Our discussion looks at the CFPB’s rulemaking activities before issuing its Advance Notice of Proposed Rulemaking (ANPR), the ANPR’s focus points, and differences from the California Consumer Privacy Act. Other topics include the role of data aggregators and how banks are responding to them, technical and other issues arising from third party access to consumer data, and the application of the FCRA and other federal consumer financial protection laws to data aggregators.