Subject: File No. S7-2024-05
From: Lynette T Stevenson

On behalf of DALS Credit Solutions Co., I would like to provide our comments on the proposed rule to establish data standards to promote interoperability of financial regulatory data across various agencies, as outlined by the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Consumer Financial Protection Bureau, Federal Housing Finance Agency, Commodity Futures Trading Commission, Securities and Exchange Commission, and the Department of the Treasury. Serving the Underserved Community At DALS Credit Solutions Co., we empower underserved and underrepresented communities by providing critical credit solutions, financial education, and access to capital. We focus on fostering sustainable growth and economic success for individuals and businesses traditionally excluded from mainstream financial services. We believe that financial inclusion and equitable access to credit are fundamental drivers of economic opportunity, especially for those in underserved communities. The Importance of Data Standards and Interoperability We welcome the effort to create data standards that promote interoperability among financial regulators. Standardized data collection and the seamless sharing of financial regulatory information across agencies are essential for ensuring consistency in how credit is assessed, regulated, and reported across the economic system. This could lead to more accurate and timely credit analyses, particularly for small businesses and individuals in underserved communities who often face challenges navigating a fragmented financial regulatory landscape. As a company that provides credit analysis and solutions to underserved populations, we see firsthand how inconsistencies in data across different financial institutions and agencies can lead to misinterpretation of creditworthiness, inaccuracies in reporting, and, in some cases, unnecessary barriers to access to credit. For example, a lack of standardized data sharing between financial institutions can contribute to redundant processes that disproportionately affect those in underserved communities, delaying access to crucial financial services and solutions. Supporting the Financial Data Transparency Act of 2022 The Financial Data Transparency Act of 2022 aims to improve transparency and accessibility within the financial system by standardizing financial data across agencies. We strongly support this Act's goals because it will likely result in more inclusive and accurate credit assessments. These improvements are critical for providing underserved populations with fairer opportunities to access credit. By establishing common standards, the proposed rule will help mitigate systemic issues that have long plagued these communities, such as uneven access to financial services, credit misreporting, and a lack of consistent regulatory oversight. Additionally, with agencies adopting final standards, we expect improvements in data quality, which can lead to more informed and equitable lending decisions. When financial institutions have access to uniform and high-quality data, they can better assess credit risk, potentially opening up opportunities for businesses and individuals that have previously been overlooked or misjudged due to inconsistent or incomplete data. This could be a significant benefit for the communities we serve, where individuals and small businesses are often disproportionately affected by credit barriers. While we applaud the initiative, we urge the agencies to ensure that implementing these data standards does not create additional compliance burdens on smaller financial institutions or companies like ours that serve the underserved community. The data standards must be designed to be flexible enough to account for the diverse nature of the financial ecosystem while ensuring that all participants—especially those who are already at a disadvantage—are not further marginalized by increased regulatory complexity. We encourage the agencies to actively engage with small and community-based financial institutions and organizations like ours that work directly with underserved communities to ensure that the final rule strikes the right balance between improving transparency and avoiding unintended consequences that could further hinder access to credit. In conclusion, DALS Credit Solutions Co. strongly supports the proposed rule to establish data standards to promote interoperability of financial regulatory data as required by the Financial Data Transparency Act of 2022. We believe this rule will positively impact credit analysis and access to credit, particularly for underserved communities. We urge the agencies to ensure that the standards are implemented to maximize benefits for these populations without imposing additional barriers. We appreciate the opportunity to comment on this critical rulemaking and look forward to further developments as the standards are finalized and implemented. Thank you for your attention to this matter.