Before we address untapped industries outside the financial space, it is important to note that the wealth management use cases have not yet received sufficient attention in the design and implementation of open banking/finance in the US and Canada. Current initiatives are almost exclusively focused on retail banking use cases for personal financial management (PFM), lending and payments—with asymmetric and incomplete coverage of investing, advice, education, and retirement related use cases. These issues are insufficiently addressed by the current Consumer Financial Protection Bureau’s NPRM of the Dodd-Frank Act Section 1033: lacking support by providers and technical standards organizations for delegated access in the consent and authentication flows, inconsistent data parity by providers who do publish APIs, and prohibitions on screen-scraping by those that don’t publish APIs without alternative access solutions.
There also exists an unfair characterization that wealth management use cases are only for the rich, rather than for everyday workers, retirees, and their families who need to prepare for and live fruitful and dignified lives. Saving for and funding education, caring for elderly or disabled family members, and ensuring a safe retirement are more prevalent needs than those of the ultra-high-net worth
The CFPB and the SEC should join forces to ensure a unified data sharing ecosystem that will also support the SEC’s Reg-BI to ensure advisors’ fiduciary duty.
