Databrokers Pose Growing Financial Risks to Consumers, Including on Streaming TV

Leading data brokers play a powerful behind-the-scenes role leveraging their data holdings across the “omnichannel” marketplace. Data brokers are currently in the forefront of providing digital “dossiers” that identify and target U.S. financial consumers, especially through “identity graph” services that enable personalized tracking and microtargeting. This is especially true with the now-dominant digital video streaming system (connected, or CTV) that touches nearly every American household, including those with children. CTV devices and streaming video networks are increasingly AI-driven data processors of consumer financial transactions, offering cross-device monitoring and interactive responses to the behavior of individual consumers. Data brokers are thoroughly embedded in the multiple operating layers of CTV, posing new and greater risks to consumers and their financial applications. The practices we describe are currently pervasive, non-transparent, unaccountable, and harmful—and clearly requiring the updates to the FCRA as proposed by the rule.

The Trump Administration’s willful destruction of the CFPB raises questions as to whether consumer financial protection is still a core mission of the agency—and whether it is even possible given the mass firings and abrupt terminations of policies and staff. If the Trump CFPB decides not to enact the rule, it will place the majority of the American public at a new and higher level of financial risk, especially every time they go online or watch programming.

Read CDD's full comments in the CFPB Docket "Protecting Americans from Harmful Data Broker Practices (Regulation V)" in the attachment.