BankerCollege

We have been hearing the rumblings about the CFPB’s Section 1033 of the Dodd-Frak Act for some time, but do we fully understand the impact to our customer data, the expectations of information security and the continued emphasis on vendor due diligence? 

Banks, as covered data providers, will need to have compliance procedures around responding to requests from consumers making their “covered data” available to them in electronic format. We will talk about the machine-readable requirements and the adventures of working with other providers. 

There will be many opportunities for banks to take advantage of this new world of data sharing and just being compliant would be a shortcoming if banks do not also take advantage of the new opportunities to help provide better services and products in this new world.

This session will address these issues and help you to more thoughtfully plan out your attack as the due dates roll closer. 

Topics include: 

• We will discuss API Enablement and whether your organization already has these in place or if this is something that you want to engage in for your customers to provide better services and access to their accounts. We will discuss how to monitor and report the performance and 
• Third Party Risk Management-How will you risk rate and evaluate third-party data recipients to make sure they meet your minimum security and compliance standards? This has become an evergreen topic with the regulators, but when dealing with customer data in an even more expanded and potentially risky arena such as providing the data to approved third parties, this is a must.
• Operations & Processes-What are the types of changes you will need to make with your current operational processes to synch with the regulatory requirements? You will need to decide what experience you want to offer your customers. Will the bank always be the data provider, or will it sometimes be the  data aggregator?
• FDX-What is it and how will it help you to understand the new arena that banks will be forced to be a part of? There are many resources available, and this organization has taken the lead in helping to provide a uniform framework for all the players in this new functionality. 

Take-aways

1. 3 key things to keep in mind as you develop your Open Banking Compliance Program:
   1. Customer information security- How will you make sure that your program and the sharing of your customer data will be at the security levels required?
   2. Don’t be afraid of APIs- This is how the finance world now turns. Embrace it and become part of the solution instead of just continuing along the same path.
   3. Vendor due diligence- We will address the different levels of standards that are required, even if the regulators have not specifically spelled them out.