It's time to act. Prioritize 1033 compliance for your customers.

Olivia Fahey: Hello and welcome everyone. Thank you for joining us today. My name is Olivia Fahey, and I'm the product marketing lead here at Akoya, and I will be hosting our session this afternoon. 

This is the second in a series of three webinars that we are hosting with our partners at Capgemini. 

The goal of this series is to prepare financial institutions like banks and credit unions of all sizes as we all work toward achieving Open Banking regulatory compliance. 

As I said, we've teamed up with our partners at Capgemini to really go beyond the surface level discussions and equip business and technology leaders at banks and credit unions with the education and resources they need to make informed decisions and get into CFPB 1033 rule compliance as quickly and effectively as possible. 

So as many of you know, the final ruling dropped on October 22 and is known as the Personal Financial Data Rights Rule. So, we can have a lot more meat in the conversation. And what we will really center on is what this final rule means for data providers, both from a technology and a business perspective, as well as leveraging Capgemini and Ramendeep's expertise and some of the global learnings there and some of the potential pitfalls that financial institutions can work to avoid. 

Olivia Fahey: So, with that, I would like to introduce our two speakers today. 

First, I would like to welcome Ramandeep Singh from Capgemini. Welcome, Ramandeep. We're really happy to have you here today. Ramandeep has over 25 years of experience working with global banking, insurance, and capital market firms. 

His focus is primarily on providing strategic technology solutions in the financial industry, and he specializes in designing and developing business focus enterprise systems. He has extensive experience in shaping and delivering large scale business and technology transformation programs with a deep focus on design and implementation. Again, happy to have you here, Ramandeep 

And second, but certainly not least, is Behram Panthaki, chief operating officer at Akoya. Behram brings over 20 years of entrepreneurial and management experience from startups to enterprise companies, including experience building and scaling networks with a deep domain expertise in payments. 

Prior to Akoya, Behram spent a decade at JP Morgan, Chase and Citi, where he led digital payments and platforms, building and scaling digital offerings like Quick Pay and Zelle. We are lucky to have him here at Akoya. Welcome, Behram. 

Behram Panthaki: Thank you. 

Olivia Fahey: Now, we did want to kick things off with a quick poll. The purpose of the poll is to get a better understanding of you, our audience, and help us tailor the conversation based on where you are in your 1033 compliance journey. Okay, thanks for participating in the poll. So exactly half of the audience is in the discovery phase and just taking in the final rule. Like I said, it has only been out two weeks now. 

And another third of the group are a little bit further along in either the business or technical planning phases. So, that is good to know. We will consider that as we progress into the conversation and appreciate everyone that participated. 

So, all right, that is enough of me. Let us hear from Behram and Ramandeep. My first question, Behram, is for you. 

As I mentioned a few times now, the final 1033 rule dropped two weeks ago. I'm sure everyone here has looked at it, but if you could help us and really summarize some of the key elements of the final rule, and then highlight some of the notable differences between the final rule and the proposed rulemaking that we saw on October 22. 

Behram Panthaki: Absolutely. So, if you think about the final rule, it follows in the footsteps of the notice of rulemaking, where it continues to protect consumers and provide consumers access to their financial data. 

And in that sense, the final rule continues to ensure that consumers can get that access in a safe and secure fashion. The rule does not eliminate screen scraping, but it actually goes a step further than the proposed rule, in saying that the intent of the CFPB is to sunset the practice of screen scraping -- which is having consumers provide their username and passwords -- and then an intermediary storing the username and passwords to access the website on behalf of the consumers to get their data. And so, from the consumer’s perspective, that’s a wonderful thing. 

The 1033 rule continues to enable consumers to have more informed consent or how they are sharing the data with whom they are sharing the data and what data they are sharing. So, a lot more fidelity around data sharing practices, a lot more focus on data minimization in terms of what data gets shared with authorized third parties. 

Behram Panthaki: And then the rule sort of ensures that when consumers share data, they have the ability, then revoke the sharing if they so need to. They can also change the accounts they are sharing, add more accounts, and delete them, and then the rule ensures there is a recertification of that consent annually. So, from a consumer perspective, it continues to ensure that there's safe and secure sharing and more resilient sharing of the data. 

As you think about the rule, what are the third parties' obligations? The rule once again ensures that consumers are safely sharing data with authorized third parties, and those authorized third parties have the sound and safe and secure practices around data, minimization data, storage data, deletion after the facts and the rule talks a lot about obligations of third parties in terms of what data they can take on behalf of the consumer.  

How do they protect the data? And then the obligations of 3rd parties also require them to get what they call informed consent to ensure that consumers understand what data they are providing to the third party, and for what reason. 

And in terms of the use of the data, the use of the data is restricted to the primary use that the consumer is consenting to, and then a few secondary uses, such as fraud and risk, or improving products and services offered to the consumer. 

And then, as you move on to the other side of the spectrum, what are the obligations of data providers? Data providers need to be able to create a data sharing interface which is an API based interface, and they have to be able to maintain that aid interface ensure that there is resilience in that interface uptime SLA and ensure that they can share the data with these authorized third parties on behalf of the consumer. 

Behram Panthaki: The data providers have the ability to ensure that these third parties are meeting certain guidelines around safety, security, and soundness. So, they have the ability to do due diligence to these third parties before they on board them. And then they also provide the ability for consumers to revoke consent and modify consent on their website if they choose to. 

You know, tokenization has seen a lot of deliberation. The rule continues to permit banks or data providers to use tokenization of account numbers to secure these account numbers. 

And then in terms of obligations around onboarding these third parties, there is some latitude provided to data providers around ensuring that they can do so in a reasonable amount of time. As the third parties approach banks, credit unions and other data providers for the data, they have defined the scope of covered data.  

They have defined it in terms of regulation E, which is any institution that is providing depository accounts to consumers, and it includes the likes of wallets, like PayPal, etc., and then on the Reg Z Side, which is credit products like credit cards, and includes buy now, pay later. 

So, the rule has defined the ecosystem in terms of data providers. They can choose to set up these interfaces themselves, or they can choose to use a third party, such as their core provider or Akoya, to set up these interfaces. 

And then they do talk about two other entities in the ecosystem. They talk about financial data aggregators. The aggregators can be used by data recipients for the purposes of getting authorization and access to some of the data that they need to get on behalf of their consumers, and then the last entity that they talk about are standard setting bodies which would help the industry, evolve standards around data, sharing practices. 

Olivia Fahey: Great. Thank you. One thing and one notable difference was, of course, the extended deadlines as well. 

Behram Panthaki: The deadlines have been extended. The first tranche of banks, over 250 billion in assets, or non-depository institutions with over 10 billion in revenue must be compliant by April 2026, about 18 months from now. The second tranche is any bank with about $30 billion, they have until 2027, and it goes on until 2030. 

The other notable difference is that banks under $850 million do not have a compliance deadline. The CFPB is hoping that the market pressures and market forces enable them to get compliant through their core providers or other entities in the ecosystem. 

While the deadlines are relaxed, I was just talking to my son over the weekend he was stressing about a term paper. He's a senior at Carnegie Mellon, and so this resonated with me to talk a little bit about that although these deadlines seem a little longer, things take longer than expected to get out there. 

And so, we expect the largest banks will need a solution in the market sometime early in 2026, testing and ensuring that everything meets standards before they comply with the mandate on April 1st of 2026. 

Olivia Fahey: Got it. I'm sure your son appreciated that alignment to the CFPB rule, as well. 

Ramandeep, you've worked on open banking implementations around the world through your work at Capgemini. So, in that same vein on the relaxed timelines, what do you feel are the implications on financial institutions of these timelines, especially those in the higher asset tiers that need to be compliant in 2026 and 2027? 

Ramandeep Singh: Sure, and while I agree compared to what was there earlier, the timelines in the U.S. are now are relaxed, based on my experience working in Europe on the initial PSD1, and then on PSD2 since 2016, and then coming from a technology background, I agree with Baram that timelines will be challenging. 

So just to take a parallel, if you investigate how Europe or Australia, and then to some extent Middle East, implemented these changes and see what differences major differences there between Europe and the U.S. 

So, if you investigate Europe, the discussion started somewhere in 2017 for the Payment Service Directive coming in in 2018 with the deadline of 2019, right? So, there were anywhere between three to or minimum two years were there for implementation like and, in fact, for Tier 1 banks, it's even more challenging in the U.S. 

Ramandeep Singh: Then it must be extended for secure customer authentication. What Baram mentioned about the screen scraping and disabling of screen scraping and having more secured mechanism of customer authentication and control so all that takes lot of time. 

I've seen banks struggling over three years to achieve this. And then, even with the extended timeline of end of 2020 there were challenges to have the secure customer authentication implemented. 

Ramandeep Singh: And while in Europe the move to Open Banking was very regulatory driven. There was a good regulatory text. There were what we call in Europe regulatory technical standards. Those were very clearly given. So, technology, central body central registry, some of those constructs were very well defined in the U.S. 

Most of this regulation is market-driven, especially by the smaller banks. It would be driven completely by their will and the market pressure which is a good thing in terms of flexibility, and what probably consumers will get at the end, they will have more flexibility and more features, but it also means that this consensus building, getting to a common standard will take some time 

There will be many discussions around interoperability and API security, which must be sorted out. So, while yes, we have 18 months, I see that as a truly short timeline to implement compared to what I have seen in Europe and in in Australia for their implementation work. 

And specifically, one important thing is that when we are working with in in the market in this open standard. It is not just what I am implementing in my bank. It will always be how the integration with many of the third parties. 

Ramandeep Singh: How do I test this? API integration or the technology integration across different banks and different financial bodies, as well as certain regulatory registries and standards which might develop from now until the end of next year. The integration testing verification must be synchronized between multiple parties, and that takes time. 

The certification and testing process in Europe was between 4- to 6-months. So, we must keep those in our mind when we are developing. This would, of course, would impact lot of different departments business units in a bank, and then that must be looked upon when we are planning 

So, when we look into it, I've seen that, the size of institutes, the larger bank, we will have bigger challenges, because there would be a lot of different systems, and many times larger banks have developed through inorganic acquisition. So, there might be isolated parallel systems. And all those systems must adapt to a certain data standard. And along with that, the right sizing of the data, in what manner, while keeping everything secure where I touched a little bit on tokenization. 

So, that will come into the picture for the consumer as a controller will get much authority in providing the consent. So, management of consent, adjustment of that consent, adding accounts and removing accounts from those consents becomes a complicated system when it must talk to multiple different systems and modules within the bank. So, that causes much work at the bank to ensure those systems are aligned, data is captured, transformed, and shared in the right way. 

Ramandeep Singh: And while we are doing this, the infrastructure also brings a lot of challenges. Right now, most of the banks operate where these data systems and the transaction systems are at the back end, while certain websites, or mobile or different channels are at the front end. The channel between the front-end back end must be adjusted. 

Similarly, the scale on which the APIs or integrations will work can vary. So, this would be a very variable load coming in. So how do we utilize cloud, or non-cloud scalable systems become some important aspects and would need some tweaking in the infrastructure as well as the operating model around that infrastructure. 

So, those are two main things I have seen causing lots of work, internal consensus and capability building within the banks and financial institutions, and while doing that, there is also regulatory governance. And then, the market and how the market reacts, what people are doing with it will continue to evolve. So, we must continue to evolve as per that while keeping everything secure and seeing this as an opportunity. 

But this also would mean that the bank can also receive a lot of information about their consumers, and give them better products, more tweaked and tween and custom offerings to those customers.  

So, if we start thinking in that direction that adds another business angle to it and look at it comprehensively, the earlier we start, the better. And I have seen, if we have a platform like Akoya, where lot of those market facing challenges are taken care of, and bank then can focus on all the internal systems that is always helpful. So, looking into what I have seen in Europe and in Australia, I wouldn’t say that timelines are relaxed, and I would say the timelines will still be challenging. 

Olivia Fahey: Yes. I want to go a little bit deeper on one thing you just were saying at the end. There towards about consumers. I feel like we have talked a lot about the impact of the rule on financial institutions and on the data recipients. But the impact on consumers here is paramount. 

So, if you could, Behram, talk about what this means for the end consumer, and how banks should think about this as a benefit and an opportunity. 

Behram Panthaki: Absolutely. So, if you think about you know what the API-based access is going to provide, firstly, it is going to provide banks with visibility into how their consumers are interacting with other entities in the ecosystem, what entities are they using? What are they using them for? And that is great intelligence for the financial institution to then use capabilities that exist in the market to provide better products and services to their consumer. 

If you think about the consumer, they will have the ability to transition away from this traditional screen scraping, which is always a good thing. And they will feel they will have to be educated on feeling more safe and secure about this new capability through open banking, and how they can share their data. 

On the other side there are lots of use cases around which banks can evolve their experiences as they provide them to the consumers. So, for example, open banking enables streamlined account opening processes, streamlined payment processes, the ability to use cash to do cash flow underwriting, using banking data. There are lots of use cases that are prevalent today, and there will be a lot more that will evolve over time. 

As you know, the industry evolves as the type of data sets that are undercover data for banks as that evolves. And so there is a fantastic opportunity for banks to leverage the information that they are getting from their consumers, as well as leveraging the power of open banking to become more of a data recipient and to power these experiences for their consumers. 

And then, lastly, as the industry evolves, how do we streamline the authentication process for consumers 

It is important that banks start to evolve to more seamless authorization and authentication processes like biometrics app to app capabilities, so that you know the actual consumer experience of authenticating their account with their financial institution gets enhanced over time. So, there is opportunity for all parties of the ecosystem to innovate and evolve as these open banking rules get formalized. 

Olivia Fahey: Great. Thank you. So clearly based off everything we have talked about, there is a compelling case for financial institutions to get started on this sooner rather than later. You know the time is now to start acting. The timelines may seem far out, but they approach quicker than you think, and there's countless opportunities and benefits for consumers.  

So, when it comes to standing up a developer portal that fits the regulation requirements. What are some of the key technical considerations, Ramandeep, that a bank, a finance financial institution, should take into consideration to get started on that journey. 

Ramandeep Singh: Sure. So, when we talk about core technology, we must think about Day zero, which is where we are right now in planning, thinking about it, and having the gap analysis done. 

Then, on Day 1, it would be about how do we implement it. And then, Day 2 should focus on how we run this in a scalable manner, but also in a cost-effective manner. 

So, technologies which we have seen across the globe for supporting a scalable system for open banking, of course, technologies like cloud play a key role. So, the cloud and APIs are given. So, when you are thinking about open banking in the U.S., obviously, the choice will be around how do we have scalable APIs implemented and developed in a cost-effective manner? 

Ramandeep Singh: But then, on the planning side of it, right? When we are in Day Zero, it is important to understand where the current systems are. What level of maturity the banks have from data perspective, from an API perspective, from the integration and the middleware capability perspective. Because when we open these systems, it is going to impact everything. 

And while we are going to open these systems to external parties who consume data, security is also paramount, and it must be considered. So, data availability. Specifically, if you have heterogeneous systems, multiple different acquisitions, some data might reside on mainframes. Some might be modern systems. So how that data will become available through extraction and transformation is the first step we must think about. 

And then, of course, the APIs. So, a scalable API which can help take this data and open this data externally will become the most important thing. So, the security of the API gateway implementation, monitoring and logging on to the API, will become an important aspect. 

And while we are doing this data privacy, how do we handle the consent we discuss about consent management consumer getting empowerment to manage their consent to manage which accounts they want to centric control? How minimal amount of data is shared as per the customer preferences is an important thing. 

And while we are doing this, while we are adding this additional complex technology layer, the user experience, the interface communication to the user error handling and communicating those errors in a friendly manner is also an important consideration. 

And error handling is one of the areas where both in Europe and Australia, I have seen key issues during the first implementation, and then, even in Europe, regulatory bodies had to intervene to provide certain standards about errors and error handling so that must be investigated with close focus. 

Ramandeep Singh: And then as we move forward, we also must think about this infrastructure which is going to be consumed by many different third parties, not just our mobile application and our banking interface. So, the monitoring of that, making sure that set of APIs and interfaces are up and running in optimal performance are important. 

So, that monitoring, making sure they are scalable and secure is the day to focus that continuous monitoring and making sure that system continue to behave while also looking the other way around, that not there should not be that one party, or one particular agency, and maybe hacked agency is not able to consume all the bandwidth and all the API thresholds for you. So, keeping a balance, keeping a monitoring about how the APIs are being consumed and then scaling them in a cost, effective manner is the day to focus which we must consider. 

Using all this and making sure there is continuous compliance is a huge challenge. There is a continuous testing market evaluation and certification of third party, as well as your APIs that goes through all three phases. And this will be an important aspect. 

So. when you are thinking about technology, think about what are and how you are going to do your current assessment, identify the gaps, and then move on to your API strategy and data strategy implementation around it. 

Olivia Fahey: Thank you, Ramandeep. That is extremely helpful. 

So next, given everything that we have discussed today, the road to compliance can be complex, and it can be long.

Akoya has developed two tools, a readiness assessment and a cost calculator. These are both interactive tools and they are live today.  

We've had countless conversations with leading financial institutions across the U.S and really dug into what are the main buckets of work that it takes to achieve compliance.  

We've taken those and distilled them down into the key tasks under each one and what you can do is go through this assessment. It should take less than five minutes, and it'll help you understand whether you're at a low medium or high readiness, your financial institution, as it relates to full compliance. 

And it'll also give you a ballpark time on how many more months you need to achieve compliance. So that's the first compliance readiness tool. And the second is an interactive cost calculator. We ask you to plug in the number of scrum teams that you have available for this work and the anticipated data recipients you might see coming to your platform for data. And we help you think about what are not only the initial costs that it would take to achieve compliance, but also the ongoing costs. 

So, it really helps you think about your business case here and put some numbers to it and get a gauge on where you are and what you have left to do to achieve compliance. 

So, in that same regard, I want to pass it on to Behram quickly, so he can talk about this. 

How can Akoya help from a 1033 compliance solution and secure data access partner perspective? 

Behram Panthaki: Thanks, Olivia. So, if you think about Akoya, we play two roles in the marketplace. The first role is that of a service provided to data, providers, financial institutions, credit unions, banks, wallets, etc., where we enable the institution to outsource the entire sort of creation and operation of their hosted developer interface to an entity like Akoya. We do this for some of the largest financial institutions in the country today. 

And in terms of the sort of support we provide. We provide them with support on three core dimensions. 

The first dimension is supporting financial institutions as they go about the business of extracting data. 

And Akoya has built out technology where we can help financial institutions expose the data, standardize the data, transform the data as Ramandeep mentioned, and ensure that they can then present the data in a in a standardized format, to authorize third parties, to be able to comply with the regulation. 

So, that is creating and managing the infrastructure to provide the data forward. But that is only a piece of the puzzle. 

The second piece of the puzzle is, as these third parties come to financial institutions, you must provide them with not just the APIs, but a sandbox to allow them to test against the APIs, a process by which they can go through and integrate, certify, get production, access ongoing support, managing that ongoing support, and managing the projects. 

As these regulations evolve, and as more data gets added as part of covered data, the entire administration of the hosted developer interface is also something that Akoya takes on behalf of the financial institution. This enables the financial institution to be able to get quick distribution into the marketplace. In terms of getting data access to entities who can then use the data. 

And then the third dimension is all the administration around these interfaces. So, the ability to ensure that you're doing due diligence around the safety and security of third parties, contractual obligations, etc., etc. So, we manage all that on behalf of the third party on behalf of the data provider. 

Behram Panthaki: The second role we play in the marketplace is a secure data access network where we have over 4,000 data providers who have, you know, who we have integrated with. And so, this enables, you know, institutions like banks and credit unions to authorize third parties to be able to access the data providers we work with. 

We are an inclusive network. We are an API only network. We are a pass-through network. So, we don't store the data on behalf of anybody. We just pass it through to the data recipient. And most importantly, we work with everybody in the ecosystem. So, we work with fintechs. We work with banks and credit unions. We also work with some of the largest financial data aggregators in the ecosystem, and we enable them to get access to data as they require. 

And in terms of the use cases, there are lots of use cases that this data powers like online account opening and cash flow underwriting and payments. But that is just the beginning. There is a lot more that will get involved as this ecosystem gets evolved and enhanced over time. 

Olivia Fahey: Great. Thank you, Behram. So, with that we are ready for Q&A. We have about 9 minutes left. We have some questions that have been submitted. Let me start with one we just got in. 

I'll send this to you, Behram. Is consent management part of the obligation of the third party or the data provider financial institution? 

Behram Panthaki: So, the rule provides the ability for third parties to, you know, put in front of them, put in front of the consumers, sort of consent screens. It also provides the ability for the financial institution to sort of review and reply to that consent and sort of ensure that it is. It aligns, and then, in terms of ongoing consent and ongoing management of it. 

Both data recipients and data providers can provide access to consumers to be able to add accounts, revoke consent, etcetera. So, I think it's a little bit of a joint responsibility between both entities. 

Ramandeep Singh: Yes, just to just to add one point, the important thing to understand is looking into the global view as well. If the bank has an account, they should be able to view and make sure that the consent is rightfully given. If the process is not complete by the third party, the bank cannot directly allow it. 

So, there must be this verification as mentioned. Let's say, if I am in Bank of America, I just want to see where all I am sharing my data. That would be one source where I will go to. So, banks have a lot of work around consent management which they would have to deal with the way we have seen across the globe. 

Olivia Fahey: Got it. Thanks, Ramandeep. This next question here, I think I will pass to you. 

Having worked with so many banks across the globe on their open banking implementations, what are some of the biggest pitfalls or areas where you have seen banks struggle as it relates to achieving this compliance? 

Ramandeep Singh: Yes, I think the biggest focus should be making sure there is clear sponsorship. This will not be just API or just data access work, right? Many different systems will be involved. Then the security, the customer education, and many distinct aspects of the bank's business would need to get involved. So, a senior level sponsorship to this program is important for its success. 

So that’s where I would start beyond the technology and then not trying to implement everything from scratch by building onto a platform like Akoya, where a lot of APIs, the developer portal, the playground, and the sandbox for verification and testing, would already be in place. That will take a lot of loads out from the banks and financial institutes for implementing it.  

So that would be my recommendation beyond the sponsorship internally, which would be needed. 

Olivia Fahey: Thank you. We have some more questions. This one, Behram, is for you. 

How does the data and the APIs vary between Akoya's 1033 compliance portal and Akoya's secure data access network? 

So, the API standards kind of overlap. But if you think about the data access network, it is more productized so the APIs there are more product focus while they are FDX compliant. They are a little different when you are looking at the hosted developer interface. Those will be FDX compliant APIs, with the assumption that FDX is the standard setting body that is recognized by the CFPB. And so that will provide an indication of compliance to data providers if they use that standard.  

Olivia Fahey: Got it. Behram, I will stay with you on this one, because it is related. But is the FDX format only relevant for data being sent to aggregators? It seems like the transactions API across Akoya, and other aggregators are all quite different. 

Behram Panthaki: So, the standard setting body and the API standard, at least the way I read the rule today, is primarily focused on how data is sent from data providers to authorized third parties. 

The rule does not talk about any standards for any aggregators, you know, while Akoya had in its letter to the CFPB and talked about trying to create uniform standards for aggregators as well, so that there could be further implications for third parties that are not in the rule at this point in time. 

Olivia Fahey: Okay, great, thank you. 

Ramandeep, this question is for you. Based on banks you have worked with, what phase has been taking the longest for a new bank to be ready? 

Ramandeep Singh: Yes, so yes, quickly. Behram can add what he is seeing in the U.S., but the biggest things I have seen are two aspects. So, one, of course, was the data. So, making all the back-end system able to talk and provide the right amount of data in a secure manner was the most challenging and we have gone through this with many banks. 

And the second was building this secure customer facing or the market facing platform. Right? So far, most of the banks had APIs which were consumed by their channels, their website, mobile systems, and some very, very trusted third-party partners. 

But this is now opening all that infrastructure and the platform to the outside world where not any trusted third party, but an authorized third party, should be able to come and access. So, building that platform which is customer facing and ability to provide the data in a secure manner is also challenging and something financial institutions must think about. 

Behram Panthaki: Yes, just to add to that, I would say, the entire process of vetting authorized third parties is something that financial institutions really need to think through, because there needs to be a balancing of requirements. 

There is the requirement from the regulator to ensure that any entity that is working with them is ensuring that the data is safely and securely protected. And then, on the other hand, there is this requirement to provide access to a third party. And so, it is a little bit of a balancing act. 

And financial institutions figure out how to ensure that third parties are, in fact, adhering to the safety and security protocols required by the rule is extremely important. 

Olivia Fahey: I think we can answer one more question. Behram, if you could answer this in under a minute. The CFPB 1033 compliance solution. How many agreements, or signatures with 3rd parties should a regional bank need to plan for? 

Behram Panthaki: So, the way we think about it is it could be 10, or 50, 60, 70. It all depends on whether the regional bank has already gone ahead and connected with some of the larger aggregators in the industry. 

If you think about the largest banks in the country, they have been on this journey for decades. They have created agreements with the top 15, 20, 25 data recipients who are the largest and who have been consuming data and the data aggregators. 

And so, if you pack onto that other authorized third parties who would want to go directly to a financial institution because of multiple reasons, whether it be cost or the ability to sort of get more direct data access that would all sort of add up. 

And so, the number of entities that would be approaching a financial institution depends on where they are in the journey as well as knowing the size of the institution. 

Olivia Fahey: I would like to thank very much both of our panelists, Ramandeep Singh and Behram Panthaki. You two are wonderful. Thank you so much for joining us today and for everyone attending thank you for being with us. We hope you found this helpful. 

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