Join CDIA and Chris Napier, Partner, Mitchell Sandler, Melissa Baal Guidorizzi, Partner, Davis Wright Tremaine, and Shelby Schwartz, Counsel, Mitchell Sandler, as they explore the evolution of the existing Rule, its historical impact on the consumer reporting industry, and the key questions raised in the reopened rulemaking process. Moderated by Benjamin Corb, SVP for Strategy and Public Affairs, CDIA, this session will examine where the regulation may be headed, with particular focus on the potential narrowing of authorized third‑party access and the resulting implications for Fair Credit Report Act (FCRA) coverage. We will also discuss how data aggregators' access to bank transaction data may affect their regulatory status as CRAs, and the broader regulatory risks, benefits, and uncertainties facing both CRAs and users of consumer reports.
Building on this foundation, we will address how Section 1033 is reshaping transaction‑level data flows across the financial, data, and payments ecosystem. The conversation will include how data aggregators should begin preparing for potential FCRA compliance obligations, and how the convergence of crypto, data access, and payments innovation will influence market structure and regulatory expectations moving forward.