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In the United States, a bank cannot treat your entire customer file as freely shareable. The CFPB’s Personal Financial Data Rights Rule (Regulation 1033, implementing Section 1033 of the Consumer Financial Protection Act) identifies specific financial data that a covered provider must make available electronically when you request a service from an authorized third party. The provider and the recipient then have different, continuing duties.
Your authorization does not make the receiving company free to sell, advertise with, or keep the data indefinitely. The bank is responsible for its data-provider and interface obligations; the authorized third party is responsible for informed consent, limited collection and retention, security, and controls on onward sharing. The current implementation timetable is unsettled because the CFPB reports that a federal court stayed the rule’s compliance dates on October 29, 2025.
The short answer: controlled access, not a blank-check data sale
When you connect a budgeting, payment, lending, or other financial app to a bank account, the legal model is generally permissioned access for a requested product or service. Under 12 CFR § 1033.201, a covered data provider must make covered data in its control or possession available to the consumer and an authorized third party, on request, in an electronic form usable by both.
That obligation is narrower than “the bank may share anything it knows about me.” The regulation lists the data categories, sets exceptions, requires a specific authorization disclosure, and limits what the recipient may collect, use, retain, or pass to another company. A bank’s privacy notice, your account contract, state privacy law, and other federal rules can add requirements; Regulation 1033 is not the only rule that may apply.
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“A data provider must make available to a consumer and an authorized third party, upon request, covered data in the data provider’s control or possession concerning a covered consumer financial product or service that the consumer obtained from the data provider, in an electronic form usable by consumers and authorized third parties.”
This sentence appears in the CFPB’s final regulation at 12 CFR § 1033.201(a)(1). It describes an access right with conditions, not a general permission to commercialize every bank record.
What bank data is covered?
For a covered consumer financial product or service, 12 CFR § 1033.211 identifies these categories, as applicable to the account.
| Covered category | Examples in the rule | Important qualification |
|---|---|---|
| Transaction information | Historical transactions, amount, date, payment type, status, merchant or payee, rewards credits, fees, and finance charges | At least 24 months of transaction history is sufficient for the rule’s historical-data requirement; it does not mean every older record must be supplied. |
| Account balance | Current balance and other balance information held for the product | The provider supplies information it controls or possesses and can make available through the required interface. |
| Payment-initiation information | Information needed to initiate a payment to or from a qualifying Regulation E account, potentially including account and routing numbers | A tokenized account number is permitted when the regulation’s stated conditions are met. |
| Product terms and conditions | Fees, APR or APY, credit limit, rewards terms, overdraft opt-in status, and arbitration terms | These are the legal terms for the covered financial product, not every internal bank document. |
| Upcoming bill information | Scheduled third-party bill payments and upcoming amounts due to the provider | Only the bill information covered by the regulation and held by the provider is included. |
| Limited basic verification information | Associated name, address, email address, phone number, plus a truncated account number or another identifier in specified circumstances | This is a limited identity-and-account check, not unrestricted access to a full customer profile. |
The 24-month figure is a sufficiency standard in the 2024 final rule, not a promise that every institution has identical historical systems or that a third party may demand unrelated records. The exact fields available can also depend on the account type and the provider’s ordinary records.
What the bank does not have to release
The rule does not convert all information held by a bank into covered data. Under 12 CFR § 1033.221, exclusions include:
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- Confidential commercial information.
- Information collected solely to prevent or detect fraud or money laundering, or to report unlawful conduct.
- Information another law requires to remain confidential.
- Information the provider cannot retrieve in the ordinary course of business.
The confidential-information exception does not automatically shield ordinary consumer information merely because the bank must protect it under a privacy or security rule. A provider must identify a genuine regulatory exception rather than labeling routine account data “confidential” simply to avoid an access request.
How an app or other third party obtains access
A third party must be acting for a service you requested. The consent flow is supposed to tell you who is requesting access, what it wants, and how long access will last before the provider releases covered data.
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- You select a requested service. The company must seek access on your behalf for a product or service you asked it to provide, rather than obtaining data for an unrelated purpose.
- The company gives an authorization disclosure. Under 12 CFR § 1033.401, the disclosure must identify the third party and the data provider, describe the requested service and data categories, explain the expected collection duration and how to revoke access, and include the required certification of its obligations.
- You give express, informed consent. 12 CFR § 1033.411 requires a signed electronic or written authorization. A prechecked box or vague statement that “partners may receive information” is not the same as the specified authorization for the service.
- The provider makes the covered data available electronically. The bank or other data provider uses its required consumer-and-developer interface, subject to the regulation’s security and risk provisions.
- You can revoke access. The disclosure must explain the revocation method. Revocation stops future authorized collection under the rule; it does not by itself erase data that another law, contract, or a documented legal obligation permits the recipient to retain.
Read the data categories and duration as carefully as the name of the app. An authorization for balances and transactions is materially different from one that also permits payment initiation or access to account and routing information.
Who is responsible for protecting the information?
Responsibility follows the role each participant performs. The bank remains accountable for duties attached to being the data provider, while the receiving company has independent obligations after it obtains the information.
| Participant | Core responsibilities under Regulation 1033 | What this does not mean |
|---|---|---|
| Bank or other data provider | Make covered data in its control or possession available in a usable electronic form; operate an appropriately secure interface; follow the rule’s access, performance, and risk-management requirements. | The bank is not automatically responsible for every later use or security incident at an independent recipient. |
| Authorized third party | Obtain the required informed authorization; limit collection, use, and retention to what is reasonably necessary for the requested service; protect the data; and impose required obligations on onward recipients. | Your consent does not excuse the company from security, minimization, retention, or redisclosure restrictions. |
| Data aggregator | It may perform authorization procedures for the authorized third party, must be identified in the consumer disclosure, describe its services, and certify compliance before accessing data. | Using an aggregator does not transfer the authorized third party’s compliance responsibility away from that third party. |
| Consumer | Choose whether to authorize, review the scope and duration, monitor connected services, and use the stated revocation process when access is no longer wanted. | A consumer’s decision to connect an app does not waive the recipient’s legal duties. |
The rule therefore creates shared, role-based responsibility. It does not establish that the bank alone protects the data after transmission, nor does it make an app solely liable for every event involving the bank’s systems. The legal result of a particular breach or dispute can also depend on contracts, other federal requirements, state law, and the facts.
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Limits on what the receiving company may do
12 CFR § 1033.421 requires an authorized third party to limit collection, use, and retention to what is reasonably necessary to provide the product or service you requested. The regulation expressly identifies targeted advertising, cross-selling, and selling covered data as purposes that are not reasonably necessary for that service.
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Collection is generally capped at one year from the most recent authorization unless you reauthorize. A company cannot treat one old click as perpetual permission. If the service continues, the company must follow the rule’s reauthorization requirements rather than silently extending the original period.
Use and retention
Data may be handled for the requested function and for activities reasonably necessary to deliver it, but the recipient must not expand the authorization into unrelated advertising or data sales. The one-year collection limit is not a universal deletion deadline: retention can still be affected by another law, a legal obligation, or a contract, while the recipient remains bound by the rule’s limits on use.
Onward sharing
Before providing covered data to another recipient, the authorized third party must contractually require that recipient to meet specified obligations. An additional vendor, processor, or service provider is therefore not outside the compliance chain simply because it did not receive your original click directly.
Security program
The recipient must apply the applicable Gramm-Leach-Bliley Act (GLBA) information-security program. If it is not subject to GLBA section 501, the regulation points to the information-security program identified by the FTC Safeguards Rule. Security is an ongoing obligation covering the data the company handles, not a one-time promise displayed during account linking.
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What the bank’s interface must do
The provider’s interface is part of its legal responsibility. Third parties generally may not use your ordinary online-banking username and password to reach the provider’s developer interface; 12 CFR § 1033.311 prohibits that practice, subject to the text’s stated service-provider provision.
The rule also contains a performance measure: at least 99.5 percent proper interface responses per calendar month, calculated under the regulation’s rules and with scheduled downtime treated as specified there. This is a regulatory minimum for the interface, not a guarantee that every connection will work every time or that an app’s own systems will be available.
A provider may deny or restrict access in certain risk-based circumstances. Under 12 CFR § 1033.321, the denial must be tied to applicable safety-and-soundness, security, or other risk-management requirements and satisfy the rule’s reasonableness conditions. A generic refusal to support all third-party access is not the same as a documented, rule-compliant risk decision.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How GLBA privacy notices fit with Section 1033
The GLBA privacy framework is related but distinct. The FTC’s GLBA Privacy Rule compliance guide says covered financial institutions must provide privacy notices describing information collection and sharing.
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A GLBA opt-out is not a substitute for the express authorization required when a third party requests covered data under Regulation 1033. Conversely, Section 1033 authorization does not erase the institution’s separate privacy-notice duties. Check both the connection screen and the bank’s privacy notice to understand which legal mechanism applies to a particular transfer.
Current compliance status and dates
The regulation’s published phase-in schedule in 12 CFR § 1033.121 lists initial compliance dates by provider size from April 1, 2026, through April 1, 2030. Those printed dates should not be presented as presently enforceable without checking for later court or rulemaking action.
The CFPB’s implementation resource reports that the court in Forcht Bank, N.A., et al. v. Consumer Financial Protection Bureau, et al. stayed the compliance dates on October 29, 2025. The same resource reports an August 22, 2025 advance notice of proposed rulemaking and plans for a proposed rule to extend the dates. Because this status can change, consult the CFPB’s Personal Financial Data Rights implementation page before relying on a deadline, enforcement assumption, or implementation date.
A practical checklist before connecting a financial app
- Identify every participant. Note the app, the bank or other data provider, and any named aggregator.
- Read the categories. Confirm whether the request covers transactions, balances, payment initiation, terms, bills, verification details, or a combination.
- Check the time period. Look for the historical range and the expected collection duration. Treat one-year collection as a limit, not an automatic renewal.
- Confirm the purpose. The stated service should match what you are trying to do. Advertising, cross-selling, or a data sale is not reasonably necessary for the requested service under the rule.
- Use the official authorization flow. Do not hand an unrelated company your ordinary bank password to “scrape” the account.
- Save the disclosure. Keep a copy or screenshot showing the parties, categories, duration, and revocation instructions.
- Review security information. Look for the recipient’s security program, breach-contact information, and explanation of vendors or processors.
What to do when you no longer want access
- Use the app’s account or privacy settings to revoke the connection, if that is the stated method.
- Check the bank’s connected-app or third-party-access page and revoke the authorization there as well when the bank provides a separate control.
- Ask the app what data it already collected, what it will delete, and what it must retain for a legal or contractual reason.
- Remove the app, change credentials only if you shared them improperly or suspect compromise, and monitor statements for unfamiliar transactions.
- Keep records of the authorization and revocation dates. They help distinguish future access from data that was collected while authorization was active.
If a company continues collecting data after a properly completed revocation, uses it for an unrelated purpose, refuses to explain the parties involved, or a provider denies access without a clear risk-based reason, preserve the notices and contact the institution or company first. You can then consider the relevant federal or state regulator and legal advice. The regulation allocates duties, but it does not by itself decide damages or liability in a particular incident.
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