1.We actively monitor the status of the CFPB Personal Financial Data Rights rule (Section 1033), including the current litigation and reconsideration rulemaking.

The rule was finalized in October 2024, enforcement is currently enjoined, and the CFPB is rewriting parts of it — readiness means tracking both the rule and its direction.

2.We have a named executive owner and cross-functional team accountable for open banking compliance.

3.We know which compliance tier our institution falls into by asset size and have a roadmap that works back from a realistic go-live date.

4.We engage with industry standard-setting — FDX membership, working groups, or comment letters to the CFPB.