16 CFR Part 314, Standards for Safeguarding Customer Information, Project No. P145407 #00024

Submission Number:
Scott Talbott
Electronic Transactions Association
District of Columbia
Initiative Name:
16 CFR Part 314, Standards for Safeguarding Customer Information, Project No. P145407
November 7, 2016 Via electronic submission to https://ftcpublic.commentworks.com/ftc/safeguardsrulenprm Donald S. Clark Federal Trade Commission Office of the Secretary 600 Pennsylvania Avenue NW Suite CC--5610 (Annex B) Washington, DC 20580 Re: Safeguards Rule, 16 CFR 314, Matter No. P145407 Dear Secretary Clark: The Electronic Transactions Association ("ETA") appreciates this opportunity to provide comments regarding the Federal Trade Commission's ("FTC" or "Commission") Request for Public Comment on its Standards for Safeguarding Customer Information ("Safeguards Rule" or "Rule"). ETA supports maintaining the Safeguards Rule as it currently stands, and recommends the FTC not change any definitions. ETA is the leading trade association for the payments industry, representing nearly 550 companies worldwide involved in electronic transaction processing products and services. The purpose of ETA is to influence, monitor, and shape the payments industry by providing leadership through education, advocacy, and the exchange of information. ETA's membership spans the breadth of the payments industry, and includes financial institutions, payment processors, independent sales organizations, and equipment suppliers. ETA's members use data to provide a wide range of products and services designed to enhance and secure electronic transfers. Our members rely on data to help reduce fraud and to authenticate transactions to make transactions between businesses and consumers seamless and secure. The Commission's review seeks information about the costs and benefits of the Safeguards Rule and its regulatory and economic impact for the purpose of assisting the Commission in identifying elements that may warrant modification or rescission. More specifically, the Commission has solicited comments on what modifications to the Rule are needed (if any) to increase consumer benefits, reduce costs, or account for changes in relevant technology or economic conditions. The attached comments outline in detail the position of ETA and its membership with regard to the FTC's request for public comment on the Safeguards rule. ETA thanks you for the opportunity to submit these comments. Respectfully submitted, Scott Talbott Senior Vice President of Government Affairs Electronic Transactions Association