Open banking has long promised to reshape the financial services ecosystem, empowering consumers with control over their data and promoting greater innovation through API-driven access. In October 2024, the Consumer Financial Protection Bureau (CFPB) took a major step forward by finalizing a rule under Section 1033 of the Dodd-Frank Act. But the celebration was short-lived.

Litigation quickly followed. The change in presidential administration and agency leadership only deepened the uncertainty. Now, financial institutions, fintechs, and data aggregators are left navigating a future in flux.

In this session at the IPA’s Compliance Boot Camp, Brian Montgomery of Pillsbury Winthrop Shaw Pittman LLP will provide a legal and regulatory roadmap for how companies can prepare for what’s next, despite the ambiguity.

Why Open Banking Matters Now

The CFPB’s final rule represented a milestone in the open banking journey, mandating that consumer financial data be made accessible upon request. However, multiple legal challenges have cast doubt on the rule’s implementation timeline, and emerging federal leadership may shift priorities once again.

Montgomery will discuss the rule’s foundational components, how it compares with global frameworks, and what steps companies can take now to remain agile and compliant—whether the rule is paused, narrowed, or upheld in full.

Key session topics:

• Overview of the CFPB’s final rule under Section 1033
• Current legal challenges and their potential implications
• Industry obligations under the rule – what’s required and what’s still unclear
• How open banking could evolve under a different regulatory philosophy
• Strategic considerations for institutions managing API access and data security
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As financial institutions increasingly rely on partnerships and data-sharing models, understanding how open banking may (or may not) unfold in the U.S. is critical to risk management, compliance, and long-term strategy.

​Reg E, which governs electronic fund transfers and consumer protections under the Electronic Fund Transfer Act, remains a cornerstone of compliance in the payments industry. However, as enforcement trends shift and scrutiny increases, companies must stay ahead of how regulators interpret – and act on – potential violations.
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In this session at the IPA Compliance Boot Camp, Greenberg Traurig attorneys Tim Butler and Matt White will walk attendees through recent enforcement actions brought by the Consumer Financial Protection Bureau (CFPB) and State Attorneys General. They’ll explore the conduct that led to scrutiny, how regulators framed those violations under Reg E, and, most importantly, how companies can proactively manage risk in their operations.

Why Reg E Matters Now

 Despite the change in regulatory leadership, Regulation E remains a key area of focus. Alleged failures in disclosures, error resolution, and procedural clarity have resulted in penalties, reputational harm, and ongoing compliance burdens for companies across the financial services landscape.
This session will provide practical, actionable guidance to help your organization avoid similar pitfalls and stay off regulators’ radar.

Key session topics:

• Common patterns in recent Reg E enforcement actions
• How the CFPB and state regulators are interpreting violations
• Risk areas tied to disclosures, error resolution, and transaction handling
• Proactive compliance strategies and internal controls
• Real-world tips to strengthen your organization’s Reg E posture
  
  

Whether you’re overseeing compliance directly or managing product teams that support electronic fund transfers, this session offers vital insights for navigating today’s regulatory environment with confidence.

Information provided to members by OGR

As Congress counts down to the Independence Day recess, the Senate faces growing pressure to finalize reconciliation and debt ceiling legislation. At the same time, shifting international dynamics and heightened domestic tensions are altering the focus in Washington—making this a critical week for leaders in financial services and payments policy.

In this week’s OGR’s Big Picture, available exclusively to IPA members, we cover:

• The Senate’s expected vote on the GENIUS Act, a bipartisan bill regulating stablecoins
• Key developments in reconciliation, including potential changes to SALT deductions and business tax extenders
• How internal GOP divisions are shaping the final package—and what moderates and fiscal hawks want
• The debt ceiling timeline and Treasury’s warning of mid-August limits
• Domestic and global implications of the G7 summit, recent violence in Minnesota, and foreign policy shifts
  
  

And in Tuck’s Tax Take: What placeholder tax provisions may reveal about the negotiations—and where Senate Finance is headed next.

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As financial pressures continue to mount for millions of Americans, tools that provide short-term financial flexibility, like Earned Wage Access (EWA), are more critical than ever. EWA gives workers early access to wages they’ve already earned, offering a vital buffer for unexpected expenses and reducing reliance on high-cost credit products.

In a recent op-ed published by Payments Dive, Brian Tate, President and CEO of the Innovative Payments Association, calls on the Consumer Financial Protection Bureau (CFPB) to provide clear, stable guidance that protects access to EWA. Tate argues that the CFPB’s recent regulatory reversals have created confusion and uncertainty, despite years of precedent affirming that EWA is not credit.

In 2020, the CFPB issued an Advisory Opinion confirming that EWA functions as early wage delivery—not lending. That opinion spurred responsible innovation and widespread adoption, helping workers manage cash flow without incurring debt. But the Bureau has since revoked that guidance without adequate input from stakeholders, introducing unnecessary instability into the marketplace.

Tate’s message is clear: The CFPB must reissue a strong, expanded advisory opinion to affirm that EWA is not a credit product. Doing so would restore regulatory clarity and support the continued availability of this important tool for American workers.
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Read the full op-ed in Payments Dive:
IPA CEO: CFPB must clarify earned wage access is not credit (via Payments Dive)