Open finance without a mandate: a strategic business case

The recent uncertainty around the timeline of CFPB’s 1033 Rule has left many financial institutions questioning whether now is the time to invest in open finance. For smaller and mid-sized institutions, where resources are scarce and priorities constantly compete, regulatory imperatives help with prioritization. But if the regulation is delayed, should open finance initiatives be deprioritized? 

The short answer: absolutely not. 

Open finance is no longer about “if” or “when” — it’s about “how fast.” Even without an immediate regulatory push, the consumer demand, competitive pressure, and associated security risks make it a compelling case to act on.

Here’s how a financial institution should rethink the business case for open finance — and why delaying could cost more than just time. 

Consumer-led momentum 

Other global markets that have adopted open finance have benefitted from either a regulatory push or a committed action by all financial institutions. However, the US hasn’t had either of these factors impacting its meteoric growth. Instead, the catalyst for open finance in the US has been the consumer adoption of fintech apps. Consumers have increasingly adopted third party services to benefit from better financial products and services, and many of these services are powered by consumer data sitting with their financial institutions. 

A compelling data point to underscore this growth is from the Financial Data Exchange (FDX), a standards setting organization in the US. FDX data published in April 2025 shows over 114 million customer connections via FDX-aligned APIs (a sharp rise from 76 million a year ago), underscoring the consumer adoption momentum in the open finance space.  

So, in effect, even if a financial institution is not actively participating in open finance, their customers already are — without them. 

Active participation, however, does not mean disintermediation. I would argue to the contrary - customers still trust their banks and credit unions to protect their financial data. Embracing open finance actually strengthens that trust by giving customers secure, controlled, and transparent ways to share their data. 

The risk is already here — and it’s growing 

Even if open finance regulation is delayed, the risks that it’s meant to address continue to grow. Today, hundreds of millions of consumer login credentials are stored with aggregators and third parties due to screen scraping. This presents a growing risk vector for the industry. At a conservative $200 cost per breached account in operational costs, fines, and churn, the potential financial exposure to financial services industry is in tens of billions of dollars 

By enabling secure APIs, financial institutions can mitigate this immediate and growing risk. Doing so will allow them to actively protect their customers and their brand. 

Thinking beyond compliance: two vectors of value — data out and data in 

At its foundation, open finance is about enabling secure, permissioned data exchange between financial institutions and third parties. This exchange moves in two directions: data out and data in. 

Most financial institutions start with data out — making customer-permissioned data, such as accounts, transactions, and balance information, available to approved third parties through APIs. This supports essential functionality that customers increasingly expect, including account aggregation, personal financial management, and payment initiation. Enabling data out allows the financial institution to participate in the broader financial ecosystem while giving customers transparency and control over their data. 

But open finance’s long-term strategic value emerges when institutions also think about data in—bringing in external financial data (aka held away accounts data), with the customer’s consent, to enhance their own operations and experiences. With access to data from outside accounts, they can strengthen risk assessments, tailor product recommendations, and proactively engage customers based on a more complete understanding of their financial lives. This bi-directional approach transforms open finance from a compliance requirement into a platform for growth, innovation, and deeper customer relationships. 

How to make the case internally: strategic and tangible benefits 

Here are specific, actionable reasons why your financial institution should lean in now — even without the force of Rule 1033: 

1. Immediate risk mitigation: Secure APIs eliminate credential sharing, lowering your security and compliance risk profile.
2. Better third-party risk management: Allowing access to third parties through secure APIs also allows the financial institution to perform the appropriate due diligence and risk management on these entities, further securing their customers' data.
3. Simpler technical implementation: FDX standards, support from digital banking providers, and partners like Akoya make the implementation easy and quick.
4. Improved customer service & retention: Reduce scraping errors and support costs, while improving digital experience and loyalty.
5. Derive customer behavior insights: Understand where and why customers share their data. Use this to shape product strategy and partnerships. 
6. Drive new revenue streams: Offer premium APIs for non-covered data like tax and commercial data that offer a monetization opportunity. 
7. Deliver smarter personalization and offers: Leverage held-away data to support cash flow underwriting, targeted offers, and life-event-based services. 

A vision that needs executive endorsement 

Open finance isn’t a compliance project — it’s a strategic initiative that touches on product innovation, risk management, customer experience, and revenue. This also means that cross-functional alignment is critical — product, risk, legal, technology, customer support — all need to participate and own the initiative. For institutions to embrace its full potential, leadership must treat it as a  time-sensitive imperative and not just a “wait-and-see” effort tied to Rule 1033. 

The time to act is now 

Delaying open finance plans due to regulatory uncertainty is not the best plan of action. The risks are immediate, the consumer demand is clear, and the strategic upside is too valuable to ignore. Financial institutions should not wait for a regulatory mandate to get started — all they need is a vision, a partner, and a plan. 

Open finance is the bridge to a future where financial institutions remain central to their customers’ financial lives. Adopting open finance could lead to much better outcomes for the financial institution’s customers, leading to more loyalty and revenue while staying competitive and relevant.  

Connect with Akoya to get started on your open finance journey.

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