The Future of Open Banking: Regulation Meets Reality

Session 2: IPA Compliance Boot Camp

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
  ​
  

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.

Register Now | Compliance Boot Camp

The IPA’s Compliance Boot Camp in Chicago on Sept. 11 offers a unique opportunity to dive deep into the latest regulations and trends. From hot topics like Open Banking and Earned Wage Access to the legal implications of AI and serving cannabis businesses, this one-day event is packed with insightful sessions led by industry experts. Eligible for up to 7 CLE credits in Illinois, Georgia, Florida, New York, and Texas, the Boot Camp provides both practical knowledge and professional development. Don’t miss this chance to gain the insights you need to thrive in today’s dynamic market. Register now.