What the US Can Learn from the World on Open Finance

Rafe is Director of Fair Finance Consulting, which provides consumer protection and competition policy advisory services and research design. For nearly 20 years Rafe has supported governments and financial service providers across Africa, Asia, and Latin America improve financial consumer protection and address competition issues in digital finance.

As an American citizen who works on open finance globally, but lives and banks locally here in North Carolina, the last year of open finance policy in the US has been personally and professionally frustrating. A bank lobbying group’s lawsuit, combined with political changes in Washington, halted open finance regulations, while JP Morgan’s subsequent open finance data fees pitted big banks against innovative payments, without much consideration for what American consumers may want. I can’t help but remember a saying from Africa, the region where I do most of my work: “When elephants fight, it’s the grass that suffers.” And yes it seems us consumers in the US have been the grass on this metaphorical savannah for the past year.

But if you step outside of the US, there are open finance flowers blooming all over the world. From Brazil to the United Kingdom, from the United Arab Emirates to India and on to Korea, open finance models are scaling and delivering impact for consumers and small businesses. Here in the US, our policy delays mean we risk being left behind — or ending up with fragmented, state-by-state regimes (see the proposed New York financial data rights act). If the inaction or fragmentation paths continue, the ones who will lose most will be US financial consumers through limited data rights, higher costs for financial services, and fewer new product innovations.

A Dream of Spring

There are signs the current open finance policy winter could be thawing. In August, 2025, the CFPB issued an Advance Notice of Proposed Rulemaking on Personal Financial Data Rights Reconsideration, and many eagerly await further issuance of rules or public debate. If we are really going to give another try at a regulated open finance regime in the US, I have five lessons I think the US could learn from other markets the second time around:

1. A Hands-On Approach to Implementation and Governance

The previous 1033 rules established a new entity type, the standard-setting body (SSB). These SSBs were intended to manage networks of open finance participants, including key functions like standards development and appeals. But a lesson from other markets is that the regulators’ role actually increases once the regulations are issued, and they should be active and vocal collaborators with industry in the first few years of standards development and live deployment of open finance. Even where industry leads on open finance implementation, initial co-implementation by SSBs and government agencies helps ensure timely and high-quality standards, keeps a close watch for non-compliance, and ensures quick participant dispute resolution. This can be through direct government leadership like in the United Kingdom’s Open Banking Implementation Entity or the UAE’s Nebras Open Finance, or indirectly like the Central Bank of Brazil’s close engagement with Open Finance Brazil, the industry implementation body. 

2. One Implementation Entity Instead of Many Separate Entities

In most leading open finance markets, a single entity is leading implementation (even in voluntary models like India or Korea). A single SSB instead of many different authorized SSBs can avoid the risk that various SSBs create different standards and interpretations of rules. Europe has faced this standards and implementation fragmentation challenge in its open banking implementation, and the US, with its 5000+ banks, might regret a model with many sub-networks under various SSBs implementing separate standards development and service delivery.

3. Don’t Leave Small Business and Small Consumer Data Out in the Cold

A recent review of the impact evidence on open finance in several leading markets identified increased credit options and reduced costs for small businesses and underserved consumers. Not including any credit products besides Regulation Z credit cards in US open finance leaves a large competition and financial inclusion hole in the middle of our ecosystem. Both live and in-development countries across the globe are including broader ranges of credit products, and often prioritizing those used by small businesses and thin-file consumers. In Australia, open banking is even starting to make a positive impact in the mortgage market — a prime opportunity in the US as well. The US should expand 1033 significantly — by legislation if necessary — to make sure the new consumer data rights in Section 1033 unlock more choice and lower costs of credit for American businesses and underserved consumer segments. 

4. Fix Pricing, or the Big Guys Will Probably Price-Fix for You

The drama around JP Morgan’s pricing policies for consumer data API access shows that pricing will be used for competitive advantage, undermining what is supposed to be a system that benefits consumers. Expecting cost-recovery for running APIs that share consumer data is not unreasonable, and not without precedent globally. My research on pricing models globally found many ways to allow fees in open finance, including: a set price per API call; “freemium” models which only charge after certain volumes; and discounted rates for smaller firms to encourage innovation and market entry. Leaving pricing to the market is a risky choice that can enable anti-competitive practices and raise costs to consumers. The US should learn from last year’s market signals from JP Morgan and set clear rules on pricing (e.g. cost-recovery only, same fees for the same function). While it may be too early to set specific rates, a new version of 1033 should require participants to submit pricing policies and data regularly to the CFPB, and enable authorities to set standard pricing rules for covered transactions and data types in open finance to support competition and consumer benefit.

5. Fight Fraudsters with Better Data

Did you know that in the UK payments made through open banking have lower fraud rates than other electronic payments? Fraud in financial services is a massive and fast-growing risk. Open finance certainly expands some risks by connecting more accounts across a wide network of participants. But the ability to check multiple forms of identity confirmation, and expanded visibility on fraudulent transactions at other financial institutions, could make open finance a fraud-fighting tool as well. FDX in the US has a fraud-reporting endpoint in its APIs its members can use to share fraud incidences as they occur. In the United Kingdom, Pay.UK tracks suspicious payments and flags money mule accounts which are used to receive payments for push payments fraudsters. A new version of the open finance rules in the US should require fraud incident reporting to a centralized database, which participants can use to check individuals and accounts for flagged activities prior to authorizing transactions, and develop shared fraud detection tools built off comprehensive, industry-wide fraud-incident databases.

America Can Learn and Lead

The 250^th anniversary of America reminds us of all that makes America unique and wonderful. But that doesn’t mean we don’t have lessons to learn from the rest of the world. Open finance is taking off in countries across the globe. The current open finance policy reset means America has the chance to learn from other countries’ successes and regrets to build an open finance system that is focused on increasing competition, reducing costs for consumers and small businesses, and keeping our money safe in an increasingly dangerous digital world.

The opinions shared in this article are the author’s own and do not reflect the views of any organization they are affiliated with.

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