Section 1033 Compliance Date Further Delayed
We’ve previously discussed the fact that the CFPB plans to reconsider the Final Rule to implement Section 1033 (Personal Financial Data Rights) of The Dodd-Frank Act. Compliance was initially going to be mandatory beginning on April 1, 2026, for some institutions, but a court order previously delayed those timeframes. In its Spring 2025 Rulemaking Agenda, the CFPB anticipated issuing a proposed rule for the Section 1033 requirements by the end of December. While that could still happen, the U.S. District Court for the Eastern District of Kentucky recently issued an injunction that prohibits the CFPB from enforcing the Rule ...until it has completed its reconsideration of the Rule. It was noted that:
It is unlikely that the CFPB will issue a new rule before that (first compliance) date, and it remains unclear whether or when the CFPB will extend the compliance deadlines…. Ultimately, the CFPB is currently engaged in rulemaking to reconsider the Rule considering the plaintiffs’ concerns about its lawfulness. Nevertheless, the plaintiffs and their members are being compelled to incur expenses that would be unrecoverable and unnecessary if the new rule substantially revises the existing requirements or if the current Rule is vacated. Under these unique circumstances, and to preserve the status quo while the CFPB completes its rulemaking process, the plaintiffs’ motion for preliminary injunction will be granted.
So, stay tuned!
Published
2025/11/10
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!