All Things FinReg

Almost exactly a year after issuing a Notice of Proposed Rulemaking (NPRM) on Personal Financial Data rights, on October 22, 2024 the Consumer Financial Protection Bureau (CFPB) issued its final Rule under Section 1033 of the Consumer Financial Protection Act. The Rule, also referred to as the “open banking rule,” has been a key priority of CFPB Director Rohit Chopra’s rulemaking agenda, and according to the CFPB and Director Chopra, aims to give consumers greater rights over their personal financial data and promote competition and consumer choice in financial products and services.

As highlighted previously, three federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency) recently issued proposed risk management guidance regarding third-party relationships (Proposed Guidance). Among other things, the Proposed Guidance specifies that banking organizations should adopt third-party risk management processes that are commensurate with the identified level of risk and complexity from the third-party relationships, and with the organizational structure of each banking organization.