News

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FDATA North America Provides Input in Response to Canada’s 2025 Pre-Budget Consultation

Contact: Layne Dillon, (202) 897-4837,  [email protected]

March 10, 2025, Washington, DC – The Financial Data and Technology Association of North America (FDATA), a trade association representing approximately three dozen financial technology organizations that provide consumers and small- and medium-enterprises with innovative financial products, services, and tools, today submitted its response to the Canadian Department of Finance’s 2025 pre-budget consultation.

In our submission, we urged the Department of Finance to:

  1. Hasten delivery of open finance in Canada: The implementation of consumer-driven finance in Canada has been plagued by delays. Amidst significant economic uncertainty, FDATA North America encouraged the Government to prioritize delivering a comprehensive open finance regime to Canadian consumers and small- and medium-enterprises.
  2. Adjust the initial design of Canada’s open finance regime: We encouraged the Government to revise elements of its initial open finance regime to promote competition and innovation in Canada’s financial sector, including clearly providing for the inclusion of small- and medium-enterprises in the system, providing the Bank of Canada with the authority to oversee the system, and devising a tiered accreditation framework that will allow Canadian startups to come to market and flourish.

A full copy of the comment is available here.

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FDATA North America March 2025 Newsletter

FDATA North America Monthly Newsletter for March 2025

Welcome to FDATA North America’s monthly newsletter! These regular dispatches will share developments from our organization and our 30+ member companies, all of which are promoting financial access and inclusion with open finance use cases. We also include a list of upcoming industry events, and coverage of any market developments that impact fintech innovators. Know someone who’d like to receive these monthly updates? Send them here to sign up.

FDATA North America News

FDATA North America Statement on the Designation of Treasury Secretary Scott Bessent as Acting Director of the CFPB. On February 3, 2025, the Financial Data and Technology Association of North America (FDATA) welcomed the appointment of Scott Bessent as Acting Director of the Consumer Financial Protection Bureau (“CFPB” or “Bureau”). Steve Boms, Executive Director of FDATA North America, released the following statement: “Acting Director Bessent takes the helm at a crucial moment for financial data access and consumer protection. As the CFPB moves toward finalizing the implementation of Section 1033, we urge the Bureau to uphold its commitment to ensuring a competitive, innovative, and consumer-centric financial ecosystem. We look forward to engaging with Acting Director Bessent and his team to advance policies that empower consumers and support financial inclusion.” Read the full statement here.

FDATA North America Submits Comments to the CFPB’s NPRM on the Fair Credit Reporting Act. On February 24, 2025, the Financial Data and Technology Association of North America (FDATA) submitted comments to the CFPB opposing the misclassification of consumer-permissioned open finance platforms as CRAs under the FCRA. The proposed rule creates regulatory contradictions with the CFPB’s Section 1033 rule, adds compliance burdens, and risks limiting consumer choice. FDATA urges the CFPB to exclude these platforms from Regulation V or rescind the proposal to avoid disrupting consumer-permissioned data access. Read the full release here. Read the full letter here.

Member News & Activity

Basis Theory published a blog on how merchants can migrate to a new payment processor without disruptions. The post highlights common migration challenges, such as transferring stored customer payment data, and explains how using a third-party tokenization service provider (TSP) like Basis Theory can simplify the process. By securely storing cardholder data in a programmable vault, merchants can seamlessly switch between PSPs, avoid excessive fees and delays, and even implement a multi-processor strategy for cost savings and improved transaction success.

GoCardless’s Lewis Turek, General Manager of North America, was featured on the latest episode of What the FinTech? to discuss the evolving digital payments landscape in North America. He joins FinTech Futures editor Paul Hindle to explore how businesses in the region manage payments differently than those in the UK and Europe, the challenges of adopting new payment methods, and how GoCardless is driving innovation. Plus, Lewis shares which fintech buzzword he’d lock away in Fintech Jail!

Method published a blog on the transformative power of bank-fintech partnerships and how they drive financial innovation and inclusion. These collaborations combine the infrastructure of traditional banks with fintech agility, enabling use cases such as reducing the cost of credit, facilitating debt repayment, and delivering real-time financial insights. Method’s platform bridges the gap between financial institutions and consumers, ensuring secure, scalable solutions that empower individuals to manage their finances effectively.

Plaid was recognized on the Forbes Fintech 50 list for the 10th consecutive year. Over the past decade, finance has evolved, and we’re proud to continue driving innovation in payments, credit, and fraud prevention. Congratulations to our customers and partners who were also recognized—here’s to shaping the future of finance together.

Trustly was featured in a report highlighting the growing adoption of Open Banking in the travel sector, with a 230% increase in spending via Pay by Bank in the UK compared to last year. As airlines and hotel providers seek to reduce fraud risk, cut processing fees, and improve cash flow, Open Banking is becoming a key payment option alongside traditional cards. Trustly’s expansion into the U.S. through partnerships like Spreedly signals further momentum, despite challenges from established payment giants.

VoPay published a blog on the critical role of payment automation in property management software, highlighting how automation streamlines operations, ensures compliance, and enhances scalability. As property managers handle increasing transaction volumes, automated solutions reduce manual workloads, prevent payment delays, and improve financial transparency. By embedding payment automation tools, platforms can offer seamless compliance, flexible payment methods, and scalable solutions that drive efficiency and growth.

Events and Submission Deadlines

  • March 7, 2025Fair Credit Reporting Act (Regulation V); Identity Theft and Coerced Debt Comment Letter Due Date
  • March 11, 2025, 10 a.m. ET — HFSC hearing titled, “Navigating the Digital Payments Ecosystem: Examining a Federal Framework for Payment Stable coins and Consequences of a U.S. Central Bank Digital Currency”
  • March 25, 2025, 10 a.m. ET — HFSC Capital Markets Subcommittee hearing titled, “Beyond Silicon Valley: Expanding Access to Capital Across America”
  • March 26, 2025, 10 a.m. ET — HFSC Financial Institutions Subcommittee hearing titled, “A New Era for the CFPB: Balancing Power and Reprioritizing Consumer Protections”
  • March 31, 2025 — Comments due on CFPB on digital payment privacy and consumer protection proposed rule (information here)
  • March 31, 2025 — Comments due to the HFSC on improving investor access and capital formation (information here)
  • April 2, 2025 — Comments due on the CFPB’s “data broker” NPRM (information here)
  • April 11, 2025 — Comments due on CFPB request for information regarding the collection, use, and monetization of consumer payment and other personal financial data (information here)
  • April 21-22, 2025 — Financial Data Exchange Global Summit (information here)
  • May 5, 2025: FDATA 2025 Open Finance Summit, Washington, DC
    • Join us at the FDATA 2025 Open Finance Summit, where key policymakers, regulators, and industry leaders will convene to discuss the state of open finance and payment modernization, and share insights and lessons learned from around the globe.
    • Reserve your hotel room here; Rate Code: G-FDA3; Room Cutoff Date: April 4, 2025.
    • Want more information on sponsorship opportunities? Interested in speaking? Have questions? Contact: [email protected]
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FDATA North America Submits Comments to the CFPB’s NPRM on the Fair Credit Reporting Act

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, February 24, 2025 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today submitted comments in response to the Consumer Financial Protection Bureau’s (“CFPB”) Notice of Proposed Rulemaking (“NPRM”) on the Fair Credit Reporting Act (“FCRA”).

In the letter, FDATA North America expressed concern that the proposed rule would inappropriately classify consumer-permissioned open finance platforms and financial providers as consumer reporting agencies (“CRAs”), creating consumer confusion and regulatory contradictions with the CFPB’s recently finalized Section 1033 rule. FDATA North America warned that this misclassification could impose unnecessary regulatory burdens, create legal uncertainty, and hinder financial innovation without providing any additional consumer protections.

The submission urged the CFPB to explicitly exclude consumer-permissioned open finance and financial providers platforms governed under the Bureau’s Section 1033 rulemaking from the proposed changes to Regulation V. FDATA North America also highlighted that the NPRM’s expanded definitions of data assembly and de-identified data could inadvertently subject a broad range of financial service providers—including data analytics firms and financial software providers—to CRA regulations, despite their activities not aligning with traditional credit reporting functions or Congress’ intended application of the Fair Credit Reporting Act (“FCRA”).

FDATA North America asserted that the CFPB’s final Section 1033 rule already establishes clear consumer protections and regulatory guidelines for authorized third-party financial data access. Applying the FCRA to consumer-permissioned open finance platforms would introduce conflicting compliance requirements, increase liability risks, and undermine the principles of consumer control and transparency that the CFPB has sought to promote through its open banking framework.

Given these concerns, FDATA North America recommended that the CFPB revise the proposed rule to remove consumer-permissioned open finance platforms and financial providers from its scope. If these revisions cannot be made, we strongly advised rescinding the proposal to prevent disruptions to existing consumer-permissioned data access models.

A full copy of the letter is available here.

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FDATA North America February 2025 Newsletter

FDATA North America Monthly Newsletter for February 2025

Welcome to FDATA North America’s monthly newsletter! These regular dispatches will share developments from our organization and our 30+ member companies, all of which are promoting financial access and inclusion with open finance use cases. We also include a list of upcoming industry events, and coverage of any market developments that impact fintech innovators. Know someone who’d like to receive these monthly updates? Send them here to sign up.

FDATA North America News

FDATA North America Urges Minister LeBlanc to Implement Canada’s Consumer-Driven Finance Framework. On January 16, 2025, the Financial Data and Technology Association of North America (FDATA) sent a letter to The Hon. Dominic LeBlanc, Minister of Finance and Intergovernmental Affairs, urging him to prioritize the long-delayed implementation of Canada’s consumer-driven finance framework. FDATA North America emphasized the urgent need to establish an open finance regime that fosters affordability, competition, and improved consumer access to financial services, noting that Canadians still lack these benefits seven years after the government first announced its intention in Budget 2018. The letter highlighted how granting consumers control over their financial data would help address barriers created by Canada’s highly concentrated financial sector, where high fees, limited credit access, and slow transaction settlement times are common challenges. With Minister LeBlanc being the third finance minister with the opportunity to deliver a consumer-centric ecosystem, FDATA North America urged him to advance this initiative and reaffirmed its readiness to provide data, insights, and support. A full copy of the letter is available here. Read the full release here.

Member News & Activity

GoCardless was featured in Fintech Futures, where Pat Phelan, Chief Customer Officer and Managing Director of UKI, GoCardless, highlighted the advantages of being an early adopter of payment technology. While open banking payments in the UK now exceed 22 million per month, they are still years away from becoming mainstream. Drawing parallels to the decades-long evolution of credit cards, Phelan emphasized that adopting new payment technology early can provide businesses with a competitive edge, improved efficiency, and better financial visibility. GoCardless’ research with 11:FS found that businesses using open banking reported faster payments (48%), reduced fraud (35%), and lower payment management costs (33%). Beyond these benefits, early adopters position themselves as market leaders, enhance customer acquisition and retention, and gain a critical learning curve advantage—potentially shaping the development of new financial products.

Method was featured in TechCrunch for its role in helping fintech companies like SoFi integrate repayment functionality into their apps. By leveraging consumer credit access protections from the Dodd-Frank Act, Method aggregates users’ debts and enables balance transfers, bill payments, and payoffs through a seamless API that requires only a phone number. With over 30 million account connections and $500 million in liability repayments facilitated, the company recently raised a $41.5 million Series B to expand its banking partnerships and credit card integrations, aiming to enhance the user experience and increase conversion for fintechs.

MX published a blog highlighting how Open Banking is becoming a key competitive advantage for financial institutions, with new research showing that 55% of U.S. consumers would share more financial data in exchange for a better experience—up from 46% in May 2024. With new regulations like the CFPB’s Section 1033 ruling and Canada’s consumer-driven banking framework solidifying data ownership and privacy rights, institutions that embrace Open Banking can gain deeper insights, personalize offerings, and stay ahead of the competition. While some may delay adoption due to regulatory uncertainties, MX emphasizes that early adopters will be better positioned to succeed in 2025, while those who wait risk falling behind.

Ozone API published a blog celebrating the Consumer Financial Protection Bureau’s (CFPB) official designation of Financial Data Exchange (FDX) as a Standards Setting Body on January 8, 2025, marking a major milestone for open banking in the United States. With over 94 million U.S. accounts already using the FDX API, this move solidifies a regulated framework under Section 1033 and positions the U.S. as a leader in financial data access and security. Industry leaders, including Don Cardinal of FDX and Eyal Sivan of Ozone API, emphasized that this recognition removes uncertainty, allowing data providers to move forward with confidence in building secure, interoperable financial APIs. Ozone API also provided key resources to help financial institutions navigate Section 1033, including technical guides, security insights, and expert discussions on open banking implementation.

Pontera posted a blog highlighting the disparities in retirement savings, particularly among women, people of color, and individuals with lower educational attainment, emphasizing the systemic barriers that prevent equal access to financial security. The blog underscores the need for personalized financial guidance, expanded access to employer-sponsored plans, and increased financial literacy to help close the retirement gap. Advisors can play a crucial role by educating underserved communities, advocating for equal pay and workplace opportunities, and leveraging resources like the DOL’s lost and found retirement account database to ensure more equitable financial outcomes.

Events and Submission Deadlines

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FDATA North America Statement on the Designation of Treasury Secretary Scott Bessent as Acting Director of the CFPB

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, February 3, 2025 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today welcomed the appointment of Scott Bessent as Acting Director of the Consumer Financial Protection Bureau (“CFPB” or “Bureau”).

Steve Boms, Executive Director of FDATA North America, released the following statement:

“Acting Director Bessent takes the helm at a crucial moment for financial data access and consumer protection. As the CFPB moves toward finalizing the implementation of Section 1033, we urge the Bureau to uphold its commitment to ensuring a competitive, innovative, and consumer-centric financial ecosystem. We look forward to engaging with Acting Director Bessent and his team to advance policies that empower consumers and support financial inclusion.”

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FDATA North America Urges Minister LeBlanc to Implement Canada’s Consumer-Driven Finance Framework

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, January 16, 2024 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today sent a letter to The Hon. Dominic LeBlanc, Minister of Finance and Intergovernmental Affairs, urging him to prioritize the long-delayed implementation of Canada’s consumer-driven finance framework.

FDATA North America highlighted the  urgent need to ensure Canadians benefit from an open finance regime to foster affordability, competition, and improved consumer access to financial services. In the letter, we underscored that Canadians still lack these benefits seven years after the Government first announced its intention to establish a consumer-driven finance ecosystem in Budget 2018.

By empowering Canadians with control over their financial data, FDATA North America emphasized that such a framework would address barriers created under Canada’s highly concentrated financial sector. In this environment, consumers and small businesses frequently face high fees, limited access to credit, and slow transaction settlement times.

The letter noted that Minister Dominic LeBlanc is the third Minister of Finance with the opportunity to deliver an inclusive, consumer-centric ecosystem that could significantly improve the financial wellbeing of millions of Canadians. FDATA North America urged Minister LeBlanc to advance this initiative and reaffirmed its readiness to provide data, insights, and support to advance this critical work.

A full copy of the letter is available here.

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FDATA North America January 2025 Newsletter

FDATA North America Monthly Newsletter for January 2025

Welcome to FDATA North America’s monthly newsletter! These regular dispatches will share developments from our organization and our 30+ member companies, all of which are promoting financial access and inclusion with open finance use cases. We also include a list of upcoming industry events, and coverage of any market developments that impact fintech innovators. Know someone who’d like to receive these monthly updates? Send them here to sign up.

FDATA North America News

FDATA North America Statement on the CFPB’s Proposed Rule Under FCRA. On December 3, 2024, FDATA North America (FDATA) expressed disappointment with the Consumer Financial Protection Bureau’s (CFPB) Notice of Proposed Rulemaking (NPRM) under the Fair Credit Reporting Act (FCRA). Steve Boms, Executive Director of FDATA North America, stated that the proposed rule is a significant misstep, as consumer-permissioned data access platforms are not “data brokers” and should not be regulated as such. He warned that the CFPB’s proposal risks creating a regulatory framework that contradicts its final Section 1033 rule, potentially undermining consumer choice, control, and competition—key benefits of open banking. Boms emphasized the potential negative consequences for consumers and the financial tools they rely on, urging the CFPB to reconsider its approach. Read the full statement here.

FDATA North America Submits Comments to the FDIC’s NPRM on Recordkeeping for Custodial Accounts. On December 6, 2024, FDATA North America (FDATA) submitted comments on the FDIC’s Notice of Proposed Rulemaking (NPRM) regarding recordkeeping for custodial accounts. FDATA supports the FDIC’s goal of protecting customer funds and enhancing transparency but urged clarification that non-transactional settlement accounts should not be classified as “custodial deposit accounts with transactional features.” These accounts, vital for digital payments and e-commerce, act as temporary conduits without granting transactional rights to account owners. Imposing customer-level recordkeeping on these accounts could disrupt payment systems and increase costs unnecessarily. FDATA also called for regulatory coordination, emphasizing alignment with other actions, such as the finalized Section 1033 rule, to foster innovation, protect consumers, and ensure affordable financial services. A full copy of the letter is available here. Read the full release here.

FDATA North America Statement on the Incoming Chair of the House Financial Services Committee. On December 12, 2024, FDATA North America (FDATA) congratulated Representative French Hill (R-AR) on his appointment as the next Chair of the House Financial Services Committee. Steve Boms, Executive Director of FDATA North America, praised Rep. Hill’s dedication to fostering financial innovation during his time on the Committee and expressed enthusiasm for continued collaboration in the next Congress. Boms emphasized the importance of ensuring that consumers and small businesses have free and full access to third-party financial tools and data, which are essential for financial inclusion, competition, and economic growth. He conveyed confidence that, under Rep. Hill’s leadership, the Committee will support policies that empower consumers, drive innovation in financial services, and establish a legally binding consumer financial data right. Read the full statement here.

FDATA North America Statement on Consumer-Driven Banking Proposals in the Fall Economic Statement. On December 16, 2024, FDATA North America (FDATA) expressed disappointment with the government’s Fall Economic Statement (FES) proposals to expand the Consumer-Driven Banking Act (CDBA) and the delay in implementation by at least another year. Steve Boms, FDATA’s Executive Director, criticized the one-size-fits-all approach, which burdens innovative fintech providers with compliance obligations while offering minimal consumer protection benefits, ensuring only the largest tech companies and financial institutions can participate. This approach undermines the government’s goals of fostering competition and affordability, discouraging new entrants and stifling innovation. Instead of supporting a competitive fintech ecosystem, the framework risks solidifying dominance by a few large incumbents. FDATA urges the government to accelerate the delivery of consumer-driven banking and reconsider its accreditation approach to ensure Canadians and SMEs benefit from the increased choice and innovation a true open finance framework can deliver. Read the full statement here.

Member News & Activity

ByAllAccounts published a blog, emphasizing the need to advance data sharing practices under the CFPB’s final Section 1033 rule to build a comprehensive open finance framework. While the rule is a significant milestone, its current scope creates disparities by excluding non-banking and credit card accounts. Wealth management, where accurate and complete data is essential for planning and advice, is particularly impacted. To address this, the financial industry must prioritize uniform account typing, provide full tax lot data, and establish consistent recognition of delegate authority through APIs. By evolving standards ahead of future regulation, consumers can fully and securely utilize their financial data across all account types.

Plaid‘s John Pitts, Head of Policy, was featured in Open Banker, sharing insights on effective policy advocacy. He emphasizes understanding the differing incentives between businesses and regulators, the importance of contextualizing new risks, and the advocate’s responsibility to clearly explain their position to policymakers. Pitts highlights the value of credibility, advocating for transparency about both benefits and flaws in a proposal to build trust. He also notes that meaningful relationships with policymakers are built on credibility and substance, not superficial connections, reinforcing the need for thoughtful and honest advocacy.

Plaid published a blog highlighting findings from a survey of over 200 bank executives. The post emphasizes the dual role of open banking as both a regulatory requirement and a strategic tool for innovation and customer engagement. While larger banks report higher confidence in meeting new regulatory requirements, regional and smaller institutions face challenges in readiness and digital adoption. Plaid underscores the importance of partnering with trusted providers to enhance compliance, leverage consumer-permissioned data, and drive transformative growth in the financial services industry.

MX posted a blog highlighting the release of Canada’s Consumer-Driven Banking Framework, aimed at enhancing financial safety, consumer protection, and competition in the financial services sector. Overseen by the Financial Consumer Agency of Canada (FCAC), the framework mandates accredited entities to securely access consumer-permissioned data and ensures strong privacy, security, and liability protections. Initially focused on major banks, it prohibits screen scraping and requires standardized APIs for data sharing. With full implementation targeted for early 2026, the framework aligns with global best practices while emphasizing consumer control and interoperability with the U.S. open banking standards.

Trustly was featured in The Paypers discussing how Open Banking is revolutionizing payments by offering faster, more secure, and cost-effective alternatives to traditional card networks. By enabling direct payments from bank accounts, Open Banking reduces transaction costs, improves conversion rates, and enhances security for merchants while giving consumers more choices, lower prices, and instant payment options. Trustly’s success stories, including partnerships with HMRC and PointsBet, demonstrate the transformative impact of Open Banking across industries. As a leader in the field, Trustly is committed to driving innovation and empowering businesses and consumers through its advanced Open Banking platform.

Events and Submission Deadlines

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FDATA North America Statement on Consumer-Driven Banking Proposals in the Fall Economic Statement

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, December 16, 2024 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today expressed its disappointment with the proposals laid out by the government in the Fall Economic Statement (“FES”) to expand the Consumer-Driven Banking Act (“CDBA”), and the government’s announcement that implementation of consumer-driven banking would be delayed by at least another year.

Steve Boms, Executive Director of FDATA North America, released the following statement:

“After almost seven years of deliberations and consultations, the Government has unfortunately put forth an open finance framework that will only further the status quo. By adopting a one-size-fits-all approach, the consumer-driven banking framework advanced by the Government loses the forest for the trees, burying innovative fintech providers in a sea of compliance obligations with little to no consumer protection benefit and guaranteeing that few, if any, fintech platforms will be able to use the open finance system the Government has spent the last several years designing.

A one-size-fits-all-approach will ensure that only the very largest tech companies and financial institutions will have the means to participate in the open finance system the proposed legislation would create. This is a direct contradiction to the Government’s stated goals of fostering competition in financial services and improving affordability for Canadians. This framework will discourage new entrants and stifle the very innovation that open banking was meant to support. Instead of promoting a vibrant and competitive fintech ecosystem, this framework threatens to further formalize a market dominated by just a handful of large incumbents.

We urge the Government to prioritize delivery of consumer-driven banking as soon as possible and to its approach to accreditation, as the current approach risks thwarting the promise of open finance in Canada and denying consumers and small and medium-sized enterprises the benefits of increased choice and innovation that a true open finance framework can provide.”

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FDATA North America Statement on the Incoming Chair of the House Financial Services Committee

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, December 12, 2024 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today congratulated Representative French Hill (R-AR) on being named the next Chair of the House Financial Services Committee.

Steve Boms, Executive Director of FDATA North America, released the following statement:

“We have greatly appreciated Rep. Hill’s commitment to fostering financial innovation throughout his tenure on the Committee. We look forward to working closely with him during the next Congress to ensure that consumers and small businesses have free and full access to third-party financial tools and data — a crucial foundation for financial inclusion, competition, and economic growth.

Under his leadership, we are confident that the Committee will continue to support policies that empower consumers, promote innovation in the financial services ecosystem, and ensure a legally binding consumer financial data right.”

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FDATA North America Submits Comments to the FDIC’s NPRM on Recordkeeping for Custodial Accounts

Contact: Laine Williams, (202) 897-4757,  [email protected] 

Washington, DC, December 6, 2024 – The Financial Data and Technology Association of North America (FDATA), a trade association representing more than three dozen financial technology and open finance companies in the United States and Canada, today submitted a comment in response to the Federal Deposit Insurance Corporation’s (“FDIC”) Notice of Proposed Rulemaking (“NPRM”) on recordkeeping for custodial accounts. In the letter, FDATA North America expressed support for the FDIC’s stated goal of safeguarding customer funds and improving transparency, but urged the FDIC to explicitly clarify that non-transactional settlement accounts are not classified as “custodial deposit accounts with transactional features” in a final rule.

FDATA North America emphasized the need to broaden exemptions for non-transactional settlement accounts, such as those used in merchant acquiring services and other essential financial operations, which facilitate digital payments and e-commerce. These accounts serve as temporary conduits for fund payment transfers without granting direct transactional rights to account owners. Applying customer-level recordkeeping requirements to these accounts could disrupt established payment systems and increase costs without delivering additional consumer benefits.

In the letter, we also highlighted the importance of regulatory coordination, urging the FDIC to assess how the NPRM aligns with other recent actions, including the finalized Section 1033 rule on personal financial data rights. A cohesive regulatory framework is essential to fostering innovation, protecting consumers, and ensuring access to affordable financial services.

A full copy of the letter is available here.

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