March 9, 2026 — Press Release

Treasury’s System of Records Notice Proposal Would Enable Dramatically Increased Government Collection and Sharing of Sensitive Personal Data  

WASHINGTON – The U.S. Department of Treasury has proposed maintaining an extensive database of private personal information and sharing that information with other government agencies and some select corporations. The proposal, contained in a dry “Systems of Record Notice,” would allow Treasury to collect, maintain, and share information, including bank account information, social security numbers, and employment and income information, from eight separate Treasury-run programs. Those programs include programs that provided vital assistance to small businesses, homeowners, and renters during the COVID national emergency. 

Any personal information Treasury or the states administering those programs collected on applicants, or anyone associated with applicants whose information appears in the files, would be subject to Treasury’s proposal and cross-matched with data collected in the other programs. 

The proposed practices are disclosed in the Treasury’s February 6 Systems of Records Notice (SORN) proposal. Systems of Record Notices are usually routine documents the government uses to explain what data it is collecting and maintaining and how particularly personal and sensitive information is safeguarded. Treasury’s proposal diverges sharply from what is generally a routine bureaucratic process The National Consumer Law Center (NCLC), along with the Center for Responsible Lending, the National Housing Law Project, and nearly 50 legal service organizations, filed comments today in strong opposition to the proposal. 

“The federal government’s overbroad and imprecise proposal opens the door to the invasion of privacy of millions of people,” said Steve Sharpe, senior attorney at NCLC. “The proposed system could capture data on people who have little to no relationship to Treasury programs.” 

The Treasury proposal lists 21 separate categories of entities that may have access to the data, and there are subcategories within those 21 categories, raising concerns about the number of ways that Treasury proposes to share people’s private information.

“This proposal raises serious cybersecurity concerns that could expose sensitive information from millions of people, including small business owners, employees and struggling households,” said Anneliese Lederer, senior policy counsel at the Center for Responsible Lending. “Protecting consumers’ privacy and financial security should not require a system that risks unnecessary surveillance or widespread data exposure.”

Among the affected programs are the Homeowner Assistance Fund (HAF) and the Emergency Rental Assistance Program (ERAP), which both already have effective measures in place to prevent fraud and non-compliance, including oversight and auditing by the Treasury Inspector General. In both programs, beneficiaries do not receive federal funds directly; instead, mortgage servicers and landlords certify that mortgage payments or past due rent were owed, and the program administrators disburse payments to those third parties rather than to individuals.

“The announcements of government data collection are typically routine matters that do not warrant comment, but the scope of this notice is an astonishing and dramatic departure from prior Treasury practice,” said Sharpe. “The ways this sensitive information could be shared with other agencies are unjustifiable and dangerous.”

Advocates urge the Treasury to reconsider and narrowly tailor this effort.

“Privacy safeguards are not optional,” Sharpe said. “The Trump Administration must withdraw this effort to sweep up massive amounts of personal information for no apparent purpose.”

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