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ABA: The American Bankers Association
Letter to Congress & Regulators

Joint Supplemental Letter to the House Energy & Commerce Committee on the Request for Information regarding Data Privacy

  • From American Bankers Association, Americas Credit Unions, Bank Policy Institute BPI, Consumer Bankers Association CBA, Independent Community Bankers of America ICBA, Mortgage Bankers Association MBA, Securities Industry and Financial Markets Association SIFMA
  • Published August 19, 2025

Joint Financial Trades Supplemental Letter to the House Energy & Commerce Committee on the Request for Information regarding Data Privacy, August 18, 2025

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Chairman Guthrie and Vice Chairman Joyce, we appreciate the opportunity to supplement our April 4, 2025 response to the Committee and the Data Privacy Working Group's Request for Information on the parameters for a federal, comprehensive data privacy and security framework.

Cumulatively, the assembled joint trades (the American Bankers Association, America's Credit Unions, the Bank Policy Institute, the Consumer Bankers Association, the Independent Community Bankers of America, the Mortgage Bankers Association, and the Securities Industry and Financial Markets Association; see Appendix A for additional information) represent members comprising the vast majority of supervised financial institutions. As discussed in our previous letter, the financial services industry was among the first sectors subject to a federal framework governing the collection, use, and sharing of consumer personal information pursuant to the Gramm-Leach-Bliley Act of 1999 (GLBA). Accordingly, supervised financial institutions should not be subject to inconsistent or duplicative requirements primarily addressing other types of entities.

Recognizing this state of affairs, the Data Privacy Working Group asked for specific follow-up items that would be of use in crafting a comprehensive federal privacy law while avoiding unintended consequences for banks (including federally chartered savings & loans/savings banks and independent mortgage banks), credit unions, and investment companies. The first deliverable is preferred language that could be utilized to effectuate an entity-level exemption for those businesses already subject to the requirements of GLBA.

The joint trades reviewed language found in several of the states that have enacted comprehensive data privacy laws. Like the Privacy Working Group, many state legislatures have recognized the merits of carving financial institutions out of scope. While the concept is clear, different state laws present it in slightly different language.

Download the letter to read the full text.

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