prepaid products to mobile wallets and person-to-person payment technologies.

Clear Consent and Consumer Control

IPA supports the idea that consumers should control access to their financial data and that any third-party representative should obtain clear, informed consent. The letter recommends that consent be explicit and affirmative—an “opt-in,” not hidden in lengthy terms and conditions.

However, the association cautions that limiting representatives only to those with fiduciary duties could slow innovation and reduce consumer choice. IPA encourages the CFPB to maintain flexibility that allows new types of financial technology providers to participate responsibly in open banking.

Cost, Security, and Privacy Considerations

The IPA urges the CFPB to engage directly with stakeholders to develop a fair framework for sharing the costs of data access. It points to the recent Plaid–JPMorgan Chase agreement as an example of how private-sector collaboration can advance responsible data-sharing practices. The association supports allowing reasonable fees to help data providers maintain secure systems.

IPA also recommends creating a safe harbor from liability for financial institutions and data providers that comply in good faith. This would help mitigate risks related to fraud or unauthorized access to sensitive data.

Regarding privacy, the IPA notes that some federal requirements may overlap or even conflict with state laws, such as the California Consumer Privacy Act. It encourages the CFPB to provide clear guidance to help providers navigate these evolving frameworks.

Collaboration and Implementation

Finally, the IPA recommends that the CFPB engage industry representatives through joint discussions rather than litigation and allow additional time, up to two years after technical standards are finalized, for implementation of any new rule.

IPA appreciates the CFPB’s willingness to revisit these important issues and remains committed to supporting policies that foster innovation, protect consumers, and strengthen confidence in the payments system

For additional information, download the comment letter.

The Innovative Payments Association (IPA) submitted a formal comment in response to the June 20, 2025, Request for Information (RFI) from the prudential banking regulators (the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board) regarding potential actions to address payments fraud, with a focus on paper checks.

Our Point of View

• Prioritize collaboration and education over new rules. Financial institutions already operate under a robust framework governing check processing and fraud resolution. We believe the most effective next steps are stronger public-private collaboration, improved data sharing, and expanded consumer and business education about the risks of check fraud.
• Convene stakeholders to accelerate solutions. We encourage the prudential regulators to host joint meetings with industry participants to coordinate practical anti-fraud measures, citing existing models of public-private cooperation that can be adapted to the check-fraud context. Targeted law-enforcement task forces focused on check fraud could further deter criminal activity.
• Support the transition to safer electronic payments. The most durable way to reduce check fraud is to continue shifting away from paper checks to secure, fully regulated electronic options, including direct deposit to DDAs, mobile wallets, prepaid accounts, and other digital rails governed by Regulation E. This transition is already underway as check usage declines and electronic methods grow.
• Advance inclusion and program efficiency. Electronic disbursements are central to how many public programs deliver benefits today, providing recipients with faster, safer access to funds and an on-ramp to broader financial services. Continued modernization will enhance outcomes for both consumers and administrators.
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We appreciate the agencies' focus on mitigating fraud while supporting an inclusive and efficient payments ecosystem. For details, you can read our filed comment letter.
If members have questions about the filing, please contact Brian Tate at [email protected].

The Innovative Payments Association (IPA) responded to Treasury’s RFI on Executive Order 14247, which calls for the transition from paper checks to digital disbursements for all federal payments. IPA’s letter champions the role of prepaid accounts in this effort.

“Prepaid accounts are a proven, secure, and efficient way to disburse government benefits—especially for unbanked Americans,” said Brian Tate, IPA President and CEO. “Modernizing payments must prioritize access, cost savings, and fraud prevention.”
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The comment letter outlines the extensive regulatory oversight already in place and makes recommendations for simplifying outdated rules that limit consumer access to credit and increase compliance burdens for providers. IPA also cautions against the FCC’s “Revoke All” rule, which could disrupt fraud alerts and financial communications.

In response to the OCC’s request for information on community bank digitalization, the Innovative Payments Association (IPA) submitted a letter underscoring the positive role of bank-fintech partnerships in expanding access to modern financial tools.

“Fintech partnerships are delivering responsible innovation to underserved communities and enhancing stability for community banks,” said IPA President and CEO Brian Tate. “These partnerships already operate under an existing, robust regulatory framework.”
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The letter urges the OCC to avoid duplicative regulations that could stifle innovation. IPA highlighted how bank-fintech products like prepaid accounts, earned wage access, and small-dollar loans empower consumers—especially those who might otherwise turn to high-cost alternatives like payday lenders.

​The Innovative Payments Association (IPA) submitted a comment letter to the U.S. Treasury in response to the Presidential Memorandum investigating potential unlawful foreign contributions in U.S. elections. While the memo raised concerns about the use of prepaid products for “straw donor” schemes, the IPA urged Treasury and the DOJ to rely on the existing, rigorous anti-fraud and compliance frameworks already governing these products.

“Prepaid accounts are highly regulated and provide full transaction traceability,” said IPA President and CEO Brian Tate. “They are not a loophole but a lifeline for millions of Americans managing their financial lives.”
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IPA emphasized that prepaid accounts comply with Bank Secrecy Act (BSA/AML) requirements and support financial inclusion, especially for unbanked and underbanked communities. Rather than overcorrecting, the letter calls for informed policy rooted in the realities of how these products work.