Wise submits Open Banking comment letter to the CFPB

Nick Catino

“Open banking” is moving forward in the United States. Well, actually, it’s been happening through industry-driven partnerships for years, but the government will soon produce its first set of regulations.

In October of 2020, the Consumer Financial Protection Bureau (CFPB) announced the start of a rulemaking process to implement section 1033 of the Dodd-Frank Act, which provides for “consumer rights to access financial records.” Stakeholder comments were due last week.

Open banking is the practice by which financial institutions can connect directly via APIs, often through third parties, at the direction of consumers. Open banking is commonly utilized when consumers add money to payment apps, use personal financial dashboards, or aggregate investments with a robo-investor, among other use cases and applications that help people manage their money more efficiently and effectively.

Until now, open banking in the US has been almost entirely industry driven. That stands in contrast to the UK's more prescriptive approach with enforceable unified standards and registration/accreditation requirements for participants. The UK implemented Open Banking in 2018 to induce more innovation and competition into financial services.


As the US moves towards implementing its first ever regulations, Wise offered comments from its perspective as one of the UK’s largest open banking payments initiators, at one point originating as much as 70% of transactions.

Our recommendations to the CFPB include:

  • Ensure a consumer right to financial data access;
  • Encourage data holders to fully implement and permit authorized data access;
  • Support the development of standards that focus on consumers rights, access, and outcomes, not competitive interests;
  • Include, as within the scope of access, public information on terms, rates, and fees;
  • Consider a future open finance roadmap that includes payments initiation;
  • Provide guidelines that enshrine consumer control and transparency of any data sharing; and
  • Incentivize financial institutions to make consumer control and transparency central to product design decisions to maximize outcomes.

The benefits of authorized data access, and open finance more broadly, are clear. Consumers benefit from increased innovation and competition. This should be a continued priority for US policymakers.


This publication is provided for general information purposes only and is not intended to cover every aspect of the topics with which it deals. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content in this publication. The information in this publication does not constitute legal, tax or other professional advice from Wise Payments Limited or its affiliates. Prior results do not guarantee a similar outcome. We make no representations, warranties or guarantees, whether express or implied, that the content in the publication is accurate, complete or up to date.

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