Overview

The Financial Information Network

While dataflows are an indispensable component of the “Information Economy,” they are widely misunderstood. For many policymakers, nebulous notions of “privacy” shape the decision-making process, rather than a measured understanding of the uses and limits on the sharing of consumer data. Consumer benefits are taken for granted. At both the state and federal level, even so-called “thought-leaders” misunderstand the rules governing flows of consumer information.

This is unfortunate but understandable. Dataflows are complex. And institutional memories are often short. Even industry tends to lack a macro-level picture of dataflows. Understanding is often limited to their firm-specific compliance concerns and business needs.

In response, the Information Policy Institute has initiated development of the Finanical Information Network (FIN), an interactive educational tool on dataflows. This user-friendly software program generates a three-dimensional map that explains specific types of data exchanges between industry segments. Comprehensive “plain english” descriptions summarize depicted segments, the dataflows between those segments, and explain the federal rules that govern those dataflows. Moreover, users are given the opportunity to build maps that are as simple or as complicated as they want, depending on their level of understanding or their particular interest.

About Version 1.0

The first iteration of our tool is:

1. A view from “30,000 feet” of dataflows among credit bureaus, lenders, and other users of consumer reports and consumer data
2. A primer on Gramm-Leach-Bliley and Fair Credit Report Act obligations, with the ability to “drill-down” to the actual text of the law.

Version 1.0 also includes:

1. An explanation of the uses of consumer reports, including non-financial purposes such as law enforcement
2. Explanations of seven different types of dataflows including: data furnishers; credit reports; public information, and affiliate sharing
3. Catalogs of 12 of the most germane segments, including Credit Bureaus, Financial Holding Companies, Commercial Banks, Information Service Providers, Retailers, and Government Agencies
4. Careful attention to the uses and restrictions of “third-party” data
5. Careful attention to controversial provisions such as “joint-marketing” arrangements and “affiliate sharing” with an emphasis on consumer benefits.

Accuracy and Political Sensitivity

The content of Version 1.0 has been extensively vetted by industry experts from all depicted industry segments. These experts include: Rick Fischer, author of The Law of Financial Privacy; Jennifer Barrett of the Axciom Corporation, Stuart Pratt of the Consumer Data Industry Association, and Marty Abrams of the Center for Information Policy Leadership.