Joe Castelluccio的动态

?? "On October 22—the day the CFPB released its Section 1033 rule—the Bank Policy Institute (BPI), the Kentucky Bankers Association, and Forcht Bank, N.A. filed a lawsuit?against the CFPB challenging the final rule in District Court in Kentucky. According to the BPI, the CFPB exceeded their statutory authority and violated the Administrative Procedure Act in various ways." ?? "According to the complaint, the rule ?? Requires no oversight of third parties who are using customer banking data, thereby leaving it up to banks to ensure the protection of sensitive customer information, ?? Increases the likelihood of fraud and scams by “failing to address weak safeguarding practices,” ?? Does not outright eliminate “unsafe” practices such as screen scraping, ?? Does not hold third parties accountable for data security, ?? “Allows third parties to profit, at no cost, from systems built and maintained by banks,” and ?? “Imposes an unreasonable implementation timeline." ?? What are your thoughts? https://lnkd.in/gj9bHgxY

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing the requirements of sections 1033(a) and (b) of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. The Rule is intended to strengthen data security and improve competition in the open-banking ecosystem by making it easier for consumers to switch providers of financial products and services. For more information, read our recent client alert, “CFPB Finalizes Open Banking Rule: What Financial Institutions and FinTechs Need to Know,” authored by partners Andrew Owens and Benjamin Saul, associate Tarrian Ellis, and law clerk Nathaniel Sans.

?? The wait is over! It has been four years since the Consumer Financial Protection Bureau announced its plans to explore the implementation of Section 1033 of the Dodd-Frank Act—more commonly known as open banking. Today, the CFPB published its final rule, a nearly 600-page regulation highly anticipated by the U.S. financial industry to bring the country on par with global counterparts. This complex regulation introduces new consumer financial data rights, outlines banks' liability for fraud and data breaches, and mandates the removal of insecure data capture methods such as 'screen scraping.' The rule also extends to financial products like mobile wallets and payment apps such as PayPal, Venmo, and Zelle. In response to feedback from industry associations, the CFPB has added a new compliance tier, with the lowest threshold set at $850 million in assets. The new compliance table is now as follows (not mentioning non-depository institutions to keep it simple): 1. Depository institutions with $250B in total assets: April 1, 2026 2. Depository institutions with $10B-$250B in total assets: April 1, 2027 3. Depository institutions with $3B-$10B in total assets: April 1, 2028 4. Depository institutions with $1.5B-$3B in total assets: April 1, 2029 5. Depository institutions with $850M-$1.5B in total assets: April 1, 2030 ? If you’re feeling overwhelmed by the details of the 1033 final rule, don’t worry! We've brought together the brightest minds in the industry for a free, virtual conference on Nov 19-20. These experts will cover all aspects of the rule, from legal and privacy concerns to security, consent management, data governance, and more. ?? Register today: https://lnkd.in/eqBHAgKj #openbanking #openfinance #DoddFrank1033 #CFPB1033 Financial Data Exchange OpenFinity https://lnkd.in/g5X7UnXU

This week in exciting #OpenBanking news: last Wednesday, the?Consumer Financial Protection Bureau (CFPB) announced a new rule explaining the qualifications and attributes a standard setting body will need to be recognized by the CFPB. This is significant because recognized industry standard setting bodies will be able to issue standards to companies?so they can comply with the CFPB’s upcoming Personal Financial Data Rights Rule. ? “Industry standards can be weaponized by dominant firms in order to maintain their market position, undermining competition for all,” said CFPB Director Rohit Chopra in the CFPB's press release. “Today’s rule will prevent these firms from rigging standards in their favor by identifying attributes the CFPB will use to recognize standard setters.” ? To gain recognition from the CFPB, a standard setting body will need to display: ·??Openness ·??Transparency ·??Balanced decision-making ·??Consensus ·??Due process and appeals It is widely expected that the FDX API from the Financial Data Exchange will be declared as official standard, based on its existing market dominance. However, the CFPB has made it clear that FDX should not take this for granted, and with the release of these guidelines, they have set the bar for selection quite high,?level playing field in the open banking ecosystem. ? Read more in the release here:?https://bit.ly/3KydorY