Tag, You’re It: Navigating Smarter Data Sharing

Jane Ginn

2 days ago

The CSDF Tagging Guidelines are a foundational component of the Financial Data Exchange (FDX) ecosystem, designed to work in tandem with the Consensus Standard Data Format (CSDF) of the June 2025 API v6.4.0 release. These guidelines play a critical role in helping data providers, aggregators, and application developers efficiently implement regulatory requirements, improve security, and deliver consistent, user-friendly experiences.

How CSDF Tagging Works

At its core, the CSDF is a subset of the FDX API specification, tailored to meet the Consumer Financial Protection Bureau’s (CFPB) Personal Financial Data Rights Rulemaking (PFDR) requirements. The CSDF Tagging Guidelines provide a systematic approach for identifying and marking (“tagging”) which data elements, endpoints, and operations within the FDX API are relevant for compliance with regulations such as Section 1033 of the Dodd-Frank Act.

By tagging only those elements required for regulatory compliance, data providers can minimize their API surface area, reducing potential attack vectors and exposure of sensitive data.

Key Features of Tagging:

Specification Extensions as Tags: FDX uses custom OpenAPI specification extensions (e.g., x-fdx-csdf-account-categories and x-fdx-csdf-technical) to tag schemas, properties, paths, and operations within the API files.
Regulatory Mapping: Tags indicate whether an element is required for Regulation E (REGE, deposit accounts), Regulation Z (REGZ, credit accounts), or both (ANY). Technical tags (x-fdx-csdf-technical) identify elements necessary for technical implementation but not directly representing account data, such as pagination or availability metrics.
Reference List Integration: The tagging system is closely tied to the CSDF Reference List, which compiles all data elements potentially required under PFDR. Tags in the API files map directly to this list, making it easy for implementers to filter and identify which elements are needed for their specific regulatory obligations.

Why Tagging Guidelines Matter

1. Improving Security

Granular Control: By tagging only those elements required for regulatory compliance, data providers can minimize their API surface area, reducing potential attack vectors and exposure of sensitive data.
Standardized Security Profiles: The CSDF mandates implementation of approved security profiles (OAuth 2.0-based “Green” or FAPI 2.0-based “Blue”), ensuring robust authentication, authorization, and encryption for all tagged endpoints.
Technical Consistency: Tagged elements ensure that only properly formatted, secure data flows through the API, supporting end-to-end encryption and step-up authentication where needed.

2. Meeting Regulatory Requirements

Regulatory Alignment: The tagging system directly supports compliance with CFPB Section 1033 by making it clear which data elements are considered “covered data” for deposit and credit accounts, as well as digital wallets.
Adaptability: Since the PFDR Rulemaking sometimes defines covered data in broad terms, tagging allows each data provider to interpret and implement only those elements they deem necessary, while still aligning with the consensus standard.
Conformance Testing: FDX provides conformance tests that check whether the tagged elements are implemented and formatted correctly, offering transparency and confidence to regulators and industry partners.

3. Providing Seamless User Experience

Clarity and Consistency: Tagging ensures that only relevant data is shared, which aligns with FDX user experience guidelines emphasizing transparency, control, and data minimization for end users4.
Consent Management: By mapping tags to data clusters and consent scopes, providers can clearly communicate to users what data will be shared, for what purpose, and for how long—supporting easy consent granting, management, and revocation.
Interoperability: Standardized tagging across the ecosystem enables consistent experiences across different platforms and providers, reducing confusion and friction for users navigating data sharing and consent journeys.

Conclusion

The CSDF Tagging Guidelines are much more than a technical tool—they are a bridge between regulatory compliance, security best practices, and user-centric design. By leveraging a robust, extensible tagging system, FDX enables the financial industry to deliver secure, compliant, and seamless data sharing experiences, building trust and transparency for all stakeholders.

To read more of my articles about the FDX API v6.4.0 Spring 2025 release see the following:

References:

Jane Ginn CTIN President & Co-Founder

Jane Ginn ~ As the co-founder of the US-based Cyber Threat Intelligence Network (CTIN), a consultancy with partners in Europe, Ms. Ginn has been pivotal in the development of the STIX international standard for modeling and sharing threat intelligence. She also served as the Secretary of the OASIS Threat Actor Context Technical Committee, contributing to the creation of a semantic technology ontology for cyber threat actor analysis. Her efforts in this area and her earlier work with the Cyber Threat Intelligence (CTI) TC earned her the 2020 Distinguished Contributor award from OASIS. She is currently supporting the analysis services of Datos Insights, an advisory firm focusing on the financial services sector. In public service, she advised five Secretaries of the US Department of Commerce on international trade issues from 1994 to 2001 and served on the Washington District Export Council for five years. In the EU, she was an appointed member of the European Union's ENISA Threat Landscape Stakeholders' Group for four years. A world traveler and amateur photojournalist, she has visited over 50 countries, further enriching her global outlook and professional insights.

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