This regulatory framework will fundamentally transform how financial data flows between institutions and third parties, creating obligations and opportunities. This report examines six critical decision points FI executives must address regarding CFPB Rule 1033 implementation and provides strategic guidance on timing, methodology, risk management, and competitive positioning within the emerging open banking ecosystem.

The report is based on comprehensive market research conducted between January and April 2025 examining regulatory frameworks, implementation timelines, and strategic considerations across FI segments, as well as interviews with senior executives at FIs of varying asset sizes, fintech leaders, and data aggregators actively engaged in open banking initiatives. Secondary analysis evaluated the technological readiness, security concerns, and competitive positioning of market participants as they navigate the evolving open banking landscape.
Clients of Datos Insights’ Retail Banking & Payments and Cybersecurity services can download this report.
This report mentions Akoya, Bank of America, Bank Policy Institute, Financial Data Exchange (FDX), Finicity, Fiserv, JPMorgan Chase, Kentucky Bankers Association, MX, PayPal, Plaid, Venmo, Wells Fargo, and Yodlee.
About the Author
Stewart Watterson
Stewart Watterson is a Strategic Advisor in the Retail Banking & Payments practice at Datos Insights. He brings a broad range of experience from 30 years of consumer banking with Chase, NationalCity, and PNC, serving as SVP, Mobile Wallet & Emerging Payments. His focus includes consumer lending within all asset classes, small-and-midsize-business unsecured lending, digital banking, credit card, card and...
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John Horn
John Horn leads the Cybersecurity practice at Datos Insights, which provides valuable cybersecurity and identity research, insights, and advisory services to financial services firms. In addition to leading a team of Strategic Advisors, John functions as a distinguished industry expert and critical thinker within the rapidly evolving domains of identity, cybersecurity, and risk. His coverage areas include identity security, identity and access...