US institutions preparing for Section 1033 of the Dodd-Frank Act, or for the state-level open banking legislation currently in motion, need continuous visibility into the third-party providers and intermediaries connecting through their systems, not just a one-time check against requirements that are still being finalized.
What readiness actually requires
- Assessment aligned to the emerging standard: Verify providers against defined financial, operational, security, and Artificial Intelligence (AI) governance criteria consistent with where Section 1033 and state-level rulemaking is heading.
- Continuous monitoring, since the framework is still taking shape: Build for ongoing visibility rather than a fixed compliance snapshot, since Section 1033's implementation timeline has faced legal challenges and delay, and several states are separately advancing their own open banking rules in the meantime.
- A clear liability position ahead of enforcement: Establish, in advance, who responds to the customer first when something goes wrong – particularly given that liability under a data access agreement may route to the aggregator rather than the bank, but the account-holding institution is typically still first to respond regardless of where the agreement places responsibility.
About Invela
Invela is the infrastructure layer that makes open finance trustworthy – accrediting who's in the network, monitoring risk in real time, and ensuring liability lands in the right place. Open finance, covered.
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