Webinar Transcript
CFPB 1033 Compliance is a Significant and Ongoing Expense. Don’t Underestimate It
Olivia Fahey: Hello, everyone. Welcome, and thank you for joining us. My name is Olivia Fahey. I'm the product marketing lead at Akoya and I will be hosting the webinar today. This is the first of three webinars in our Open Banking Compliance Series hosted by Akoya and Capgemini. The goal of this series is to prepare financial institutions of all sizes as we move toward open banking regulatory requirements.
This fall, we have partnered with the experts at Capgemini to really go beyond the baseline. We are not here to discuss the impending regulation or its implications. We assume you are already well versed in those. Think of these webinars more as practical guides to becoming CFPB 1033 compliant.
We are going to dig into what it takes to stand up the technology, the policies, procedures, and especially the third-party risk management to both meet and maintain compliance for the long haul.
So, over the next several months, via these webinars and thought leadership content, we will put out some hands-on tools you can use to help you on your journey to CFPB 1033 compliance.
We aim to provide financial institutions like yours with the education and the resources to make informed decisions and help bring your organizations into compliance as seamlessly and effectively as possible.
So, without further ado, let me introduce our two speakers today.
First, we have Vijay Krishna, chief product officer at Akoya. Vijay is responsible for driving the strategic product direction here at Akoya. He has over 20 years of experience in the financial services industry with over a decade each at Citi and MasterCard.
Prior to Akoya, Vijay spent 10 years at MasterCard in multiple global and regional roles.
And next, we are happy to have Rishabh Shah. Rishabh is Vice President and creator of Capgemini's Open Banking Solution. He also has over 20 years of consulting experience in information technology and currently leads multiple projects related to open finance across the world in Europe, the U.S., the Middle East, India, Australia, and Latin America.
Welcome, Rishabh. We're happy to have you.
And with that, I will hand it over to Rishabh to dive into our content today.
Rishabh Shah: Thank you so much, Olivia. And thank you everyone for joining this webinar today. I will begin by introducing Capgemini. We are a global business and technology transformation partner for some of the largest enterprises in the world.
We are a team of 340,000 consultants, we have a 55-year history, and we cover around 50 countries across the globe. Now, what does that mean for us? It gives us a deep global perspective, but it also enables us to have extremely local context.
In terms of the solutions that we deliver, we bring together deep industry expertise. We combine it with our capabilities in AI, in cloud, and in data to deliver industry leading solutions to our clients.
Moving on, what does that really mean from an open banking perspective? I will give you a little bit of history. We started getting involved in open banking with the regulation in Europe, which is essentially PSD2 and since then we have worked on the CMA order in the U.K. We have worked on CDR from Australia. We have worked on several regulations related to open banking and open finance in the Middle East and in Latin America.
So, we get a global perspective having executed these different projects. And the way we deliver this global perspective is through our world report. So, in the center, what is the world payment report? This year the topic of the world payments report, which is now in its 20th edition, is the combination of open finance with instant payments. So, there is something that you might want to check out.
Now, I mentioned the local context, right? It is not just about the global perspectives. It is also about the local context.
So, on the right-hand side of this slide, what is our open finance maturity index from Brazil. As we work in a specific geography, we develop that deep context. And then we bring out reports that are extremely specific and reports and thought leadership that is extremely specific to that particular geography.
Now, on your extreme left-hand side, what you really see is the type of projects that we execute, right? And one of the projects we speak about in this slide is the one we did with HMRC, the tax department of the U.K. And how do we enable that particular tax department to actually use pay by bank, which is essentially the PISP functionality of open banking, too, to start to enable the U.K. citizens to start paying taxes using payment initiation.
And this is something that got mentioned in the impact report of open banking in the U.K.
Now, as you look at the CFPB 1033 ruling and our learnings from the different regulations we have worked across the globe, we can break the capability map into four different sections. The first section that I would call out is operations and this is related to everything related to the third parties.
So, for example, the onboarding of the third party, the due diligence that you really need. The ongoing support of the third party and its entire lifecycle is covered in this section. The next section is essentially privacy and security, right? So, open banking deals with an interesting phenomenon, right?
You must balance the open part with the customer privacy part, and that balance is exceedingly difficult to attain, right? And this has been an evolutionary journey throughout the globe, wherever we have gotten involved with open banking and that is the topic that is covered as a part of the privacy and security section of everything that must be implemented.
The third part is essentially the experiences, and I would really call the third-party developer experiences because they are the ones who would finally create all the value-added services for the end customer. So, everything related to the developer portal, sandbox, test data, policies, procedures, and that combined is an experience that must be delivered to third-party developers and engineers.
And the final part is the open APIs, which is all about APIs, the standards, the regulatory and performance monitoring, the whole gamut of things. Now, the interesting thing I would like to point out is that every time we talk about open banking, it is considered APIs, right?
But through this capability map, the important message we want to give you is that 1033 or any similar regulation globally has taught us there is more to open banking compliance than just the APIs. That is an especially important learning that we have had in the past.
And since I am talking about learning I think we can move on to some of the key learnings that we have had in the long journey of open banking that we have seen globally. The first one that I want to talk about is the fact that this is not a sprint, this is a marathon. And I want to highlight that through the experience of one of the geographies we have worked in, Europe.
So, open banking technically in Europe started with the second Payment Services Directive (PSD2) regulation, which is now morphing into the PSD3 regulation. It is now getting expanded with the FIDA regulation. It is coupled with what is called the Payment Services Regulation (PSR).
Already, we have seen a seven or an eight-year journey around PSD2 and the journey is expanding with PSD3 and further regulations coming in this space. The key message here is that you really need to be prepared to run a marathon, which means that there are sustained investments that are needed over an extended period.
Moving on. This slide talks about the trust framework. And again, I go back to the original comment that I made, which is essentially that open banking is all about balancing the open part with customer privacy, right? But then there are additional dimensions that start getting added on.
When you really start talking about customer privacy, you also must think about things like fraud. You must start thinking about customer friction that might get introduced because of all the trust and security frameworks that you are implementing, right? So, everything must be balanced.
And this is a difficult balance that we have seen emerging in the geographies we have worked in, and it is still evolving. See, the most important part is, are we at a point from the experiences in different geographies where we can say that the trust framework is perfect?
I do not think so. It is still evolving. And I will give you some examples of that. The critical part here is that most financial institutions underestimate the amount of work that really needs to be done to implement a proper trust framework.
Now, moving on. So, I was talking about the fact that the trust framework is evolving, right?
So let me give you a few examples of it. In Europe with PSD3, the liability model between the TPPs and the financial institutions is undergoing a change, which is one example of how the framework itself is evolving the banks in Europe and the regulator in Europe is looking at the possibility of allowing banks to share data amongst themselves to prevent it from a fraud prevention perspective. So how will that be done is still to emerge fully. But that is also an example of how some of the security protocols and trust frameworks are evolving, right? There is the emergence of digital identity wallets, right? And this wallet will again have an intersection with open banking and open finance evolution.
And which will also again lead to enhancements in the trust framework itself, right? So, there is a lot of activity going on, which again goes back to the point that this requires sustained investment over an extended period.
Moving on. Okay. So, this is an important slide. This talks about the integration costs and having worked with so many different financial institutions globally, what we have come to realize is the fact that the data finally, the customers.
Data or the data owner's data is in systems of record within financial institutions, which are legacy systems. These legacy systems and this data have service interfaces, which are bespoke. And if you really look at most of the open banking standards, these standards expose data in a canonical form.
So, extracting that information out of the legacy systems needs a lot of integration effort and orchestration effort. And in many cases, it needs some amount of redesign because the data and the state of that data that must be described to the third parties are different than how it exists within the system of records.
We have seen that integration costs sometimes can go as high as 40 to 50 percent of the total cost of implementing an open finance, open banking type of a project, right? So, this is significant from a cost perspective.
Now, from a third-party support perspective, imagine that you are a financial institution. And you suddenly must support 500 or 600 different third parties, right? And we have seen situations in the past where a lot of third parties will be able to access the information, but a few third parties are facing some of the challenges or other issues?
And when you have an exceptionally substantial number of third parties, these issues will need a support model that needs to scale out rapidly.
Now, that is fundamental in one aspect in terms of the fact that supporting a third party is quite different than supporting the captive channels that financial institutions have today, right?
So, it requires a different mindset. It requires a different approach. But it also has a dimension where the regulators start demanding a specific level of operational guide guidance, right? That is given by the regulators in terms of the version management, in terms of deprecation of the APIs, in terms of availability, in terms of performance, etc.
All these aspects and all these different dimensions must be combined as you start thinking about a support model that must be provided to the third parties. And if the number of third parties connecting into your institution is large, then the support model becomes quite significant in terms of how it needs to be scaled and how it really needs to be implemented and structured from a cost perspective.
So, these are some of the key learnings that we have had from the different geographies, working with many financial institutions, working with a lot of the ecosystem players within the open banking and open finance gamut right now across the globe.
With that, I would like to hand it over to my co-panelist Vijay to talk through the Akoya solution. Over to you, Vijay.
Vijay Krishna: Thanks, Rishabh. Capgemini is an incredible technology partner to us, and they are also thought-leadership partners. As you can see, what Rishabh brings to the table is a significant amount of global experience.
And with the U.S. being slightly late in this Open Banking journey, it is super important for us to pick up some of those cues from the rest of the world.
So, before I get into the solution itself, I do want to provide some context on who we are. Akoya is a data access network at its core. It allows consumers to share their financial data that resides with their banks and financial institutions in a safe and secure manner with third parties that want that data to provide them with different services.
We were founded in 2020 with three core principles that we hold very dearly.
The first is that consumer privacy and protection is fundamental to whatever we do and is nonnegotiable.
The second, which goes hand in hand, is that all the data we provide through our network is through APIs. That means we do not ask consumers for their login credentials, store those, and have no use for them. In a very crude form, we do not screen scrape.
And the third, the most important piece, is that we are a pass-through network, which means that we do not hold the data, we do not store the data, and we have no support for any secondary use of the data. So, those are the three core principles we were founded on.
We have stuck to those core principles because that is our differentiation in the market. And this goes hand in hand with the technology stack that we have created which is highly scalable and super flexible. And you will realize why this is important as we go through this presentation.
As I mentioned, the core principles that we have aligned with a lot of players in the ecosystem. Consequently, in a brief time, Akoya has become the most inclusive consumer financial data access network in the United States. And I will tell you what that means. It means that on our network, we have financial institutions of all sizes, large, medium, small credit unions, core processors.
We have fintechs and we have all the major aggregators connected to Akoya to either deliver data or receive data from us. But there is also another aspect to the core principles. It also resonated with a lot of our financial institution partners, who then appointed Akoya as their service provider for third parties to access their data, or their customers’ permissioned data, as I would call it.
And in that role as a service provider for financial institutions, we process billions of transactions on behalf of prominent financial institutions like Fidelity and PNC, and more.
So, as you can see, the path that we've gone from being a network to a service provider for the banks has allowed us to create that tech stack that is required, not just for the scalability that is required to support these institutions, but also the fact that we have this entire white-labeled consumer journey that is going to be absolutely important for you to deliver to your consumers as part of the 1033 compliance solution.
And then when you combine this with our third-party risk management and the entire process in terms of managing your third parties, you can understand that this is an entire comprehensive end to end solution and one of the unique solutions in the market that can take the entire load off of you, the financial institution and absorb it on your behalf.
So, before we get into the actual solution itself, let us launch a poll. And let us make this interactive. We would love to hear from you.
Here is the poll question:
What do you anticipate will be the organization's biggest challenge as it relates to becoming compliant with section 1033?
Okay, I think we can close the poll, and we have the results. Okay, managing third party security reviews I think is the easy winner. And of course, this was not multiple choice, you had to choose one.
So, in order of importance, third-party risk management is one of the bigger aspects people are thinking about, which is great.
So, what is the Akoya 1033 Compliance Solution? And Rishabh alluded to it when he was talking to us about his experience. He mentioned the fact that open banking compliance anywhere in the world is more than just standing up APIs or standardized APIs.
And we understand that. And I think if you're on this call, you understand that, too, right, based on the previous question that you answered.
So, we want to discuss the Akoya solution that covers the entire, end-to-end aspect of your 1033 compliance journey for you.
Fundamental to that – and think of this as layers of the cake – is a developer portal, which is white labeled and branded.
As for your financial institution, right now, that portal has a few aspects that are important. The first thing is your policies, which you are supposed to make available publicly on what your institution believes is your data policy.
The second would be your API documentation, which would be again, white labeled. And then there would be the sandbox and everything else. On the developer portal, you will also have FDX compliant APIs. So, whatever form your data is in, Akoya will pull that data and make it compliant to the latest spec of FDX.
Obviously, assuming that FDX is going to be the standard setting organization in this space. The third part of this is the entire consent management space. Authentication, authorization to consent management. There is an entire workflow that needs to be created with the highest security standards.
And that is what we will do while providing you with the assets that are required for your consumers to have visibility into the applications they have subscribed to and to be able to revoke or manage that consent as they wish. So, you can take those assets and make them available in your digital properties.
So, these three, to my mind – the dev portal, the FDX APIs, and the end-to-end consent management – are the tech stack. Now we have the managed services stack, which starts at the point where you have this developer portal available, and then there are third parties who are knocking on your door, wanting to access your customers’ data.
And that is where the first part of that is onboarding them, and before that, you must do a third-party due diligence on them. This could potentially be your biggest overhead. And we understand there are reports in Europe that up to 20 percent of the fintechs in the market actually went directly to banks to get this data.
So, imagine that in this context in the U.S. there could be hundreds. So, what Akoya can do for you is that we can take our robust app solution that we have created that has been informed by some of the biggest banks in the country. We can layer your risk profile or your risk framework on top of that and we can do this entire process on your behalf.
This still gives you the control so that you have the final ability to say yes or no, but we could do all the challenging work before that.
Adding to that, we would onboard these third parties, and more importantly, we would also provide them with level 1 and level 2 support as they become effective on your platform. So, this is the end-to-end solution from Akoya from all the way from the tech stack to the managed services and everything in between.
We become your partners and can take on these roles. Obviously, this is a very high-level version of this. There is a lot more detail to this as we talk about it in the future.
Why Akoya? Let's start with the fact that we do a lot of this today for some of the most prominent financial institutions in the market.
We do this on a scale, and we have been doing this for a couple of years. So, we have a proven record of accomplishment here. I talked about the modular and flexible tech stack that is critical as you scale your business scales. We need to be able to scale with you so that you get the best performance because you also have a regulatory requirement in terms of performance.
But the modular and flexible tech stack also lends itself to some other use cases, which is what we have discovered as we have been talking to financial institutions. We've realized in the U.S. that no financial institution is the same as the other. So, there could be various aspects of your business that we need to consider while we help you on your journey.
So, for instance, you could have multiple platforms that you get your data from. You could have affiliates and some of those could have come through acquisitions for instance. Or you could be supporting a slew of co brands, where the consumer's affinity is with the co brand and not with you as a financial institution.
We need to be able to take all of those and make a 1033 solution that is viable for you. And that is what our flexible tech stack allows us to do. The third aspect is the risk management piece I talked about, which is the third-party risk management informed by the biggest banks, and other guidance from regulators.
And the context-based part comes in when we work with your risk framework, apply that to our risk model, and we make it appropriate for the third parties that are coming to you. So, in quite simple terms, a financial institution coming to you for data versus a fintech versus an aggregator could go through various levels of due diligence based on the risk that you would describe to them.
And we would administer that on your behalf. And similarly, we would also be able to help you with administering your legal contracts. So, with the third parties, managing the life cycle of those legal contracts and making sure they are renewed and everything else. And finally, as Rishabh mentioned, this is not a one and done game.
The fact is that there are many aspects that the banks are still catching up on while regulations, for instance in Europe, are moving forward. There could be new regulations. There could be more data sets that need to be made available. There could be more use cases that could come in. There could be more security requirements that could come in.
And of course, the standard setting organization even now has two releases in a year in terms of new things that they want you to do. What the Akoya solution will allow you is that this is something that we will do on your behalf on an ongoing basis. So, we do not just make you compliant, we keep you compliant.
Can we do a quick poll again just to get a sense of where everyone is on their 1033 journey?
Where are you in your 1033 compliance journey?
Okay. Again, 15, 20 seconds, slightly more dense copy here. So, I will give it a couple of extra seconds.
Okay. Do you think we can look at the results?
Okay. Discovery phase, business planning phase, technical phase, and okay, we are ready to implement, which is fine, which makes sense in terms of where you should be.
And again, if you work with us, we can take what you have and move forward with you and work towards your compliance deadline and make sure you are there well before time.
Now, I end this section with the fact that Akoya has experience and expertise. By experience, I mean that most of our leadership team today has over two decades of experience in the financial services industry. A lot of us have built products and solutions that needed to be compliant by regulation.
So, we know what it takes, right? So that experience is available to you. We also have the expertise, right? We have a lot of deep open banking expertise in the form of just the people who have been with this industry for an exceptionally long time, including one of the co-founders of FTX, who is our chief evangelist.
How do I know that? Because he does not stop talking about it.
So, as a result, we have the experience and expertise to bring to bear at your doorstep. True partner who can help you on this 1033 journey and make you successful. That is important for you from a regulatory perspective. Right now, as we look at this journey, we are going to have a lot of tools available on our website so that you can work with us.
Some of them are already available. Today, we have launched our Financial Institution Compliance Worksheet. This is a comprehensive worksheet with all the elements that need to go into 1033 compliance, mapping it back to the map that Rishabh had shown right up front. The compliance map, as he called it, is really staged in terms of what the elements are and how much time we believe each of those elements is going to take, right?
So, feel free to download this. You can use the QR code on the screen right now to use, to download this checklist. Use this as your ready record, as we call it. But I think what we would. Is that if you want to set up sometime a 30-minute session with one of our team members, we would love to look at this checklist if you already have it completed and work from there to say what we need, what you would need to be compliant.
Okay, I'm going to hand this back to Olivia at this stage. Thank you.
Olivia Fahey: Thanks, Vijay. So, before we get into the Q&A, I just have one more shameless plug. So, hopefully, you have enjoyed the content today and want to stay with us as we continue our Open Banking Compliance Series. Our next webinar, It's Time to Act. Prioritize CFPB Section 1033 for your Customers, will take place on November 5.
We will be joined by Ramandeep Singh from Capgemini and Behram Panthaki of Akoya. That session will take a very consumer centric lens and discuss how CFPB 1033 will have real benefits, not only for your business, but also for your customers.
So, you can either scan that QR code there or use the link on top there, but that will just bring you to a registration page and hopefully we will see you then on November 5th as well.
So, with that let’s jump into the Q&A session.
If my bank is in the third tranche of 10 33 compliance, which for me seems to be about 30-months post rule making, when should I start planning for compliance in your opinion?
If you want to take that and then Rishabh, please feel free to add on.
Vijay Krishna: Sure. Let me answer it by turning this question on its head a little bit. Fundamentally, let's think about what open banking is allowing, right?
It allows your consumers to avail themselves of products and services in a safe and secure manner. The way we deliver that in a safe and secure manner is through APIs and through all the Auth processes that are involved in that. Now, in the absence of having APIs, you are getting screen scraped, which means that your consumers are giving their login credentials to somebody else who is a third party, putting them and you as a financial institution at risk.
And I totally understand the fact that till now the struggle has been how you create a business case to make these APIs available, because as we have discussed throughout the session, it is all about the effort and the time it is going to take to be compliant. But if now the entire question is about when and not about if, Then I would strongly recommend that you have this conversation within your organization to say, why should we not do it now?
Or at least start on the journey now in terms of discovery to try and get this done quickly just so that you provide the right experience for your consumers, and they are all and the data as well as your bank or your financial institution is safe and secure, right?
So, I would say now is the perfect time, but I'm not saying you need to start building now, you need to start planning now, you need to start the discovery process now, and then you can start thinking about when you want to implement it?
I don't know Rishabh if you have anything else to add to this.
Rishabh Shah: No, I would just agree vehemently with you, Vijay. Primarily because what we have seen in other geographies is. That it's always a rush towards the end when you are up against a regulatory deadline. And in case your financial institution has 30 months (about 2 and a half years) or a lot of time before you hit that deadline. The regulatory timeline gives you time to really plan and do this entire journey very effectively with the right foundations, right? So, I would say use this time.
Vijay Krishna So, I have one more question, which I think I will direct to you, Rishabh.
By which year do you think PSD3 would be adopted by tier 1 banks?
Rishabh Shah: It's a loaded question, but today we are talking about 1033, so PSD3, PSR and FIDA are topics from a Europe perspective.
I would say the regulatory timelines will be around 2026 when a lot of these things will have to be implemented. But again, coming back to the topic of this conversation, which is 1033 compliance, we would say the regulators tend to influence each other. That is what we have seen, right?
So, a lot of those experiences from PSR, PSD3, as well as FIDA are likely to also cross the Atlantic Ocean and have some impact in the U.S. as well. But that is a hypothesis, right? You never know what will happen.
Vijay Krishna: That's fair. Rishabh, I am sorry. I'm going to put you on the spot again.
There is one more question.
You provided some insight into the profile of the data recipients that are coming in directly to the financial institutions in Europe? Is there a certain profile? Is it more widespread?
Rishabh Shah: The bigger the open banking ecosystem is, the more complex it becomes and the more complex the integration problems between the participants.
So let me try and explain what I mean by this. If there are 10 third parties and 10 banks, it is a manageable problem from an integration perspective. But the moment you have a thousand third parties and a thousand financial institutions that those third parties must reach, it becomes an extremely difficult integration problem to solve, right?
And then the business question in front of the data recipients is, do I want to solve the integration problem? Or should I focus on the value-added services that must be delivered to the end consumer? And that is the realization that I see starting to happen in a lot of geographies.
And this is assisted by the fact that not only have a lot of the data aggregators solved for the integration problem or solved to quite a considerable extent the integration problem, but they have also started offering a lot of value-added services in terms of classification of transactions, right?
Which helps in the implementation of the use cases to the data recipients. So, I see many institutions starting to depend on the data aggregators. For the connectivity-related things and some of the foundational data classification data tagging use cases, while the data recipients start building on in terms of the value-added services, what is the actual customer proposition that they really want to take to their end consumers. That is how I see it. And again, just to say that every market is going to be different. The U.S. market is quite different than the European market. So, this is something that will play out.
Vijay Krishna: Yeah. Absolutely.
The kind, the number of banks and the number of indexes, obviously multiples of what we have in Europe. So, it's going to be interesting to look at.
Olivia, this is a question for you.
Will the presentation be shared with participants and what other assets are we going to share?
Olivia Fahey: Yes, afterwards we will share a recording of the webinar out, any unanswered questions and a PDF version of this presentation along with again, pointing people to that financial institution readiness worksheet that is available on at Akoya.com as well.
Vijay Krishna: Cool. We have time for one or two more and I will see a few more. Does Akoya’s compliance solution comply with multiple API standards? For example, could it be implemented for a multinational institution that has to comply with both 1033 directive and Brazil's open banking scheme?
The honest answer is we don't know. I think it will require a deep dive where we sit together and we try and look at the schemas and we try and compare the schemas to see where the disconnects are fundamentally, if you're looking at the primary use cases for open banking, The data sets and the data clusters should align.
Now, the fact is, can you use the same framework for another market? I don't know, Rishabh, is that something that the regulators are looking at as they what have you seen? How similar are the schemas as you have seen them get deployed across the globe?
Rishabh Shah: So, most of the schemas have evolved from the ISO standards the ISO messaging standards because that existed when there was nothing else in terms of the open banking standards, right?
And I am talking way back in 2016, 2017. So, the schemas are certainly similar, right? But every geography has regionalized the schemas. To suit the specific local context, right? For example, if you really look at a lot of the schemas in Brazil, you will find certain extremely specific information that you might not really see in the, in, in the U.K. standard, for example, right?
So, there are differences between these standards as they have evolved in different geographies. And the way we approach it is that when you are moving from one country to another, there is a regionalization that must be done, even if you have the core platform and solution available, right?
So, the core will take you 60, 70 percent of the way, but then there is a customization that must be done for every geography that you want to implement the solution.
Vijay Krishna: Perfect. Okay. I think I’ll just try and squeeze in one last one. So, the question is:
What is the biggest opportunity for community banks and credit unions?
I can take that quickly. I feel fundamentally it's about the consumer. Okay. Those consumers are going outside the financial institution to avail themselves of some services and they're going to do that. And that's what happened today. So, the question is, how do you make sure that your part of that entire journey, right?
How do you make sure that the consumer does not feel like they're getting compromised? They must provide their credentials to a third party to provide access to their bank. So, I think if you look at it from that lens, I feel like the community banks and credit unions have a unique position where the journey requires the consumer to go to the bank, authenticate.
Now, if the bank provides incremental controls, like one of my financial institutions, every three to six months sends me a message to say, listen, these are all the players that you are providing data to. Do you want to continue? Do you want to discontinue? Suddenly you start coming across as somebody who cares ... it's not about the fact that the data is coming out from them, but you as a consumer are important to them, right?
There are various aspects to this, I would say, in terms of how credit unions and community banks can take advantage of this. But fundamentally, it is about consumer engagement and being in the middle of that entire process.
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