Data in Motion, Value in Action: Open Banking Insights

The state of Open Banking in the U.S. is at a crossroads. Over the past year, the industry has seen rapid movement, from debates on data access fees to a second ANPR on Section 1033 of the Dodd Frank Act from the Consumer Financial Protection Bureau. 

Questions around liability, consumer representation, and compliance timelines continue to shape what the future of Open Banking will look like — and who will benefit from it.

To unpack these issues, MX brought together leaders from across the ecosystem for a candid discussion during Money Experience Summit 2025. The panel — featuring representatives from Plaid, Yodlee, and MX — explored the reality of today’s Open Banking environment and what’s needed to turn data movement into true value creation for consumers.

Liability and Scope of Data Are Missing from the ANPR Conversation

While issues of security, fees, and consumer representation are central to the current rulemaking process, the panel highlighted two areas notably absent from the conversation: liability and data scope.

Both have been longstanding sources of friction in Open Banking litigation and are critical to getting the next phase right. Without clear definitions of who bears responsibility in cases of data misuse or breach, and what specific data categories are covered, participants cautioned that the same disputes could stall progress again.

Fees for Data Access Should Remain Prohibited

The panel also tackled the growing debate over whether financial institutions can charge for data access. On this point the panelists were in agreement. 

Referencing recent moves by financial institutions to add fees for data access, panelists noted that while the intention was to support infrastructure, Section 1033 is clear on the permissibility of fees for data access. As John Pitts, former Global Head of Policy at Plaid, said it simply “... the 1033 law clearly makes paying fees for access illegal.”

Beyond the legality issues, panelists further agreed that the introduction of fees will add unnecessary friction to the Open Banking ecosystem. Jane Barratt, Chief Advocacy Officer at MX, was direct about the implications:

“Data access is a zero-sum game. If you charge for data out, data in will cost more. We’re just adding costs to the ecosystem under the guise of covering API costs — and those costs eventually roll downhill to the consumer.”

Her point underscored a shared concern: monetizing access could create new barriers to competition and erode the consumer value proposition at the core of Open Banking.

The panel all agreed that the introduction of fees for access to financial data will roll downhill, eventually being applied directly to consumers. But, consumers don’t want this. MX’s most recent research revealed that nearly half (48%) of consumers say they would be unlikely to connect external financial accounts to their primary bank if it came with a fee. 

The Role of Data Intermediaries

With more than 8,500 financial institutions and thousands of fintechs in the U.S., the panel agreed that intermediaries play an essential role in facilitating the secure flow of financial data.

“No single company can connect every system alone,” noted Eric Jamison, former Head of Product at Yodlee.

Data intermediaries provide quality control, standardization, and translation of raw, machine-readable information into meaningful, actionable insights. The panel compared their role to credit bureaus, where multiple data sources converge to create a holistic consumer benefit.

Expanding the flow of data, they emphasized, “raises all ships”, improving the tools available to consumers and encouraging innovation across the ecosystem.

The Need for Regulatory Clarity

The U.S. Open Banking landscape is at a critical juncture. Over the past 9 months, financial institutions, fintechs, and regulators have navigated new developments. Consumers, who often hold 5 to 7 financial accounts across multiple providers, need secure, unified access to their financial information to make informed decisions. Open Banking is key to enabling this, creating an interoperable ecosystem that promotes competition, drives innovation, and empowers consumers to manage their own data.

Yet uncertainty remains. Panelists highlighted that, absent clear guidance on representation, access fees, and compliance timelines, the rulemaking process could stretch on for years, leaving smaller institutions hesitant to invest and widening the competitive gap between large and small players. Without regulatory clarity, the risk grows that community banks and credit unions fall behind, consumers face limited choice, and the industry sees little meaningful progress. 

Strong, consistent leadership from regulators is essential to ensure that Open Banking fulfills its promise for both consumers and the broader financial ecosystem.

The Road Ahead Has Two Paths

Looking ahead, the panel outlined two possible futures for Open Banking in the U.S.:

1. An interoperable ecosystem built on standardized APIs, robust consumer protections, and open competition.
   
   
2. A fragmented market dominated by proprietary networks controlled by a few large players, where access comes with a toll.

Without clear and timely regulation, the latter could become reality — especially as emerging technologies like agentic AI drive new forms of data aggregation outside formal channels.

Turning Data into Value

As the panel closed, the message was clear, it is time for Open Banking to evolve from data movement to value creation. And, ensuring data flows safely, securely, and with tangible benefit to consumers is how we get there.

Open Banking in the U.S. is no longer a question of if, but how well. The work ahead lies in aligning regulation, infrastructure, and innovation so that access becomes empowerment — and every connection creates value.