This member spotlight features Brian Costello, Head of ByAllAccounts Data Aggregation Strategy and Governance, Morningstar Wealth. Brian tells us how ByAllAccounts’s role in providing connectivity of consumer-permissioned financial data is critical in realizing the full potential of this data and explains ByAllAccounts’s high level of engagement with policymakers to promote finalization of the Dodd-Frank Section 1033 rulemaking.
FDATA North America Monthly Newsletter for April 2024
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 NA Sends Letter to Wyoming Governor Mark Gordon and Wyoming Legislators Urging Revision of Open Banking Legislation. On March 15, 2024, the Financial Data and Technology Association of North America (FDATA) sent a letter to Wyoming Governor Mark Gordon and legislators, including Representatives Cyrus Western, Daniel Singh, Mike Yin, and Senators Alfie Ellis, Tara Nethercott, Chris Rothfuss. The letter, motivated by the recent enactment of HB 145, raised concerns over its alignment with the essential tenets of open banking, particularly the principle that allows consumers and small businesses complete control over the sharing of their financial data. As a globally recognized advocate for consumer-permissioned, third-party access to financial data, FDATA underscored the importance of revising Wyoming’s open banking legislation to reflect global best practices. With the Consumer Financial Protection Bureau on the verge of implementing a federal open banking framework, FDATA offered to provide input and collaborate with Governor Gordon and the state’s legislators to explore solutions that could establish Wyoming’s open banking regulations as a model for consumer empowerment and market competitiveness. FDATA released a statement on its submission of the letter, which can be found here.
Member News & Activity
API Metrics published a blog highlighting the importance of interoperability in the digital transformation of financial services. Through their advanced solutions and involvement in standards bodies like FDX and the OpenID Foundation, APIContext is leading the way in fostering financial inclusivity and innovation by ensuring APIs are built with open standards, focusing on reliability, security, and meeting the challenges of Open Banking standards.
Basis Theory published a blog emphasizing their commitment to security, especially in protecting Personal Health Information and other sensitive data, highlighting recent achievements of SOC2 Type1+HIPAA and ISO 27001 certifications. These certifications demonstrate their adherence to stringent security standards and regulations, ensuring the protection and compliance of user data through technical and organizational safeguards.
Codat posted a blog underscoring the potential of banking data as a key asset in the lending industry for making informed decisions on creditworthiness. The blog emphasized the need for lenders to automate the processing and categorization of banking data to unlock actionable insights and improve underwriting efficiency, highlighting Codat’s role in simplifying this process through its technology that connects open banking and accounting data for enhanced decision-making.
Envestnet Yodlee posted a blog discussing the burgeoning interest in open banking within South Africa as part of a global trend toward increased data-sharing and financial innovation. The blog highlighted South Africa’s potential to lead in open banking, given its Financial Sector Conduct Authority’s interest in an Open Finance regime, the proactive stance of major banks, and the opportunity to enhance financial inclusion for the unbanked or underbanked, promising a series of deeper explorations into the benefits and regulations of open banking in the region.
Flinks published a blog detailing the growing momentum of Open Banking in Canada, driven by consumer and business demand for personalized financial services and the Canadian government’s commitment to establishing a consumer-driven banking framework. Highlighting Flinks’ role in facilitating this transition, the blog showcased their partnerships and contributions to developing Open Banking capabilities, positioning them as a key player in enhancing financial innovation, competition, and consumer choice in Canada’s financial ecosystem.
GoCardless published a press release announcing its approval as a supplier on the Crown Commercial Service’s Open Banking Dynamic Purchasing System framework, enabling it to bid for account information and payment initiation services tenders from UK public sector bodies. This inclusion marks a significant step for GoCardless, allowing it to expand its strategic opportunities within government sectors and strengthen its presence in the charity sector.
MX published a blog addressing the struggle of many financial providers to fully utilize consumer financial data for enhancing customer and business outcomes. Highlighting findings from a Forrester Consulting study, the blog underscored the critical need for financial institutions to embrace data intelligence, invest in breaking down data silos, and leverage technology and partnerships to unlock the transformative potential of this data for improved personalization and decision-making.
Plaid published a blog detailing how integrating with Plaid’s Payment Initiation services helped Paysend, a global payment platform, to overcome challenges in customer bank account top-ups, resulting in a 125% increase in transaction volume within a year. The partnership enabled Paysend to offer instant bank transfers, significantly improving customer satisfaction and expanding their service with successful launches in the UK and plans for further expansion across the European Union.
Trustly posted a blog highlighting the advantages of ACH autopay for billers, emphasizing its potential to significantly reduce processing fees compared to card payments, thereby maximizing revenue and safeguarding cash flow. The blog also discussed how leveraging Open Banking can address the inefficiencies of traditional ACH setups by providing a streamlined user experience, reducing manual input, and enhancing security, ultimately increasing ACH autopay adoption among customers.
VoPay was featured in a PYMNTS article announcing its partnership with Cross River Bank to expand its embedded payments technology into the U.S. market, providing VoPay with access to major payment rails and networks along with Cross River’s regulatory expertise. This collaboration aligns with VoPay’s goal of delivering innovative financial solutions and will enable the company to offer a wider range of payment services including ACH, Same-Day ACH, RTP, FedNow® Service, and Pull-from-Card, enhancing its North American service offerings.
Events and Submission Deadlines
Contact: Laine Williams, (202) 897-4757, [email protected]
March 15, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) today sent a letter to Wyoming Governor Mark Gordon and Wyoming legislators including Representative Cyrus Western, Representative Daniel Singh, Representative Mike Yin, Senator Alfie Ellis, Senator Tara Nethercott, and Senator Chris Rothfuss, highlighting concerns about a Wyoming bill (HB 145) that was recently enacted into law and offering to provide input into Wyoming’s open banking regulations and financial innovation agenda.
As a leading advocate for consumer-permissioned, third-party access to financial data globally, our letter underscored the importance of aligning Wyoming’s open banking framework with global best practices, which provide complete control to consumers and small businesses over what data they decide to share with third parties. We pointed out that HB 145 deviates from this important open banking tenet.
As the Consumer Financial Protection Bureau moves to implement a federal open banking framework later through rulemaking later this year, we offered to engage in further discussions with Governor Gordon and the legislators to explore solutions that would make Wyoming’s open banking regulations a model for consumer empowerment and market competitiveness.
A full copy of the letter is available here.
FDATA North America Monthly Newsletter for March 2024
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 NA Submits Comments to Canada’s Pre-Budget Consultations 2024. On February 9, 2024, FDATA NA submitted comments to Canada’s Department of Finance as part of its pre-budget consultations for Budget 2024. The submission advocated for Canada to enhance the inclusion of consumer-driven banking (CDB) outlined in the 2023 Fall Economic Statement, aiming for a comprehensive Canadian open finance framework. Our comments also called on the Canadian government to legislate a CDB Framework in Budget 2024, establish a robust governance entity to oversee this framework, and outline a vision for open finance, signifying the next advancement in financial services. The submission noted that the proposed governance entity should be neutral, transparent, capable of making quick, binding decisions, and accountable, ensuring the framework’s success and sustainability while promoting market innovation and competition for the benefit of Canadian consumers and SMEs. FDATA released a statement on its submission of the comment letter, which can be found here.
FDATA NA Submits Comments to Canada’s Consultation on Strengthening Competition in the Financial Sector. On February 28, 2024, FDATA NA submitted comments to Canada’s Department of Finance regarding the consultation on strengthening competition in the financial sector. Our comments outlined four initiatives crucial for creating a more inclusive, innovative, and competitive financial ecosystem: 1) advancing Consumer-Driven Finance (CDF) and adopting an open banking regime to empower consumers and SMEs with control over their financial data; 2) accelerating the deployment of the Real-Time Rail (RTR) to modernize payment infrastructure, enabling instant payment processing; 3) implementing the Retail Payment Activities Act (RPAA) regulations for payment service providers (PSPs) within a robust regulatory framework to enhance payment system security and efficiency; and 4) amending the Canadian Payments Act (CP Act) to allow non-bank payment providers direct access to payment rails. FDATA released a statement on its submission of the comment letter, which can be found here.
Member News & Activity
API Metrics published a blog post announcing the formation of APIContext Inc., a merger between APImetrics Inc and Contxt Ltd, to offer comprehensive solutions for API oversight and integrity. The newly formed company aims to address the challenges of creating reliable, productized APIs by providing end-to-end visibility, proactive risk measures, and comprehensive monitoring capabilities to empower businesses.
Basis Theory posted a blog explaining the intricacies of global payment processing, highlighting its necessity for e-commerce businesses to reach an international customer base and the variety of services offered by global payment processors to facilitate cross-border transactions efficiently. The blog emphasized the importance of selecting the right global payment processor, considering factors such as supported currencies, fees, security, and integration capabilities, to enable businesses to cater to global markets effectively.
Betterment’s VP of Legal, Joshua Rubin, discussed on the #inSecuritiespod how the company navigates the complex regulatory landscape, including its approach to the fiduciary rule, by addressing overlapping regulations and explaining why their stance sometimes diverges from the broader financial services industry’s perspective on rulemaking proposals.
EQ Bank was mentioned in a Business Wire article for partnering with Trulioo, an industry-leading identity verification platform, to streamline its digital banking onboarding process. This partnership enables EQ Bank to provide a frictionless customer experience with enhanced security and compliance, utilizing Trulioo’s advanced document verification, AI checks, and customizable workflow solutions.
Flinks posted a blog highlighting the growing importance of Account-to-Account (A2A) payments, describing them as a significant evolution in the financial transaction landscape. A2A payments, which enable direct fund transfers between accounts and bypass traditional intermediaries, are gaining traction due to their speed, cost efficiency, and enhanced security, supported by financial institutions, fintech companies, and payment processors.
GoCardless published a blog post announcing the extension of its partnership with Dyce Energy, a UK-based energy provider, for an additional three years, for easy bill collection through Direct Debit payments.
Inverite was mentioned in a BNN article for its advancements in the fintech and alternative lending sectors through its Open Banking Platform. The article noted that Inverite is revolutionizing consumer directed banking, providing innovative solutions for data enrichment, identity verification, risk management, and compliance, thereby transforming the alternative credit economy.
Morningstar Wealth published a blog highlighting the significance of diversity, equity, and inclusion (DEI) within the U.S. financial data-sharing ecosystem, particularly focusing on the evolving open banking system. Brian Costello, Head of Data Aggregation Strategy and Governance at ByAllAccounts, emphasized the importance of empowering consumers with greater control over their financial data to support innovation in financial services, advocating for a holistic approach that promotes DEI in financial product design and implementation to ensure the financial well-being of all.
MX published a blog summarizing the ten key themes of the Consumer Financial Protection Bureau’s proposed rulemaking on personal financial data rights, including concerns about the scope of data covered, restrictions on secondary use cases, ambiguity in liability definitions, the potential for charging fees, the need for technical and interface standards, transitioning from screen scraping, consent and authentication protocols, tokenized account numbers, overlaps with existing regulations like Fair Credit Reporting Act and Gramm–Leach–Bliley Act, and concerns about the proposed compliance timeline.
Trustly’s Matt Janiga, Legal Counsel and Director of Regulatory and Public Affairs, published a blog applauding the CFPB’s efforts in advancing Open Banking through Section 1033 of the Dodd-Frank Act, while offering suggestions to improve the proposal for a more inclusive Open Banking ecosystem. Janiga emphasized the need for adjustments in areas such as data-sharing duration to align with consumer expectations, the practicality and security concerns around Tokenized Account Numbers (TANs), the importance of allowing safe, pro-consumer secondary data usage, and enhancing consumer experiences through better API standards and fallback options.
Ozone API was mentioned in The Paypers article for partnering with CLOWD9 to enhance their services to clients, combining Ozone API’s expertise in facilitating Open Banking innovations with CLOWD9’s payments processing platform. The article noted that the collaboration aims to create a comprehensive ecosystem to support banks and financial institutions in adapting to the evolving landscape of Open Finance, promising to foster growth and innovation within the industry.
Events and Submission Deadlines
During 2023, open data regulations in Latin America have significantly evolved, with industry, governments, and financial regulators collaborating to establish a regulated data-sharing infrastructure.
Financial data sharing has been a reality in the financial system since its inception, adapting to a more digital and instantaneous reality as technology progressed. While some Latin American countries are still exploring opportunities and best practices in the open data ecosystem, others such as Brazil, Chile, Colombia, and Mexico have implemented regulated and some case mandatory data-sharing infrastructures. This aims to create a true network effect in the data economy, wherein major financial institutions, typically holding a significant portion of customer data, share this information with third parties.
The region has predominantly taken a mandatory approach for large institutions, and it is anticipated that in the coming years, countries still operating under a market-driven model will also engage in the implementation of regulated infrastructures.
Contact: Laine Williams, (202) 897-4757, [email protected]
February 28, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) today submitted comments to Canada’s Department of Finance as part of its consultation on strengthening competition in the financial sector. Our submission underscored the necessity for the enactment and realization of several previously announced initiatives that will provide increased competition in Canada’s financial sector once delivered.
FDATA NA’s feedback highlighted four cornerstone initiatives, each critical to fostering a more inclusive, innovative, and competitive financial ecosystem:
Through the enactment and realization of these initiatives, FDATA NA envisions a fundamental transformation within Canada’s financial sector. Leveraging models of success from international jurisdictions, we highlighted the potential of our recommendations to significantly boost the sector’s competitiveness, inclusivity, and innovation. The ultimate beneficiaries of these reforms that will deliver a more competitive financial ecosystem will be consumers, small and medium-sized enterprises, and the broader Canadian economy.
A full copy of the submission is available here.
Financial services is a hyper conservative industry, and a protectionist stance is common. No institution naturally wants to share customer data with a competitor, and data custodianship is often conflated to mean institutional data ownership.
The benefit of a mandatory approach is that it often enshrines a consumer data right, which clarifies the ownership vs. custodianship conundrum. Mandatory approaches also often consider consumer outcomes first and foremost, something that is not first priority when industry is left to voluntarily design delivery and outcome.
There is ample evidence to show that without a regulatory push, certain markets are reluctant to move towards a standard open data sharing scheme of their own volition. Even in voluntary markets, the regulatory pressure to deliver open banking is so strong it might as well be considered mandatory (it’s a case of “do it, or else we’ll do it for you”).
The advantage to a voluntary approach, though, is that incumbents recognise the incentive to participate, and often see economic and commercial value from participation; the ROI is there in some form, and the business case for broad data sharing is compelling enough to participate because the majority of FIs have a similar POV.
However, experience seems to prove that a mandatory approach is needed to accelerate open data sharing at scale.
In the evolving world of open banking and finance, the United States and Canada initially adopted similar voluntary approaches. FDATA North America has closely monitored this landscape, recognizing the importance of these nations’ transitions from voluntary to more mandatory frameworks.
In the United States, the shift towards a mandatory approach in open banking has been a significant development. Initially following a voluntary regime, the U.S. saw a notable change with the Consumer Financial Protection Bureau’s (CFPB) introduction of a proposed rule under Section 1033 of the Dodd-Frank Act. This proposed rule, aimed at enhancing consumer control over their financial data, signals a move towards a mandatory regulatory framework. This transition marks a major alignment with global financial technology trends and opens new opportunities for consumer benefits and innovation. Departing from the market-driven solutions that once dominated, this shift suggests a more competitive and innovative financial market, breaking away from the traditional dominance of large financial institutions.
Canada, following the U.S.’s lead, has also begun to shift away from its voluntary stance. This movement was highlighted by the Canadian Government’s Fall Economic Statement, which included a comprehensive framework for consumer-driven finance and open finance directives. This development indicates Canada’s progression towards a more structured, mandatory approach. This transition aligns Canada with other G-7 nations and reflects a global shift towards consumer-centric financial services, signifying a substantial change in the country’s approach to financial services regulation.
For FDATA North America, these developments in both the U.S. and Canada represent pivotal moments. The U.S.’s move towards a more defined regulatory framework under the CFPB is expected to lead to a more dynamic and competitive market, in line with global consumer data empowerment trends. In Canada, the enactment of consumer-driven finance will mark a significant step from a voluntary to a mandatory approach in open banking. As both countries refine their open finance strategies, the potential for transformative changes in consumer and business interactions with financial services is substantial. These shifts open exciting prospects for innovation, competition, and financial inclusion, reshaping the financial landscape in both countries.
Acknowledging the global context in which Open Finance operates, it’s important to understand the distinct roles of mandatory and voluntary approaches, particularly when contrasting Latin America’s experience with other regions. While the voluntary approach is more prevalent in other parts of the world, Latin America has been more inclined towards a mandatory framework, as highlighted in the report by FDATA LATAM in collaboration with the Inter-American Development Bank (IDB).
The mandatory approach in Latin America, as the report suggests, brings numerous advantages. It sets a clear regulatory framework, ensuring standardized practices across the financial sector. This is essential in a region with diverse economic and financial landscapes, as it provides a consistent and secure environment for data sharing. Mandatory regulations drive competition, lower barriers to entry for new players, and foster innovation, which is crucial for a dynamic financial ecosystem.
In comparison, the voluntary approach, predominant in other regions, allows for flexibility and market-driven innovation. Financial institutions and fintechs develop data-sharing practices organically, which can lead to highly tailored solutions. However, this approach may result in uneven adoption and standards, which can be challenging for ensuring universal access and consumer protection.
In Latin America, the emphasis on a mandatory framework reflects a proactive stance towards creating an inclusive and competitive financial environment. This approach aligns well with the region’s goals of accelerating financial inclusion and leveraging technology and data to empower consumers and businesses. It ensures that all stakeholders, regardless of size, have equal opportunities to participate in the evolving financial landscape.
Thus, while recognizing the value of voluntary systems globally, the mandatory approach in Latin America, as advocated by FDATA LATAM and the IDB, is particularly well-suited to the region’s objectives. It strikes a balance between regulation and innovation, paving the way for a more equitable and progressive financial sector.
Contact: Laine Williams, (202) 897-4757, [email protected]
February 9, 2024 Washington, DC – The Financial Data and Technology Association of North America (FDATA) submitted comments to Canada’s Department of Finance as part of its pre-budget consultations in advance of Budget 2024. Our submission emphasized the necessity for Canada to build upon the inclusion of consumer-driven banking (CDB) in the 2023 Fall Economic Statement, moving towards a fully realized Canadian open finance framework. The letter underscored the significance of CDB as a foundational step towards financial empowerment for consumers and small and medium-sized enterprises (SMEs), fostering a more innovative and competitive financial services marketplace in Canada.
Our letter urged the Canadian government to:
In the submission, we also asserted that any CDB governance entity in Canada must be neutral (i.e. not controlled by any particular stakeholder(s) with commercial interests in the ecosystem), transparent (i.e. it invites and considers stakeholder input and subjects its decisions to an open, publicly visible process), nimble (i.e. capable of making binding decisions relatively quickly and without undue bureaucracy), and accountable (i.e. explain its decisions and actions and be subject to judicial oversight and administrative law processes) with all stakeholders in the system agreeing to comply with the decisions and determinations made by the open banking governance entity as a condition of being active in the market.
A full copy of the submission is available here.