The strategy: Open banking and its uncertain future in the US dominated discussions across FinovateFall’s 2025 agenda.

Vice president and senior counsel of the American Bankers Association Ryan Miller said aggregating data can help customers understand their financial health—and can keep them more tethered to providers they already use.

Financial institutions (FIs) that already offer such capabilities—and those finding new ways to use open banking—will have a competitive advantage over those waiting for more clarity.

How we got here: After nearly scrapping the rules entirely, the Consumer Financial Protection Bureau (CFPB) launched an expedited process to rework the open banking rule.

The regulator is requesting public feedback regarding the rule’s scope, cost defrayment, data security concerns, and data privacy concerns. And various financial players appear to be gearing up for a lobbying and public perception fight to push for a rule that’s most favorable to their bottom lines and their customers’ needs.

Some FIs are forging ahead to meet those needs: According to our “US Mobile Banking Emerging Features Benchmark 2024,” 36% of respondents found the ability to manage third-party data access on their FI’s mobile app “extremely valuable.” This feature gives customers some control over their data and privacy in an open banking environment and can give them a clearer picture of their finances across accounts.

Seven out of 10 banks in our benchmark offer this account management feature, which means most are ready to meet their customers’ preferences in an open banking environment.

Assault on open banking: JPMorgan will soon charge fintechs to access its customers’ bank account information, per Bloomberg. PNC has already said it would consider following suit.

These fees would be a major setback to fintechs, which may be forced to start charging their own fees or dramatically reduce the services they offer.

But fees aren’t a zero-sum game: Granular Fintech founder Martin Kleinbard said that if banks get the CFPB’s blessing to charge fees, they need to structure them carefully to avoid contentions with how they arrived at the fees they’re charging, which could result in protracted lawsuits.

Farmers Insurance Credit Union CEO Mirella Reznic reminded Finovate attendees that credit unions and smaller FIs depend on good relationships with fintechs to innovate and offer customers what they’re looking for. In this case, it can be risky to charge fees to the fintechs providing those tech solutions.

What would be the most strategic win for FIs, according to Kleinbard, would be to limit both the number of API calls they get and have greater transparency into transactions with fintechs—which means fewer costs to recoup and lower fees.

Key takeaways: Reznic told Finovate attendees that it’s important to remember who owns the data in question—the customers. And the ultimate question FIs should be asking themselves is: How can they leverage that data to provide the best experience possible for their customers?

While it’s unlikely that next steps will include fee-less transfer of this data, FIs need to consider how their next steps into open banking can set them apart from the competition.

For now, the most obvious step is doing something that many of FIs’ customers already find extremely valuable: letting customers manage which parties can access their data.