#Financial Standards

[mostlysignssomeportents]

Shifting $677m from the banks to the people, every year, forever

I'll be in TUCSON, AZ from November 8-10: I'm the GUEST OF HONOR at the TUSCON SCIENCE FICTION CONVENTION.

"Switching costs" are one of the great underappreciated evils in our world: the more it costs you to change from one product or service to another, the worse the vendor, provider, or service you're using today can treat you without risking your business.

Businesses set out to keep switching costs as high as possible. Literally. Mark Zuckerberg's capos send him memos chortling about how Facebook's new photos feature will punish anyone who leaves for a rival service with the loss of all their family photos – meaning Zuck can torment those users for profit and they'll still stick around so long as the abuse is less bad than the loss of all their cherished memories:

https://www.eff.org/deeplinks/2021/08/facebooks-secret-war-switching-costs

It's often hard to quantify switching costs. We can tell when they're high, say, if your landlord ties your internet service to your lease (splitting the profits with a shitty ISP that overcharges and underdelivers), the switching cost of getting a new internet provider is the cost of moving house. We can tell when they're low, too: you can switch from one podcatcher program to another just by exporting your list of subscriptions from the old one and importing it into the new one:

https://pluralistic.net/2024/10/16/keep-it-really-simple-stupid/#read-receipts-are-you-kidding-me-seriously-fuck-that-noise

But sometimes, economists can get a rough idea of the dollar value of high switching costs. For example, a group of economists working for the Consumer Finance Protection Bureau calculated that the hassle of changing banks is costing Americans at least $677m per year (see page 526):

https://files.consumerfinance.gov/f/documents/cfpb_personal-financial-data-rights-final-rule_2024-10.pdf

The CFPB economists used a very conservative methodology, so the number is likely higher, but let's stick with that figure for now. The switching costs of changing banks – determining which bank has the best deal for you, then transfering over your account histories, cards, payees, and automated bill payments – are costing everyday Americans more than half a billion dollars, every year.

Now, the CFPB wasn't gathering this data just to make you mad. They wanted to do something about all this money – to find a way to lower switching costs, and, in so doing, transfer all that money from bank shareholders and executives to the American public.

And that's just what they did. A newly finalized Personal Financial Data Rights rule will allow you to authorize third parties – other banks, comparison shopping sites, brokers, anyone who offers you a better deal, or help you find one – to request your account data from your bank. Your bank will be required to provide that data.

I loved this rule when they first proposed it:

https://pluralistic.net/2024/06/10/getting-things-done/#deliverism

And I like the final rule even better. They've really nailed this one, even down to the fine-grained details where interop wonks like me get very deep into the weeds. For example, a thorny problem with interop rules like this one is "who gets to decide how the interoperability works?" Where will the data-formats come from? How will we know they're fit for purpose?

This is a super-hard problem. If we put the monopolies whose power we're trying to undermine in charge of this, they can easily cheat by delivering data in uselessly obfuscated formats. For example, when I used California's privacy law to force Mailchimp to provide list of all the mailing lists I've been signed up for without my permission, they sent me thousands of folders containing more than 5,900 spreadsheets listing their internal serial numbers for the lists I'm on, with no way to find out what these lists are called or how to get off of them:

https://pluralistic.net/2024/07/22/degoogled/#kafka-as-a-service

So if we're not going to let the companies decide on data formats, who should be in charge of this? One possibility is to require the use of a standard, but again, which standard? We can ask a standards body to make a new standard, which they're often very good at, but not when the stakes are high like this. Standards bodies are very weak institutions that large companies are very good at capturing:

https://pluralistic.net/2023/04/30/weak-institutions/

Here's how the CFPB solved this: they listed out the characteristics of a good standards body, listed out the data types that the standard would have to encompass, and then told banks that so long as they used a standard from a good standards body that covered all the data-types, they'd be in the clear.

Once the rule is in effect, you'll be able to go to a comparison shopping site and authorize it to go to your bank for your transaction history, and then tell you which bank – out of all the banks in America – will pay you the most for your deposits and charge you the least for your debts. Then, after you open a new account, you can authorize the new bank to go back to your old bank and get all your data: payees, scheduled payments, payment history, all of it. Switching banks will be as easy as switching mobile phone carriers – just a few clicks and a few minutes' work to get your old number working on a phone with a new provider.

This will save Americans at least $677 million, every year. Which is to say, it will cost the banks at least $670 million every year.

Naturally, America's largest banks are suing to block the rule:

https://www.americanbanker.com/news/cfpbs-open-banking-rule-faces-suit-from-bank-policy-institute

Of course, the banks claim that they're only suing to protect you, and the $677m annual transfer from their investors to the public has nothing to do with it. The banks claim to be worried about bank-fraud, which is a real thing that we should be worried about. They say that an interoperability rule could make it easier for scammers to get at your data and even transfer your account to a sleazy fly-by-night operation without your consent. This is also true!

It is obviously true that a bad interop rule would be bad. But it doesn't follow that every interop rule is bad, or that it's impossible to make a good one. The CFPB has made a very good one.

For starters, you can't just authorize anyone to get your data. Eligible third parties have to meet stringent criteria and vetting. These third parties are only allowed to ask for the narrowest slice of your data needed to perform the task you've set for them. They aren't allowed to use that data for anything else, and as soon as they've finished, they must delete your data. You can also revoke their access to your data at any time, for any reason, with one click – none of this "call a customer service rep and wait on hold" nonsense.

What's more, if your bank has any doubts about a request for your data, they are empowered to (temporarily) refuse to provide it, until they confirm with you that everything is on the up-and-up.

I wrote about the lawsuit this week for @eff@mastodon.social's Deeplinks blog:

https://www.eff.org/deeplinks/2024/10/no-matter-what-bank-says-its-your-money-your-data-and-your-choice

In that article, I point out the tedious, obvious ruses of securitywashing and privacywashing, where a company insists that its most abusive, exploitative, invasive conduct can't be challenged because that would expose their customers to security and privacy risks. This is such bullshit.

It's bullshit when printer companies say they can't let you use third party ink – for your own good:

https://arstechnica.com/gadgets/2024/01/hp-ceo-blocking-third-party-ink-from-printers-fights-viruses/

It's bullshit when car companies say they can't let you use third party mechanics – for your own good:

https://pluralistic.net/2020/09/03/rip-david-graeber/#rolling-surveillance-platforms

It's bullshit when Apple says they can't let you use third party app stores – for your own good:

https://www.eff.org/document/letter-bruce-schneier-senate-judiciary-regarding-app-store-security

It's bullshit when Facebook says you can't independently monitor the paid disinformation in your feed – for your own good:

https://pluralistic.net/2021/08/05/comprehensive-sex-ed/#quis-custodiet-ipsos-zuck

And it's bullshit when the banks say you can't change to a bank that charges you less, and pays you more – for your own good.

CFPB boss Rohit Chopra is part of a cohort of Biden enforcers who've hit upon a devastatingly effective tactic for fighting corporate power: they read the law and found out what they're allowed to do, and then did it:

https://pluralistic.net/2023/10/23/getting-stuff-done/#praxis

The CFPB was created in 2010 with the passage of the Consumer Financial Protection Act, which specifically empowers the CFPB to make this kind of data-sharing rule. Back when the CFPA was in Congress, the banks howled about this rule, whining that they were being forced to share their data with their competitors.

But your account data isn't your bank's data. It's your data. And the CFPB is gonna let you have it, and they're gonna save you and your fellow Americans at least $677m/year – forever.

If you'd like an essay-formatted version of this post to read or share, here's a link to it on pluralistic.net, my surveillance-free, ad-free, tracker-free blog:

https://pluralistic.net/2024/11/01/bankshot/#personal-financial-data-rights

[hyacinthsdiamonds]

I'm sorry but the irony of Nico calling Max unprofessional is sending me so bad like sir there's an entire garage full of people, who were literally in the trenches trying to survive the Brocedes fallout while just doing their jobs, who might have a few things to say about your (& Lewis') level of professionalism at that time 😭✋️

[dhaaruni]

WE'RE NOT GOING BACK

[gunstellations]

rough days

[uncanny-tranny]

Your fears that you don't have a body that will transition "well" are, sure, understandable, but there isn't truly such thing as a body that's unworthy of transition. Perhaps your changing body won't suit everybody's taste, but would you rather live for yourself or for the whims of random people who don't care about your happiness as long as they're attracted to what they see?

Transition is for anybody who wants it. It's okay to be fearful. It's okay to be uncertain. But it isn't the end of the world. You are in control, and if you choose to transition to any capacity, it should be at your behest. You and your body are worthy of transition. I hope you are able to seize transition and do what you truly want for yourself.

[brw]

"but hamas is getting funded by extremist islamic hate groups!" do you think the U.S. government and military giving funding for israeli's war efforts against palestinians is a morally neutral and inherently righteous body that had no influence in the politics of southwest asia as a global colonial superpower. do you really think anything you can say about the people resisting oppression can't be said about the oppressors.

[lala-blahblah]

i am learning so much every day, it is a little humbling but also wow, i am continuing to grow and change and become a better person every day. I need to get a diary so that I stop using tumblr but like. slay.

[bonyfish]

A bit ago, dear pal @catwif3 threw some money at me to draw something off my to-draw list featuring our guys, so I picked "superLiCl somehow getting transgressive and homoerotic with the Comic Code Authority emblem". I am quite satisfied with the result! Quotes are from the actual Comics Code of 1954 as preserved by the Comic Book Legal Defense Fund. It was also great to have an excuse to break out the Debaser coloring kit again.

Anyway here's Green Lightning: Defender of Good and his archnemesis Crimson violating General Standards A5, A6, A7, B2, B4, C (Costume) 2, and C (Marriage and sex) 2, 3, 4, 5, and 7.

[cheesuschrist-iii]

OUAW 41 and Stardust Rhapsody 10: ARE YOU READY TO CRY BITCH ARE YOU READY TO SUFFER HAHAHAHAH YOU THOUGHT THESE WERE JUST SILLY DND CAMPAIGNS.

[yrrtyrrtwhenihrrthrrt]

Kinda occurred to me while I was writing fanfics the other day, I feel like money would be an argumentative topic for Blackheart and Ambrosius.

Like yes it's fun to explore all the. You know. Horrible angst they'd probably argue about but they would also be like, a regular adult couple that would argue about regular adult couple things, like money. And like-

Ambrosius grew up homeless in abject poverty, Ballister (if we're going off his Lord title) likely grew up with wealth, but his father's reckless spending and gambling caused their family to lose everything. In their young adult lives Ambrosius was a celebrity who probably had tons of disposable income, while Ballister lived pretty modestly and any ill-begotten funds he got his hands on went to his research.

So I can see a situation where like, Ballister obviously wants to save money and not spend on frivolous things in part due to practicality and in part due to childhood trauma, and he has a partner who is used to spending as much as he pleased without consequence, and who is reacting against his own childhood trauma of lacking comfort and nice things.

I imagine it wouldn't be terribly uncommon for Ballister to become frustrated when he feels like Ambrosius is being too cavalier with their money (and probably triggering a latent fear of losing what they have), and Ambrosius feeling misunderstood and deprived by Ballister not wanting him to spend money (and probably also triggering a latent fear of not having any control over his standard of living)

I think they'd reach a compromise about it eventually but it's interesting to think about

[lucky-draws]

i am never free from ocie..........

[skrunksthatwunk]

how do i tell my roommate that her cat repeatedly pissing on and destroying my things is something that people usually offer to clean or replace or apologize for instead of shrugging off

[fire-on-fuel]

I think if you watch clone wars it's easy to forget that the prequel trilogy itself doesn't commit to treating the clones as people. Always "I'll take some clones with me" "I'm taking enough clones with me". Not their battalion or platoon numbers, even. Because that's not relevant. The jedi aren't outwardly rude or dehumanizing, but they make no effort to refer to the clones as anything but uncomfortably unethical and comfortably useful resources. Even after order 66 Obi-wan kenobi says, with a resigned kind of dissapointment "my clones have turned against me". As the audience you (correctly) develop the idea that the existence of the clones- and the acceptance and use of them with little opposition by the republic and the jedi- is key to the tragedy of their fall. And I'm not mad at the clone wars for fleshing out the war or humanizing the clones more but I do think it encourages a weird kind of subtle childish optimism by giving people a false hope of what if-? That the republic as it exists in the clone wars isn't already rotted through, that if everyone just figured everything out Better it would all be okay. But the point is that these millions of people raised for the purpose of war shouldn't exist to begin with. The point is that everyone around them is complicit- the characters you like and identify with and see as good. The point of the prequels is that normal is not dependable because normal can and will be evil, and without actively choosing otherwise you'll find yourself in it. You can dislike it you can be upset about it but aside from maybe a couple characters and blurry sections from holes in the writing, those characters would and did let that slide, at minimum. It's a precendent that makes sense in the context of tragedy and while yes it's hard to write around its strange to me that so much fan content is scared of it to the point that watching the original movies is a stark contrast.

[meangan-thee-lesbian]

I just had to share this email I got so all y'all can appreciate the absolute state of welfare services in Australia with me:

The NILs Loan Scheme is a government funded, no interest loan scheme for people on low incomes, but this leaves me wondering exactly who tf can qualify for their loans. Because it seems like if you have any symptoms of poverty it's a no.

I applied because I need the clutch replaced in my van, which I live in. It's lucky that I actually CAN afford the cost myself (due to living in a van & not participating in Australia's increasingly ridiculous housing market). I thankfully can afford such an expense these days & was just looking for a responsible financial buffer, just in case. But if this had happened to me a few years ago when I first became homeless and was far less financially stable, then my next living situation wouldn't be "affordable housing" it would be a fucking tent.

Anyway, the backwards ass state of a GOVERNMENT FUNDED welfare scheme refusing to assist those who need welfare the most because they don't want to encourage homelessness or whatever the dumb fuck? Just really rustled my jimmies tbh. Just screams "yet another govt welfare scheme that's actually just about handing out money to fake charities & not helping the poor". Good Shephard just got on the "do not donate to these grifters" list along with the Salvos😒

[elbdot]

When the YouTube videos of the Alolan comic catch up to date will the comics come out faster and the videos be put on hold until more chapters come out?

I don't really know where you got this idea from but we're not currently producing any more dubs of the comics :'D We finished our first season and there's NO plans to dub the rest of the webcomic, these videos took me OVER A YEAR to complete 😭 And the comics are coming out as fast as they can RIGHT NOW, I've been updating weekly for a month now and I unfortunately won't be able to keep up that speed for much longer I'm not a content-machine, I don't have a team of artists nor lightning speed as some of the Webtoon-artists do, I'm just one person who has to work on commissions and other projects at the same time as well 😭

I'm sorry that I can't keep up the pace and update this comic as regularly as other comic artists can update theirs, but I'm trying my very best here every day, I PROMISE 😭

[syvanna]

jesus fucking christ like I want to be able to go back to school so I can make more than $23 per hour and my mom already thinks we're going to buy a different house together when my uncle passes