00035-129640.Pdf (4
"'.., Clearing ~"'"~ The House ~ At the Center of Banking Since 1853 ~ November 21, 2016 Via Electronic Submission David Lincicum and Katherine McCanon Division of Privacy and Identity Protection Bureau of Consumer Protection Federal Trade Commission 600 Pennsylvania Avenue, N.W., Suite CC-5610 (Annex B) Washington, DC 20580 Re: Safeguards Rule, 16 CFR 314, Project No. P14507 (Standards for Safeguarding Customer Information; RIN 3084-AB35) Dear Mr. Lincicum and Ms. McCarron: The Clearing House Association L.L.C. 1 appreciates the oppmtunity to comment on the Federal Trade Commission's September 7, 2016 request for public comment entitled "Standards for Safeguarding Customer Information," regarding the regulations codified at 16 C.F.R. Part 314.2 As explained further below, the financial technology ("Fintech") industry has evolved rapidly in recent years, with many of these companies now offering to consumers payment and other services traditionally associated with banks. Many Fintech companies now handle large amounts of sensitive personal financial information, and yet they remain subject only to the high level, general security standards in the FTC's Safeguards Rule. FTC Commissioner Tenell McSweeny rightfully noted during her opening remarks at the FTC's recent Fintech series event on Crowdfunding and Peer-to-Peer payments that, in light of the recent growth of Fintech, it is important to ask how Fintech platforms ensure that fund The Clearing House is a banking association and payments company that is owned by the largest commercial banks and dates back to 1853. The Clearing House Association L.L.C is a nonpmtisan organization that engages in research, analysis, advocacy and litigation focused on financial regulation that supports a safe, sound and competitive banking system.
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