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The Consumer Financial Protection Bureau&rsquo;s new rule under Section 1033 of the Dodd-Frank Act has arrived. Are you ready for it?
Watch this recorded conversation with policy experts and MX product leaders to hear more about:
<ul>
<li>Key changes in the final rule and what they mean for you</li>
<li>Where to get started on your road to compliance, and how to go beyond compliance to tap into new opportunities</li>
<li>MX&rsquo;s Data Access &mdash; the only solution that combines an API platform that meets FDX standards with built-in analytics that deliver actionable intelligence.</li>
</ul>

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We&rsquo;re now just weeks away from the anticipated final Section 1033 rulemaking from the Consumer Financial Protection Bureau. Is your organization ready to tackle both the new opportunities and new regulatory obligations ahead?
Watch this conversation with policy experts and MX product leaders to hear more about:
<ul>
<li>Moving beyond a compliance conversation to understanding how to improve outcomes for consumers and gain a competitive advantage</li>
<li>How MX&rsquo;s Data Access combines an API platform that meets FDX standards with built-in analytics that deliver actionable intelligence</li>
<li>Where you can start today with meeting expected compliance obligations and delivering the best experiences for your customers</li>
</ul>

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<div class="sc-9bc894f7-7 hyAXFE">
<div class="forum-info">
The majority of consumers expect their financial provider to know them. But that means more than just knowing their ZIP code, FICO score, or income. Unique individuals with unique needs want &mdash; and demand &mdash; a personalized money experience, not generic account updates and reminders.
Finastra partners with MX to provide engaging money management features as part of the Finastra Fusion digital banking platform, including MX Personal Financial Management (PFM) and Insights. These tools translate consumer financial data into actionable intelligence to deliver personalized experiences, drive consumer engagement, and support financial wellness.
&nbsp;
<h2>Watch this webinar and demo to learn how to:</h2>
<ul>
<li>Drive engagement and strengthen relationships with data-driven insights and money management experiences</li>
<li>Unlock financial data to create actionable and intuitive experiences that drive better outcomes</li>
<li>Leverage MX PFM and Insights to deliver timely, relevant guidance to help consumers reach their financial goals</li>
</ul>
</div>
</div>

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<div>
What will be the difference for financial institutions and fintechs to win in 2024? Join us for a deep dive into whats on the horizon, including Open Banking growing pains, the next generation of financial wellness tools, and the future of AI and personalization &mdash; and a peek into how financial data intelligence can be a differentiator for your organization.
<h2>Watch this Webinar to Learn:</h2>
<ul>
<li>4 predictions for 2024 for the financial industry landscape</li>
<li>How to unlock new insights and opportunities with your financial data</li>
<li>Best practices for winning and retaining deposits &mdash; and engaging customers for the long term</li>
</ul>
</div>

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Consumers are more than just a zip code, FICO score, or income. We&rsquo;re unique people with unique stories that require a personalized experience to meet our needs. Today&rsquo;s digital banking experiences require the right balance of automation and personalization that meet consumers where they are.
MX partners with NCR to provide MX Insights &mdash; a personalized feed of real-time financial insights &mdash; which integrates seamlessly with the NCR digital banking platform and will be available to NCR customers early next year.
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<ul>
<li>Build trust and strengthen relationships with data-driven insights and experiences</li>
<li>Unlock financial data to create actionable intelligence and intuitive experiences that go beyond account balances and generic reminders</li>
<li>Leverage MX Insights to deliver timely, relevant guidance and insights to help consumers reach their financial goals</li>
</ul>

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Financial institutions have massive amounts of data. Putting data into action can create more engaging customer experiences.

Financial institutions have massive amounts of data. By putting data into action, they can create more engaging customer experiences.

Putting Data into Action for Better Customer Experiences

Today&rsquo;s economic uncertainty requires financial providers to effectively leverage consumer data to positively influence the financial system.&nbsp;
Rodney Hood, Former Acting Comptroller of the Currency and Chairman of the National Credit Union Association, <a href="https://www.mx.com/summit/2025/welcome-mxs-2025/">recently said</a>, &ldquo;Our financial system is strong, our regulators are engaged, and our innovators, companies like MX, are proving that technology, data, and partnerships can create a more inclusive and resilient financial system.&rdquo;
Unfortunately, 31% of consumers agree they don&rsquo;t feel financial providers do enough to support their financial needs, <a href="https://www.mx.com/research/financial-apps-fall-short/">according to MX</a>. The same study found that 65% of consumers agreed they expect financial institutions to use the data they have about them to provide them with actionable and clear insights about their finances.
What does this tell us?
Consumers want and expect more. They need more for a resilient financial system that prioritizes consumer outcomes. And, the solution can be found through financial data.
Financial institutions are sitting on massive amounts of consumer-permissioned data. But data for the sake of data doesn&rsquo;t do anything. The key is turning that data into action. Action for the institutions. Action for the consumers. Action that transforms.
<h2>What Do We Mean by Data?</h2>
Every time a consumer opens their mobile banking app, taps their card to make a payment, or browses loan options, they&rsquo;re signaling who they are and what they need. Financial institutions can leverage this data and turn it into wisdom to become a dynamic partner to their customers.
Additionally, consumers opt to share specific data that can help their financial institution to know them even better. Once they&rsquo;ve consented to sharing data, it&rsquo;s up to financial institutions to turn that data into something better.
As <a href="https://www.thisweekinfintech.com/from-bits-to-gold-the-alchemy-of-data-in-financial-services/">Jas Shah with Fintech Takes</a> said, &ldquo;Data is valuable, but only when it&rsquo;s given context, meaning, and put into action to make intelligent, informed decisions.&rdquo; He also shared how each of these things build upon each other to transform data into something real and tangible.
 <img src="https://cms.mx.com/assets/75e9dc94-cffc-4f15-bd05-3a4c4551fcd9?width=1600&amp;height=901" alt="DIKW/DIKI Pyramid" /> 
<h2>Consumers Don&rsquo;t Just Want It &mdash; They Expect It</h2>
In a <a href="https://www.mx.com/webinars/data-in-action-retain-grow-deposits/watch/">recent webinar</a>, Jana Manley, Chief Growth Officer at Suncoast Credit Union, answered the question whether customers are ready for their providers to use consumer data to personalize their experiences.
<blockquote>
&ldquo;They expect it. And I think a lot of them are exceptionally disappointed that their financial institutions don&rsquo;t look to that level to help them.&rdquo;
</blockquote>
Consumers agree with that sentiment. Today, 55% of U.S. consumers said they would give their financial provider access to more of their data if they knew it would result in a better experience, <a href="https://www.mx.com/research/financial-apps-fall-short/">according to MX</a>.
Putting data into action is a value add for everyone. Financial providers can create better, more engaging customer experiences. Consumers can take advantage of improved, personalized financial experiences. It&rsquo;s a win-win.
<h2>Activating Data for Financial Institutions</h2>
Data is dynamic. Financial providers that treat data as such will be able to unlock growth that impacts the entire business and drives better outcomes for consumers. Some key areas of growth include:
<ul>
<li style="font-weight: 400;" aria-level="1">Attract and Retain Deposits: Grow relationships and share of wallet with early visibility into deposit risks.&nbsp;</li>
<li style="font-weight: 400;" aria-level="1">Support Financial Wellness: Unlock insights that offer personalized guidance to help customers reduce financial stress and take action to improve their financial strength.</li>
<li style="font-weight: 400;" aria-level="1">Deliver Personalized Insights and Offers: Surface data-driven product recommendations that improve engagement and deepen relationships over time.</li>
<li style="font-weight: 400;" aria-level="1">Prevent Fraud: Recognize irregularities that may be a sign of fraud more quickly to help proactively manage risk and reduce call center volumes.</li>
</ul>
<h2>Activating Data for Consumers</h2>
Financial institutions that make data-driven decisions will be able to delight customers and create more engaging experiences. Activating data can transform the customer experience through:
<ul>
<li style="font-weight: 400;" aria-level="1">Increased Engagement and Financial Wellness: Consumers can receive personalized nudges about savings goals, switching direct deposits, or reviewing irregular transactions. These insights can empower them to take a more active role in their financial lives &mdash;&nbsp;and drive higher levels of engagement.</li>
<li style="font-weight: 400;" aria-level="1">Increased Clarity and Transparency: Cleansed data ensures that consumers know where their money is going &mdash; instead of trying to make sense of a confusing jumble of numbers and letters.</li>
<li style="font-weight: 400;" aria-level="1">Increased Trust: Through better data use, financial providers can become even more trustworthy partners for financial decisions.</li>
</ul>
<h2>Your Data into Action Partner</h2>
MX&rsquo;s solutions are built on the promise of turning data into action, and letting that create positive outcomes for consumers. At <a href="https://www.mx.com/summit/2025/welcome-mxs-2025/">Money Experience Summit 2025</a>, Rodney Hood said, &ldquo;MX proves that financial data &mdash; when delivered transparently and responsibly &mdash; can close gaps in access and, in fact, promote fairness.&rdquo;
In practice, what does data into action look like? Rodney went on to explain that institutions using fintech tools that provide proactive, real-time financial nudges can help underbanked families start saving for emergencies, avoid overdraft fees, and pay down debt &mdash; which all have a significant impact on financial health.
Turning data into action is a non-negotiable for financial institutions today. To win and retain customers, it&rsquo;s all about the data and making the right data work. Financial providers who put the data consumers choose to share with them into action will drive stronger engagement, increased customer satisfaction, higher deposits, and establish long-term relationships.
To see how you can turn data into action, <a href="https://www.mx.com/request-demo/">discover MX</a>.

The Power of Data: Putting Data into Action

MX&rsquo;s latest survey of more than 1,000 U.S. adults outlines what financial institutions and fintechs need to know to win and retain customers and deposits.&nbsp;
<h2>Key Findings&nbsp;</h2>
<h3>1. Financial Account Consolidation Continues&hellip; But So Do New Account Openings</h3>
Today, most consumers report they only have 1 to 2 financial accounts (46%). However, when asked how often they have opened a new account, 1 in 4 consumers are doing so at least once per year.&nbsp;
<img src="https://cms.mx.com/assets/18a85aba-870d-4a60-a147-3dd06cdef710?width=1200&amp;height=280" alt="Callout1 (2)" />
<h3>2. Better Rates and Security Drive Direct Deposit Switches</h3>
When asked what is likely to make them switch their direct deposit, the top 3 factors for consumers are:
<img src="https://cms.mx.com/assets/7d88603a-0b72-4eb2-8335-eb0a1d779c55?width=1200&amp;height=511" alt="Callout2 (1)" />
<h3>3. Consumers Quick to Save Card on File&nbsp;</h3>
67% of consumers say they keep their bank or credit card information on file for recurring bills or services. In addition, 44% of consumers agree they have a &ldquo;top of wallet&rdquo; account they use for the majority of their purchases and payments.
<img src="https://cms.mx.com/assets/8aca921e-8087-42d0-80e9-56058f4fe41c?width=1200&amp;height=267" alt="Callout3" />
<h3>4. Financial Data More Closely Guarded than Medical Data</h3>
Of all data types, consumers are least likely to share their financial data with a trusted third party in order to receive a service. 44% of consumers say they are unlikely to share their financial data with a trusted third party in order to receive a service.
<img src="https://cms.mx.com/assets/93c1fe7c-1883-4380-9310-abd5a842c7b1?width=1200&amp;height=250" alt="Callout4" />
<h3>5. Consumers Are Ready to Ditch Bad Experiences</h3>
67% of consumers say they will stop using a mobile app if the experience changes for the worse. And, 51% of consumers say they have closed or switched a financial account.
<img src="https://cms.mx.com/assets/edf86998-6ec6-4f90-84ea-6dc9be2e73b0?width=1200&amp;height=364" alt="67percent (2)" />
<h2>Financial Account Consolidation Continues&hellip;&nbsp;</h2>
In our <a href="https://www.mx.com/research/financial-apps-fall-short/">previous research</a>, we saw a clear indicator that consumers are consolidating the number of finance-related apps they use. Now, we&rsquo;ve asked consumers to share how many financial accounts and providers they currently have. The largest group of consumers (46%)&nbsp;say they only have 1 to 2 financial accounts.&nbsp;
Figure 1. Approximately how many financial accounts (i.e., checking, savings, investments, credit cards, loans, etc.) do you currently have?&nbsp;
<img src="https://cms.mx.com/assets/bf790f7b-7630-4d3b-9a1f-2aea068cf5a6?width=1200&amp;height=875" alt="Figure1" />
At the same time, 61% of U.S. adults say they have accounts with just 1 to 2 different financial providers. This is a <a href="https://www.mx.com/research/what-consumers-want-from-financial-providers/">10-point increase in the past 2 years</a>, showing more evidence that financial account consolidation is on the rise.&nbsp;
<blockquote>
In the past 2 years, at least 1 in 10 consumers have made an effort to consolidate the number of financial providers they have accounts with today.&nbsp;
</blockquote>
<h2>&hellip; But So Do New Account Openings</h2>
While consumers may be looking to consolidate their financial lives into fewer accounts, apps, and providers, that doesn&rsquo;t stop them from opening new accounts when the occasion calls for it. On average, more than 1 in 4 consumers open a new financial account at least once per year. This is even higher among younger generations.
Figure 2. On average, how often have you opened a new financial account, including credit cards, loans, etc.?
<img src="https://cms.mx.com/assets/bea5ab5e-316d-493c-8cc4-b61928aedd66?width=1200&amp;height=901" alt="Figure2" />
While some new account openings may be the result of a well-timed promotion or incentive, many consumers are likely to open new accounts or switch their direct deposits at key moments in their lifetime. Literally moving to a new city tops the list of life events that could prompt a switch, followed by a new job and purchasing a home.&nbsp;
Figure 3. In what situations would you be likely to open a new account or set up a new direct deposit?&nbsp;
<img src="https://cms.mx.com/assets/784921c6-8494-4493-81b4-cfcb5694aae9?width=1200&amp;height=943" alt="Figure 3" />
<h2>Better Rates and Security Drive Direct Deposit Switches</h2>
Deposits are the lifeblood of any financial institution. But, growing and retaining them is increasingly difficult due to increased competition, rising rates, and shifting customer behaviors. Our research shows what factors are top of mind for consumers to encourage them to set up or switch a direct deposit.&nbsp;
Direct deposit is the clear norm for most consumers &mdash; 89% use direct deposit today, with most continuing to default to depositing the entire amount into one account.&nbsp;
Figure 4. Which of the following statements most closely aligns with how you manage direct deposits?
<img src="https://cms.mx.com/assets/399d9eaf-71cd-434e-b5ca-4410724b2f33?width=3334&amp;height=2500" alt="Figure4 (2)" />
<blockquote>
Simplifying Direct Deposit
In the same way that consumers are consolidating how many accounts and providers they use, our research also shows consumers may be simplifying their direct deposits. In the past year, the number of consumers who split their direct deposit into multiple accounts has declined by 5 points.&nbsp;
</blockquote>
For most consumers, setting up a direct deposit at a financial institution yields a long term relationship. In fact, 60% of consumers say they have never switched their direct deposit to a different financial institution. But, that might be changing. Since the <a href="https://www.mx.com/research/driving-engagement-for-consumers-research/">beginning of 2024</a>, 5% more consumers have now switched a direct deposit. Why the switch? Top reasons include: 
Figure 5. Which of the following factors was most important in your decision to switch your direct deposit to a different institution?&nbsp;
<img src="https://cms.mx.com/assets/a7156225-9e2d-4d7e-b358-6e44e1b33f19?width=1200&amp;height=954" alt="Figure5" />
As more consumers become willing to make a change to their direct deposit, financial providers should lead with incentives and security. When asked what is likely to make them switch their direct deposit, the top 3 factors for consumers are:
<img src="https://cms.mx.com/assets/33849b53-41cb-4d4a-8b1b-cf35f6592da3?width=1200&amp;height=511" alt="Callout2 (1)" />
In addition, when asked specifically if a cash incentive would encourage them to switch, 44% of consumers say yes. However, there&rsquo;s no clear dollar amount that will drive action. We gave consumers the opportunity to write in the lowest cash amount they would accept as an incentive to switch your direct deposit to a different account. Results varied widely from millions to hundreds to nonsensical text (&ldquo;cactus&rdquo; was our favorite answer). However, most conventional answers fell in the range of $50 to $200.&nbsp;
<img src="https://cms.mx.com/assets/cec6add4-1a92-417a-9bf9-cb038f67c906?width=1200&amp;height=358" alt="Callout.6" />
<h2>Consumers Quick to Save Card on File&nbsp;</h2>
Easy to use. Earns Rewards. Trustworthy. These are the three top reasons consumers choose to use a particular account by default for the majority of their purchases and payments. What&rsquo;s more, 44% of consumers say they have a &ldquo;top of wallet&rdquo; account they use for the majority of their purchases and payments. 
Figure 6. What is the primary reason you use this account by default for the majority of purchases and payments?
<img src="https://cms.mx.com/assets/c17bcaec-4803-424a-9454-34d021b6895d?width=1200&amp;height=890" alt="Figure6 (1)" />
The research makes it clear that consumers often prioritize convenience in their financial lives. In fact, 67% of consumers say they keep their bank or credit card information on file for recurring bills and/or services, leveraging it to pay for everyday items like streaming services and utilities to ongoing bills like rent and insurance.&nbsp;
Figure 7. For which of the following recurring bills or services do you have a bank account or credit card on file? (Select all that apply)
<img src="https://cms.mx.com/assets/7ab349bb-f9e2-4b3d-bf59-490c35d90576?width=1200&amp;height=1112" alt="Figure7" />
Consumers are also likely to save their bank or credit card information with a store or vendor for online purchases. In fact, 1 in 5 consumers say they do this whenever it is an option.&nbsp;
Figure 8. Outside of the recurring services mentioned above, how often do you save your bank or credit card information with a store or vendor for online purchases?
<img src="https://cms.mx.com/assets/bb637a3e-0b84-4cd9-adb1-7674d5080bc3?width=1200&amp;height=898" alt="Figure8 (1)" />
<h2>Financial Data More Closely Guarded than Medical Data</h2>
Consumers are willing to exchange their data for a better experience, but they&rsquo;re not quite ready to share all data to the same extent. Our research shows financial data may be the most closely guarded.&nbsp;
Figure 9. Of all data types, consumers are least likely to share their financial data with a trusted third party in order to receive a service.&nbsp;
<img src="https://cms.mx.com/assets/076a9f72-3d1e-4c18-bcb9-944fdc082fa7?width=1200&amp;height=837" alt="Figure9" />
Figure 10. Unsurprisingly, older generations are least likely to share their data with a third party&hellip;
<img src="https://cms.mx.com/assets/16b705c0-da6f-4397-838a-85c596a9c5fc?width=1200&amp;height=629" alt="Figure10 (4)" />
Figure 11. &hellip;compared to younger generations who will more readily share information with third parties in order to receive a service.&nbsp;
<img src="https://cms.mx.com/assets/f8516906-eb32-4612-9c01-57533e311b6a?width=1200&amp;height=627" alt="Figure11 (2)" />
While consumers appear to be most protective of their financial data, previous research shows a clear willingness to share their data if it will deliver better experiences for them. <a href="https://www.mx.com/research/financial-apps-fall-short/">Our previous survey shows</a> 55% of U.S. consumers agreed they would give their financial provider access to more of their data if they knew it would result in a better experience.&nbsp;
<h4>Why? It&rsquo;s about personalization and, as we&rsquo;ve said before, convenience.&nbsp;</h4>
While consumers claim to be hesitant to share their financial data with third parties, the reality is consumers want fast, easy, and personalized experiences. And, they&rsquo;ll pay for them with their data.&nbsp;
For example, nearly half of consumers are ready to save their information with an online store after just one purchase, most likely to save time down the road.&nbsp;
Figure 12. Have you ever created an account and saved your information the first time you made a purchase through an online store?&nbsp;
<img src="https://cms.mx.com/assets/fb6472d0-4f6d-47e3-8990-819a11c7211a?width=1200&amp;height=654" alt="Figure12" />
And, when asked in which cases they expect financial providers to use their data to offer a more personalized experience, only 18% of consumers said none. Top use cases where they expect personalization from their data include:
Figure 13. In which of the following cases do you expect financial providers to use your data to offer a more personalized experience? Choose all that apply.
<img src="https://cms.mx.com/assets/f60ae5e3-0379-4e22-8a1e-634af3bca8c6?width=1200&amp;height=901" alt="Figure13" />
Once consumers share that financial data, maintaining access is often an exercise in setting it and forgetting it. Only 36% of consumers say they have actively revoked access to their data from organizations with which they have previously shared their data. Among younger generations, this number is higher &mdash; pointing to a clear need to prioritize privacy-first principles and value-add experiences for consumers over the long haul.
Figure 14. Have you ever actively revoked access to your data from an organization you&rsquo;ve previously shared your data with?
<img src="https://cms.mx.com/assets/a3f911c2-6e1f-4664-be28-9549ea19a748?width=1200&amp;height=759" alt="Figure14" />
Among those who have actively revoked access to their data, most did so simply because they stopped using the service.&nbsp;
Figure 15. What prompted you to revoke access to your data?&nbsp;
<img src="https://cms.mx.com/assets/56a1b33b-5892-4b99-b9fc-ce93e8773f50?width=1200&amp;height=884" alt="Figure15" />
As wary consumers become more willing to share their financial data, financial providers have an opportunity &mdash; and imperative &mdash; to earn the trust of consumers by putting that data into action to deliver better experiences, insights, and outcomes.&nbsp;
<h2>Consumers Are Ready to Ditch Bad Experiences</h2>
Slightly more than half of consumers (51%) say they have closed or switched a financial account. This is even higher among older generations &mdash;&nbsp;58% of Baby Boomers have closed or switched a financial account compared to 40% of Gen Z respondents. Top reasons why include:&nbsp;
Figure 16. What was your primary reason for switching or closing an account?
<img src="https://cms.mx.com/assets/1897c67a-e008-43e6-bbcc-4a7081c831f0?width=1200&amp;height=695" alt="Figure16" />
While only 1 in 10 consumers have closed an account because of bad customer service, research shows the majority of consumers have little patience or sub-par mobile experiences. Sixty-seven percent of consumers say they will stop using a mobile app if the experience changes for the worse.&nbsp;
<h2>Putting Data into Action: What This Means for Your Organization</h2>
Consumers want more simplicity &mdash;&nbsp;and are consolidating apps, accounts, and financial providers as a result. To ensure your organization remains in the mix, focus on delivering data-driven, personalized services, offers, and insights that keep consumers coming back.&nbsp;&nbsp;
Convenience trumps rewards, but rewards can open the door. While offering cash incentives and better rates can drive new account openings, the financial providers who make it simple and easy to use their accounts will have greater engagement in the long run.&nbsp;
Consumers expect financial providers to use their data to drive better outcomes for them. <a href="https://mx.com/research/financial-apps-fall-short/">Our previous research</a> shows most consumers would give their financial provider access to more of their data if they knew it would result in a better experience. However, many financial providers still struggle to leverage data effectively. In fact, 30% of consumers agreed they often see messages from their financial provider that are not personalized or relevant for them. And, less than half of consumers (42%) believe financial providers use their data only in ways that will benefit them.&nbsp;
To win and retain customers, it&rsquo;s all about the data. Financial providers who put the data consumers choose to share with them into action will drive stronger engagement, increased customer satisfaction, higher deposits, and establish long-term relationships.
Survey Methodology
This survey of 1,040 American adults was conducted by MX in April 2025 using an online survey platform. Results included an even split in responses across each generation, as well as gender (male and female) and White and non-White (Asian, Black, Hispanic, or Other) respondents.

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Cheat Codes for Driving Deposits and Achieving Top of Wallet Status

Turn Data into Growth

The vast array of financial service providers in the United States can make managing money difficult. Critical to navigating this complexity is the ability for consumers to bring together disparate financial data and gain insights and advice about their financial picture. Open Banking makes this possible by creating a secure, seamless way for consumers to access, manage, and share their financial data.&nbsp;
Existing regulations to guide Open Banking in the United States have seen much debate over the past year &mdash; leading the Consumer Financial Protection Bureau (CFPB) to issue a new Advance Notice of Proposed Rulemaking to re-evaluate critical questions within the final rule issued under Section 1033 of the Dodd-Frank Act.
At MX, we&rsquo;ve spent the last month unpacking these questions with policy experts and industry leaders. We believe&nbsp; any revisions to Rule 1033 should move the industry closer to the goal of giving consumers safe, seamless control of their financial data. Here are key takeaways from those conversations:
<h2>1. A Healthy Ecosystem is Essential </h2>
No single financial institution can meet every consumer or business need, and it&rsquo;s neither realistic nor secure for individuals to manually transfer their data between multiple providers. Third parties &mdash; such as fintechs, data intermediaries, and other authorized representatives &mdash; are critical to enabling a healthy flow of data and creating a modern, innovative financial ecosystem.
Consumers deserve a system that reflects the digital world they live in and allows them to authorize trusted representatives to move their data securely and seamlessly. Third parties expand access, enable specialized services, and deliver capabilities that no single institution could provide on its own. 
<h2>2. Open Banking is Bi-Directional</h2>
The financial services ecosystem is complex, and Open Banking is not a one-way flow of data. As Jane Barratt, MX Chief Advocacy Officer and Head of Global Public Policy, explained:
<blockquote>
&ldquo;There has been this binary view that financial institutions are the data providers and fintechs are the data recipients. That is one of the biggest things we need to change perception of because data is bi-directional. &hellip; At MX, our biggest use case is bank-to-bank or bank-to-credit union or credit union-to-bank again. People have multiple relationships.&rdquo;
</blockquote>
Enabling secure, scalable data sharing both to and from institutions is essential for a thriving ecosystem. It gives consumers more control and flexibility, while financial institutions benefit from incoming data that improves decision making, service personalization, and innovation.
<h2>3. Defining &ldquo;Representative&rdquo; Defines the Market</h2>
How the CFPB chooses to interpret and define a &ldquo;representative&rdquo; under Section 1033 will have far-reaching implications for the financial services ecosystem.&nbsp;
A narrow definition (i.e., limited to certain agents or intermediaries) could unintentionally stifle competition, reinforce data monopolies, and drive up costs for smaller institutions, fintechs, and consumers. When only a few entities are authorized to access consumer data, smaller players are pushed out and innovation slows down.
Conversely, a more inclusive definition supports a more balanced and competitive environment. Consumers own their data and should be able to choose who they authorize to access it. Recognizing a wider range of authorized third parties fosters a thriving ecosystem, encourages diverse solutions, and lowers costs for consumers and innovators alike.&nbsp;
Ultimately, how &ldquo;representative&rdquo; is defined will determine how easily data flows and how much choice consumers have in the marketplace. Permissioned third parties should be considered representatives in order to enable consumers to truly own and manage their data.
<h2>4. The Current Rule Provides a Strong Start for Privacy, Consent, and Control</h2>
The CFPB&rsquo;s current rule represents a meaningful step forward in consumer privacy and data rights. It helps bridge the long-standing regulatory gap between banks and fintechs by introducing modern privacy principles like opt-in consent, consumer authorization, and greater control over personal data.
Still, key questions remain. There is opportunity to create more clarity around liability and risk management responsibilities and align secondary data use cases more closely with contemporary privacy networks. With refinement, future iterations of the rule can strengthen trust while supporting innovation.
<h2>5. API-Based Open Banking is the Solution, Not the Problem</h2>
Many of today&rsquo;s security and fraud challenges stem from outdated, credential-based methods like screen scraping. Open Banking APIs solve this by enabling secure, tokenized data sharing. Consumers never have to share their credentials, making the process auditable, standardized, and significantly safer.
While API development can be a lift for smaller institutions, the benefits are clear: reduced fraud risk, fewer technical failures, and a stronger foundation for interoperability and trust. API-based access is not only more secure, it&rsquo;s the infrastructure on which true Open Banking depends.
<h2>6. Fees and Standards Go Hand in Hand</h2>
Standards are the foundation of a scalable, competitive open banking ecosystem. The Financial Data Exchange (FDX) has emerged as a leading industry standard in the U.S., helping prevent fragmentation by establishing consistent technical and security protocols for data sharing.&nbsp;
Without such standards, each financial institution could define data access terms or &ldquo;reasonable fees&rdquo; differently, creating inefficiencies and uneven access. In addition, the current rule expressly prohibits fees. Charging fees under Rule 1033 is illegal. Full stop.
While standards don&rsquo;t dictate pricing, they directly influence it. A consistent baseline enables transparency and fairness in how fees are structured and applied. Lessons from the UK &mdash; where regulators have introduced &ldquo;premium API&rdquo; frameworks that allow enhanced paid services beyond core open banking functions &mdash; show how alignment between standards and pricing can balance innovation and sustainability.&nbsp;
Active participation from fintechs and financial institutions in standard-setting and regulatory development will ensure that resulting frameworks are fair, interoperable, and representative of the full ecosystem.
<h2>7. Customer-Centricity Should be the Driving Force</h2>
At its core, the debate surrounding Section 1033 isn&rsquo;t about banks, fintechs, or regulators &mdash; it&rsquo;s about people. The ANPR asks who should act as a &ldquo;representative,&rdquo; whether fees can be assessed, what data can be shared, and how that data must be protected.
Each of these questions ultimately comes back to consumer empowerment and enabling people to&nbsp; access, understand, and use their own financial data. The best path forward will be the one that upholds transparency, choice, and consumer benefit above all else.
<h2>8. Open Banking is Here to Stay</h2>
Consumer demand, market innovation, and regulatory momentum have converged around a shared principle: people should be able to securely access and share their own financial data. Though the CFPB is reevaluating parts of Rule 1033, Open Banking in the U.S. will continue to gain adoption &mdash; fostering a competitive environment where those who prioritize secure access, transparency, and consumer control will be best positioned to thrive. Those who choose a &ldquo;wait and see&rdquo; approach to Open Banking will be left behind.
<h2>The Revised Rule is Just the Beginning</h2>
Wide scale adoption of Open Banking won&rsquo;t be achieved through policy changes alone. It requires ongoing collaboration between regulators, financial institutions, fintechs, third parties, and consumers &mdash; each contributing to a secure, inclusive, and innovative financial ecosystem. The CFPB&rsquo;s Rule 1033 is a strong starting point, but it&rsquo;s only the beginning of a broader effort to build a financial system that works for everyone.

The CFPB issued a new ANPR to re-evaluate the final Section 1033 rule. At MX, we’ve unpacked key questions with policy experts and industry leaders.

CFPB's Section 1033 Reopened | Key Takeaways from MX

MX recently submitted a comment letter to the CFPB in response to its new ANPR regarding its reconsideration of Section 1033. 

MX’s CFPB comment letter dives into benefits of Open Banking for the entire ecosystem, as well perspectives on key questions raised and areas of consideration. 

Charting the Path Forward for Open Banking | ANPR 1033 Comments

MX recently submitted a new comment letter to the Consumer Financial Protection Bureau in response to its new advanced notice of proposed rulemaking regarding its reconsideration of Section 1033 of the Dodd-Frank Act on personal financial data rights. In our response, we continue to advocate for secure, permissioned data sharing that drives consumer-centric innovation forward for our clients, consumers, and the broader financial services industry.
As the CFPB evaluates the nearly 14,000 comment letters received, we believe this is a pivotal moment for the U.S. financial services industry. Preserving key elements of the current 1033 Rule is necessary to foster a more competitive and consumer-centric ecosystem.&nbsp;
The U.S. financial system can be complex and difficult for many Americans to navigate, compounded by the fact that the <a href="https://www.mx.com/research/how-to-keep-consumers-from-breaking-up-with-banks/">average consumer has at least 5-7 financial accounts</a> across multiple different providers. Without access to, and a unified view of, their financial information, it becomes nearly impossible for consumers to make truly informed financial decisions.&nbsp;
Consumers need access to digital financial technology that will bring disparate financial information together and provide the tools and insights needed to effectively understand their finances and make informed financial decisions.&nbsp;
Open Banking is the key to promoting innovation, increasing competition, and ultimately empowering consumers. And, it&rsquo;s not just consumers who benefit from Open Banking. Banks, credit unions, fintechs, and all data providers benefit from Open Banking, such as:&nbsp;
<ul>
<li style="font-weight: 400;" aria-level="1">Reducing potential exposure or misuse of consumer login credentials and associated fraud costs by moving from screen scraping to token-based API access for authorized third parties</li>
<li style="font-weight: 400;" aria-level="1">Gaining insight into which authorized third parties are accessing consumer-permissioned data through an API, which enables both enhanced security controls and intelligence into areas where the data provider could create better experiences for consumers.</li>
<li style="font-weight: 400;" aria-level="1">Enhancing overall data protections and liability exposure by requiring the execution of bilateral agreements with authorized third parties as a pre-requisite to providing data access, which establishes clear access, security, and liability parameters</li>
</ul>
Our comment letter dives into the benefits of Open Banking for the entire ecosystem, as well as our perspectives on key questions raised by the CFPB and areas of consideration. These key questions and areas of additional consideration include: 
<h2>1. Data Access Fees</h2>
We strongly support the existing PFDR Rule&rsquo;s prohibition on <a href="https://www.mx.com/webinars/data-access-fees-impact/">fees for data access</a>. A fee for access fundamentally contradicts the nature of a right. A consumer&rsquo;s financial data belongs to the consumer, and financial institutions are merely the custodians of that information. Allowing financial institutions to charge fees would not only obstruct a consumer&rsquo;s right to their own data, but also create an anti-competitive environment where some large banks could use fees as a gatekeeping mechanism to stifle innovation and crush smaller players in the market. 
<h2>2. Defining Consumer &ldquo;Representatives&rdquo;</h2>
How &ldquo;representative&rdquo; is defined will determine how easily data flows and how much choice consumers have in the marketplace. <a href="https://www.mx.com/webinars/defining-role-consumer-representatives/">Permissioned third parties should be considered representatives</a> in order to enable consumers to truly own and manage their data.&nbsp;
Limiting the definition of &ldquo;representative&rdquo; would hinder the consumer&rsquo;s ability to choose and work with their preferred financial technology or other third-party service provider, or potentially eliminate the consumer&rsquo;s choice altogether if those third parties cannot adequately compete without necessary access to data.
<h2>3. The Secondary Use of Data</h2>
The rule limits the collection, use, and retention of covered data to what is "reasonably necessary" to provide the consumer's requested product or service, even where broader use may ultimately benefit the consumer without any sale of covered data. We believe this interpretation is too narrow, which could prevent more tailored and beneficial financial products being offered to consumers.&nbsp;
If a consumer gives informed consent, they should be able to authorize uses of their data that add value for them. For example, these beneficial use cases can unlock a range of powerful benefits for consumers:
<ul>
<li style="font-weight: 400;" aria-level="1">Fraud prevention and product improvements: By analyzing a consumer's entire financial footprint, banks can more effectively detect and prevent fraud. And, data analysis helps companies improve the design and functionality of their financial products, making them more user-friendly and secure.</li>
<li style="font-weight: 400;" aria-level="1">Better, more tailored offers: Companies can use transaction data and spending patterns to create personalized credit card and loan offers, rewards programs, payroll deposit switching, and other financial management tools that are more relevant to a person's lifestyle.&nbsp;</li>
<li style="font-weight: 400;" aria-level="1">Public interest uses:Anonymized and aggregated data can be used by researchers to analyze economic trends, inform public policy decisions, and improve access to the financial system by helping lenders build more complete credit profiles for consumers with thin credit histories.&nbsp;</li>
</ul>
<h2>4. Re-authorization Requirements</h2>
The current rule requires third-party data recipients to obtain a new authorization from a consumer at least once every 12 months to continue collecting data. This creates an unnecessary and burdensome administrative hurdle to the detriment of consumers and service providers alike. It could also disrupt the continuous services provided by third parties, such as long-term financial planning, budgeting and tax tools, or fraud monitoring, which rely on a consistent flow of updated data.&nbsp;
<h2>The Road Ahead</h2>
As we&rsquo;ve said before, consumer demand, market innovation, and regulatory momentum have converged around a shared principle: <a href="https://www.mx.com/1033-reopened/">people should be able to securely access and share their own financial data</a>. Though the CFPB is reevaluating parts of Rule 1033, the current PFDR Rule takes a significant step in the right direction by ensuring permissioned data sharing is a statutory right for consumers.&nbsp;
The stakes are incredibly high. In addition to the ANPR, the U.S. District Court for the Eastern District of Kentucky issued a ruling to <a href="https://www.pymnts.com/bank-regulation/2025/court-halts-cfpbs-open-banking-rule-as-banks-fintechs-await-rewrite/">halt the CFPB from enforcing Rule 1033 until the Bureau completes its ongoing reconsideration</a>. This could further disrupt the timeline for Open Banking implementation and lead to additional activities by Congress, federal and state regulators, and the broader industry. The CFPB&rsquo;s reconsideration of key parts of Rule 1033 will determine how competitive and consumer-centric the financial services industry in the United States is going forward. Speed and clarity are of the essence.&nbsp;
We look forward to further collaboration across the ecosystem to foster innovation, protect consumers, and ensure the continued growth of the U.S. Open Banking market.&nbsp; Regardless of what happens, MX remains committed to ensuring that secure and permissioned data access continues to drive innovation forward and deliver positive outcomes for consumers and businesses.

Another Fork in the Road for the Future of Open Banking

The Future of Open Banking

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The first internet native generation, full of crazy new slang and big ideas about how they want the world to change. And, that desired change is reflected in the impact they are having on the financial industry.

Gen Z’s modus operandi (MO) is a digital-first, app-heavy, dynamic approach that asks financial providers to leverage their financial data for better outcomes and help in building their financial health.

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Consumers Expectations Drive the Future of U.S. Open Banking

As policy and industry leaders continue to debate how Open Banking should take hold in the U.S., consumers already live in an open finance world. Through budgeting apps, loan applications, investment tools, payment platforms, and more, the majority of Americans already use services powered by data sharing, even if they don&rsquo;t realize it.
According to<a href="https://www.mx.com/research/crossing-the-chasm-consumer-demand-mobile-experiences/"> MX&rsquo;s latest consumer research</a>, adoption and awareness of Open Banking are both growing. Among Gen Z and Millennials in particular, familiarity is quickly rising. This signals that younger generations not only know about data connectivity, but expect it as part of modern financial life.
<h3>The Demand for Financial Freedom</h3>
At its core, Open Banking isn&rsquo;t just about access, it&rsquo;s about freedom. Freedom to connect accounts, to view finances holistically, to shop around for the best financial products, and to use the tools that best serve individual needs.&nbsp;
In our latest survey of 1,000+ U.S. adults, 44% of consumers said the ability for them to share their own financial data with third-party providers to get better experiences and services is important. That number climbs dramatically for Gen Z (64%) and Millennials (66%), underscoring the future of Open Banking.
But, even among more cautious consumers, attitudes are shifting. Nearly 6 in 10 (59%) now say they&rsquo;re willing to share their financial data as long as they trust it&rsquo;s securely protected &mdash; up ten points from just a year ago.&nbsp;
<h3>The Expectation for Connected Accounts</h3>
Today, 82% of U.S. adults say they expect to be able to see all of their financial data in one place. This growing demand reflects a broader shift in consumer mindset: financial connectivity is no longer a luxury, it&rsquo;s a necessity.&nbsp;
People want the ability to create a unified view of their financial world, from checking and savings accounts to credit cards, loans, and investments. They want personalization, simplicity, and control &mdash; all powered by secure data sharing.
As these expectations increase, Open Banking has become the foundation of a modern financial ecosystem. For financial providers, the message is clear: enabling secure data connectivity isn&rsquo;t optional anymore. It&rsquo;s what consumers already assume you&rsquo;ll deliver.
<h3>The Cost of Restriction</h3>
Still, the path forward isn&rsquo;t without friction. One key point of discussion in the industry has been if fees for data access should be allowed. However, doing so would likely introduce added complexity and downstream costs for consumers for what many now see as a basic right &mdash;&nbsp;to connect your own financial data to the third parties and services you choose.&nbsp;
Nearly half (48%) of consumers say they would be unlikely to connect external financial accounts to their primary bank if it came with a fee, and that reluctance spikes among older generations. The willingness to pay, where it exists, is highest among Millennials, but even then, cost sensitivity remains high.
Introducing fees or blocking data connections doesn&rsquo;t just threaten innovation, it threatens consumer trust. Our research found that more than 4 in 10 U.S. adults would be likely to stop using a financial provider that restricted their ability to share data with a trusted third party. That&rsquo;s not a small risk &mdash; it&rsquo;s a warning signal.
<h3>Open Finance Is the Future &mdash; and Consumers Know It</h3>
The evolution of Open Banking from innovation to expectation is well underway. Consumers no longer simply want access to their banking data. They want seamless control over their financial lives and actionable insights based on their permissioned financial data to help them achieve their goals.
Financial institutions that lean into openness and transparency won&rsquo;t just meet consumer expectations, they&rsquo;ll earn their loyalty. Those that resist &mdash;&nbsp;or are slow to embrace Open Banking &mdash; may soon find themselves left behind.

Open Banking No Longer Optional for Consumers

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There are several ways that financial institutions and fintechs can enable consumers to link their financial accounts today. But, as we shared before, not all connectivity experiences are created equal.&nbsp;
<h2>Understanding Connectivity Methods</h2>
<img src="https://cms.mx.com/assets/b88b8caf-f896-43ee-bdc3-68d785682257?width=1200&amp;height=245" alt="Connectivity Methods" />
Here&rsquo;s an overview of the primary connectivity methods used today for data sharing and account aggregation:&nbsp;
<h3>1. Screen Scraping</h3>
Screen scraping, or credential sharing, is the process of gathering data from one app by inputting user credentials (such as username and password) and displaying that data in another app. Screen scraping requires consumers to share their username and password with the data recipient to gain access to their data.&nbsp;
The biggest downside to screen scraping is that the process relies on the other institution&rsquo;s website structure, which becomes problematic when scraping happens without coordination with that financial institution. This means organizations are constantly fixing connectivity issues resulting from web updates, changes in login procedures, etc.&nbsp;
Connections also break every time a consumer updates their username or password. It also means that website downtime results in loss of connectivity. In addition, screen scraping results in slower connections compared to APIs.
On the other hand, the financial institutions who have data being scraped don&rsquo;t always know who is capturing their data and for what purpose. And, it creates added risk for both the institution and consumer as credentials are freely shared with third parties. Scraping can also make it really difficult to decipher the difference between permissioned activity and possible malicious activity.&nbsp;
<h3>2. Whitelisted IPs</h3>
Whitelisting IP addresses is still a form of screen scraping. However, instead of allowing any app to scrape data, this method allows a financial institution to &ldquo;whitelist&rdquo; known third parties and sanction data sharing with those specific IP addresses.&nbsp;
While the downsides of screen scraping remain, whitelisted IPs does eliminate some risk but ensuring only trusted sources can access data and preventing access from unknown scraping sources.
<h3>3. Banking APIs</h3>
Banking application programming interfaces (APIs) are the next evolution in enabling reliable connections for consumers to link their accounts from third parties. While banking APIs still rely on consumers to input their username and password to create the connection, data sharing is enabled via an API versus screen scraping.&nbsp;
This creates a more reliable connection because an API doesn&rsquo;t rely on the other institution&rsquo;s website structure. Connections no longer break any time the other institution makes a change to its login procedures or updates its system. However, connections will still need to be re-established any time a consumer changes their username or password. And, the risk of sharing credentials with a third party remains. 
<h3>4. OAuth APIs</h3>
OAuth APIs, sometimes referred to as an open banking or open finance API, allow consumers to access their transaction data without the need to share usernames and passwords. Instead of asking a consumer to input their username and password, the consumer is redirected to the other institution to log in directly to its system. Then, a token is created and passed back to the third party to establish a connection and enable data access.&nbsp;
This creates the most secure experience for consumers and institutions because it eliminates any credential sharing with third parties. In addition, it clears a more reliable connection as consumers will not need to re-authenticate every time they change their password or when system changes occur.&nbsp;
Finally, OAuth API connections also help financial institutions get ahead of upcoming compliance regulations related to the final rule from the Consumer Financial Protection Bureau (CFPB) under <a href="https://www.mx.com/whitepapers/mx-perspective-on-consumer-data-rights-rulemaking/">Section 1033 of the Dodd-Frank Act</a>. Currently, the CFPB&rsquo;s proposed rule would &ldquo;prevent data providers from relying on screen scraping to comply with the proposal because it is not a viable long-term method of access.&rdquo; Instead, the CFPB will require data providers to establish and maintain a developer interface that makes data available in a machine-readable, standardized format and doesn&rsquo;t allow a third party to access the system using consumer credentials.&nbsp;
The downside to OAuth APIs? Standing up an open finance API can be an expensive and time consuming process. For example, the <a href="https://files.consumerfinance.gov/f/documents/cfpb-1033-nprm-fr-notice_2023-10.pdf">CFPB estimates</a> a &ldquo;total upfront cost of $250,000 to $500,000 for small depository data providers that choose to build their developer interface in-house&rdquo; &mdash; with &ldquo;ongoing annual technology costs of $20,000, as well as ongoing staffing costs of $45,000 to $91,000.&rdquo;&nbsp;
Choosing to build or buy a solution will be a key decision point for financial institutions who don&rsquo;t yet have an open finance API. MX&rsquo;s Data Access platform can enable institutions to deliver a safe and secure connectivity experience for their customers &mdash; and helps financial providers get ready for potential requirements under Section 1033 rulemaking.
<h2>How MX&rsquo;s Data Access Solution Powers Open Finance</h2>
At MX, our solutions and products are built with consumer-permissioned data sharing at the forefront. And, we make it easy for financial institutions of all sizes to accelerate open finance adoption and enhance the money experience for consumers through our Data Access product.&nbsp;
Data Access enables financial institutions to more easily create or evolve their open finance APIs to ensure they meet FDX standards, deliver the required data elements, and follow authentication protocols, such as OAuth and OIDC. In addition, Data Access is interoperable across all intermediaries, enabling financial providers to accelerate their path to eliminate screen scraping from their environment.&nbsp;
Data Access also creates better visibility into the open finance journey by providing real-time performance metrics, insights into data sharing activity, and support tools to easily manage and maintain connections. For instance, Data Access&rsquo;s API Overview and Test Users feature takes the guesswork out of understanding what data needs to be included in open finance APIs. Financial providers can access &mdash; per use case and account type &mdash; which data fields are required and under what conditions. And with our Test Users feature, data providers and data recipients can test the APIs before they go live to ensure that all required data is there.&nbsp;
For consumers, Data Access&rsquo;s Consent Management Dashboard can be easily embedded into mobile and online banking portals so that consumers can see and manage where they have shared their financial data with a third party. Consumers can view when their data was last updated or revoke data sharing access with a third party.&nbsp;
<blockquote>
Want to learn more about how Data Access helps financial providers get ready for regulatory obligations? <a href="https://www.mx.com/whitepapers/how-data-access-supports-1033/" target="_blank" rel="noopener">Read our whitepaper</a>.
</blockquote>
<img src="https://cms.mx.com/assets/211e228a-1bdc-4382-b045-b329a36aea1c?width=1200&amp;height=1187" alt="Data Access" />
<h2>Setting the Standard &mdash; FDX</h2>
In June 2024, the <a href="https://www.consumerfinance.gov/about-us/newsroom/cfpb-launches-process-to-recognize-open-banking-standards/">CFPB took the next step</a> toward recognizing industry standards-setting bodies as part of its Section 1033 rule making to establish consumer financial data rights in the United States. The CFPB&rsquo;s rule identifies the attributes that standard setting bodies must demonstrate in order to be recognized, as well as a step-by-step guide for how standard setters can apply for recognition.
Recognizing industry standards is crucial to moving the industry forward with Open Finance, and literally setting the standard for secure consumer-permissioned data sharing. Across the industry, the <a href="https://financialdataexchange.org/">Financial Data Exchange</a> (FDX) has already driven strong adoption of open finance with 76 million consumer accounts transitioned from sharing data via screen scraping to the FDX API as of April 2024.&nbsp;
<img src="https://cms.mx.com/assets/1225b519-9cb5-4b58-938e-6aaa28fe949a?width=600&amp;height=345" alt="Fdx" />
FDX is a non-profit, industry standards body dedicated to unifying the financial services ecosystem around common, interoperable, and royalty-free technical standards for user-permissioned financial data sharing. Any company within the financial industry can contribute to the development, growth, and adoption of the FDX API and other objectives. MX continues to be a driving force at FDX by chairing and collaborating in key task forces and representing fintechs on the FDX Board of Directors.&nbsp;
It&rsquo;s great to see the CFPB listening to industry feedback and moving forward on SSOs in advance of the final Section 1033 rule. This will help ensure little disruption to the data sharing environment and avoid delays in the industry&rsquo;s ability to implement this rule. We&rsquo;re excited to continue working with organizations like FDX on accelerating a truly open financial ecosystem.&nbsp;

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