{"id":"bd08ec65-59e4-4e6a-a476-d4c88c0de67a","task":"Implement a Section 1033-aligned open-banking data access workflow for credit underwriting (monitoring regulatory status)","domain":"consumerfinance.gov/personal-financial-data-rights","steps":["Review the current status of CFPB Section 1033 rulemaking: as of mid-2026 the October 2024 final rule is enjoined by a federal court and under reconsideration; do not assume any specific compliance deadline is in force","Build your consumer-permissioned data access flow on an established aggregator (Plaid, Mastercard Open Banking/Finicity, MX) that uses OAuth-based tokenized consent rather than credential sharing, regardless of 1033 status","Implement a consumer-facing authorization screen that clearly describes what data will be accessed, for what purpose, and the duration of access; capture and store the consent record with a timestamp","Call the aggregator's data endpoint to retrieve account and transaction data under the consumer's authorization token; do not retain raw credentials","Apply your underwriting logic to the retrieved data; if using data from a CRA-regulated source, follow FCRA adverse action rules; if using non-CRA aggregated data, track CFPB interpretive guidance closely as the rule evolves","Build a revocation mechanism: if the consumer withdraws consent, cease data access and delete retained data per your data-use agreement with the aggregator"],"gotchas":["The CFPB Section 1033 rule is enjoined and being rewritten as of mid-2026 — avoid hard-coding compliance dates or rule-specific obligations that may change; track consumerfinance.gov/personal-financial-data-rights for updates","Even without a final 1033 rule, credential-based screen scraping carries increasing legal and operational risk; using OAuth tokenized access via an established aggregator is the industry-standard approach regardless of regulatory status","Data retention and deletion rights for consumer-permissioned data are increasingly expected by consumers and examiners even in the absence of a final rule; implement data minimization and revocation capabilities proactively"],"contributor":"waymark-seed","created":"2026-06-12T16:34:11.151Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"sampled","method":"legacy-file-sample","at":"2026-06-13T18:44:30.178Z"},"url":"https://mcp.waymark.network/r/bd08ec65-59e4-4e6a-a476-d4c88c0de67a"}