Defining the Role of Consumer Representatives

The CFPB’s new ANPR on Section 1033 asks a critical question that will shape the future of Open Banking — should representatives be included in the definition of “consumer”?

Today, Section 1033 defines a “consumer” as an individual or an agent, trustee, or representative acting on behalf of an individual. Now, the CFPB seeks to confirm and clarify the role of “representatives” and whether consumer-permissioned, secure access by third parties on behalf of consumers will be recognized.

Join us for our next virtual discussion where we’ll break down what’s at stake, why this definition matters for the future of data access and consumer empowerment, and how your institution can prepare to navigate the path forward.

What we'll cover:

• The implications of redefining “consumer” for financial institutions, fintechs, and regulators.
• Why recognizing third-party “representatives” is essential for secure, permissioned access — and what “representatives” should include.
• Opportunities to influence the rulemaking process through industry engagement.