Contact: Laine Williams, (202) 897-4757, lwilliams@allonadvocacy.com
Washington, DC, September 18, 2025 – The Financial Data and Technology Association (FDATA), a trade association representing more than 30 financial technology companies and consumer-permissioned data access platforms in Canada and the United States, today submitted comments in response to the joint Request for Information (“RFI”) issued by the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Fed), and the Federal Deposit Insurance Corporation (FDIC) on potential actions to address payments fraud.
In its response, FDATA highlighted the urgent need to modernize America’s payment infrastructure by reducing reliance on paper checks and prioritizing secure digital alternatives, particularly pay-by-bank. Citing the surge in check fraud—more than 680,000 reports filed by U.S. banks in 2022 alone—FDATA warned that systemic fraud risks will persist until policymakers ensure consumers and businesses have the legal right to permission access to their financial data.
“Replacing vulnerable paper instruments with secure digital payments must be a top priority for regulators,” said FDATA Executive Director Steve Boms. “Pay-by-bank, enabled by consumer-permissioned data access, represents a once-in-a-generation opportunity to reduce fraud, lower costs, and expand access. But success depends on preserving Section 1033 of the Dodd-Frank Act, which provides the legal foundation for these services.”
FDATA’s letter emphasized three core recommendations for the agencies:
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Recognize pay-by-bank as a core fraud-reduction tool;
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Encourage coordination with the CFPB to preserve Section 1033 data-access rights; and
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Promote open banking and consumer-permissioned payments as protected use cases within supervisory frameworks.
FDATA and its members—who serve more than 100 million consumers and small businesses—underscored that without a clear legal right to access and share financial data, pay-by-bank will remain fragmented and underdeveloped, leaving paper checks as a weak link that criminals continue to exploit.
A full copy of the comment letter is available here.
