Open Banker: Year in Review

Ashwin Vasan is the co-founder of Open Banker, and is a Partner at FS Vector, a consulting firm for financial services clients in a rapidly evolving industry and complex regulatory environment. Ashwin was previously Associate Director for Research, Monitoring, and Regulations at the Consumer Financial Protection Bureau (CFPB).

We started Open Banker in September 2024 to create a paywall-free space for the best thinking in financial services policy. Today, the platform delivers op-eds to over 2,000 subscribers on topics from stablecoin policy to medical debt furnishing.

Policymaking in 2025 has been fast, dynamic and exciting or reckless, chaotic and terrifying (YMMV). It’s been a year of regulatory whiplash. We’re proud that Open Banker made its mark as the platform for debate on the biggest issues of the year.  

In 2025, we published 61 articles. Here are the top themes of 2025 covered by those articles, along with our takes and thoughts on what we’d love to see debated in 2026!

10.  Consumer Products and Consumer Credit

In a year dominated by digital assets and artificial intelligence, Open Banker hosted some commentary on the “traditional” markets that still define most people’s experience with financial services. Marisa Calderon outlined options beyond the 30-year mortgage to encourage homeownership (which, wisely, did not include a 50-year mortgage!) Pete Carroll walked us through the forces challenging sustainability and affordability in the homeowners insurance market. Mack Wallace wrote about possible improvements to the Federal Student Loan system and opportunities for lenders in the graduate student loan market, following the passage of the One Big Beautiful Bill Act (OBBA).  And also stemming from the OBBA, Karen Andres and Jason Ewas wrote last week about what it will take to make Trump Accounts a success. 

Eds: Affordability and long-term wealth creation matter to voters and yet there’s a seeming disconnect between those concerns and current priorities in financial regulation (apart from Trump Accounts). We want to see more policy advocacy on core consumer products in 2026.

9.  Bank-Fintech Partnerships

A year ago, all finreg nerds could talk about was bank-fintech partnerships and the perceived ‘crackdown’ by Federal regulators. In September 2024, Alex Johnson thoughtfully argued for a balanced approach, stating that “Killing Fintech was not an Option.” Some solutions were proposed, such as use of the Bank Services Company Act, an argument that Heidi Richards challenged.This year, Alex Johnson reminded us that many of the challenges with bank-fintech partnerships still exist and offered some potential solutions. 

Eds:  Did Federal regulators just learn to stop worrying and love BaaS? What happened to all those RFI comments and the proposed recordkeeping rule? For the most part, the issue has been in hibernation — presumably until the next election or major fissure that reveals fragilities.  

8. Fraud and Scams

Fraud and scams are one of the major issues people face, with one in three Americans experiencing a financial fraud or scam in the past 12 months. Unlike in previous years when the public sector was active, private sector and non-profits took the lead in 2025, as the National Task Force for Fraud and Scam Prevention, convened by the Aspen Institution released a report recommending a coordinated national strategy. On Open Banker, Nick Bourke (a primary contributor to the strategy) shared his perspective on the problem and highlighted gaps in information sharing, scam disruption, and legal frameworks. Later in the year, Brian Fritzsche from the Consumer Bankers Association, outlined actions banks were taking and reinforced the call for a national strategy. And Natalie Loebner shared her first hand experience on how gaps in data sharing standards limit the ability of fraud investigators to address criminal activity efficiently. 

Eds: Fraud and scams are relatively quiet on the legislative and regulatory front, but continue to be a major issue for consumers. We think there should be more to hear about solutions in 2026, including specifics on legal frameworks, particularly from advocates and others who see the front-line impacts on consumers. 

7. Threatened Regulatory Moats 

A collection of Open Banker essays this year talked about a fundamental tension in today’s market: Charters create regulatory moats, leading to either complicated workarounds by innovators or calls for alternative models of regulation. Penny Lee kicked off the year, asking for the new administration to explore a Federal payments-only charter. Jason Mikula followed by pointing out the innovation that happens outside the regulatory perimeter and calling for reform of existing license and charter frameworks. In contrast, Doug Simons made the case that banks serve an important public interest, and that walls to banking functions should be appropriately high. And Rebeca Romero Rainey made a case that tax exemptions for credit unions are distorting the M&A market and thus harming communities (a credit union response is forthcoming in 2026!)

We also featured deep dives into the consequences of regulation of those moats. Matthew Goldman led the year arguing that Reg II’s limits on debit interchange resulted in rapid fintech growth over the past several years. Aaron Klein and Adam Rust followed that the Fed’s Reg II proposal further limiting debit interchange might push people out of the banking system. In response, Doug Kantor warned that sometimes regulation doesn’t have the worst consequences imagined by the “banking borgs.” Similarly, Andrew Nigrinis summarized his recent paper cautioning that rewards on stablecoin balances could threaten banks’ historic role in credit intermediation. Alexei Alexandrov countered by reminding us again that the ‘protect banks role in the economy’ argument may sometimes just be about protecting banks from market forces. 

Eds: We love these debates, as they are central to the political economy of how our current regulatory system adapts to a complex world of financial services. We hope to see much more in the coming year as the GENIUS Act is implemented, Open Banking moves along, new charters come into being, and cases like Corner Post move through the courts — all challenging legacy sources of bank revenue.  

6. Artificial Intelligence 

2025 was the year of AI, LLMs, and agents. Mike Hsu walked us through some of the challenges when fitting LLMs into traditional model risk management frameworks. Similarly, Andy Green outlined the fundamental trickiness of using one metric to determine algorithmic fairness. Martin Kleinbard offered a simple framework for unpacking (and de-hype-ing) AI risks in consumer banking. Pat Utz flagged the forthcoming wave of state AI regulations in financial services (which, more generally, the administration has pushed back against). Katie Suskind and Karan Katyal wrote about how existing frameworks need to be extended to cover agentic commerce. And Mike Silver questioned current approaches for AI-driven rulemaking and deregulation. 

Eds: As the promise and limits of AI become clearer for the business community, we’ll see these policy debates sharpen, and possibly lead to specific actions by Congress and regulators. We expect to see a lot more of this in 2026. 

5. Deleting the CFPB 

What’s the saying about death, taxes, and CFPB Drama? We at Open Banker have strong CFPB DNA, so this current chapter of the Bureau’s life is hard to watch. Early in February, David Silberman, responded to early proclamations of ‘deleting the CFPB’ with a compelling list of the chaos that would ensue in the resulting vacuum. And Mike Silver offered suggestions on how a thoughtful refresh of the CFPB might be the right course. But these recommendations weren’t taken, and the Bureau has been mired in more litigation and chaos than ever before.

Some of the Bureau’s rules also solicited vigorous debate on Open Banker. Leigh Lytle made the case for full repeal of CFPB’s rulemaking on Section 1071 of the Dodd-Frank Act. Mike Calhoun responded with a comprehensive defense of Congress’ intent when passing Section 1071. In April, Mona Shah defended the CFPB’s medical debt furnishing rule from the Congressional Review Act. And Andrew Nigrinis penned a response arguing that the rule would be an ineffective way to address the challenges of medical debt in America

Eds: The CFPB is going to exist one way or another. Congress seems unlikely to amend the statute beyond the change to the funding cap in the OBBA. And yet, for the next few years it is almost certain to be largely dormant. Let’s hear more from stakeholders who see the cost of this absence on consumers and markets.  

4. Open Banking 

“We publish on more topics than Open Banking” — is a statement John Pitts and I have frequently made over the past year. Despite that, there has been plenty on Open Banking to talk about. Early in the year, Steve Boms penned an article encouraging the new administration to build on the foundations of the final section 1033 rule. Unfortunately that optimism was short lived. The new administration was focused on vacating the “Biden-era” rule, and Dan Murphy responded with an overview of how the final rule was a fragile balance between bank and fintech interests that should be preserved. Similarly, Jason Rosen and Noah Gold emphasized how the 1033 rule was consistent with Trump era priorities for leadership in fintech. 

Nevertheless, the CFPB moved to vacate the rule, and banks started to raise fees for data access. The move sent shockwaves through the fintech and crypto communities ultimately leading to the Bureau agreeing to reconsider the rule. Jennifer Tescher and David Silberman helped us take a step back from all the drama to express alarm at the imposition of fees by some market players and the implications it could have on consumers seeking better ways to manage their finances. Steve Smith offered suggestions on paths forward, particularly around third party risk management. And Linda Jeng connected open banking to the broader concerns of data control and competition that dominate the information economy. 

Eds: We find all this Open Banking turmoil exhausting, as some parties seem intent on trench (moat?) warfare over a regulatory framework that should lift all boats for the market and consumers. Any rule that the current CFPB writes may again be challenged in court, leaving the regulatory side of open banking in permanent paralysis. As we’ve generally hosted perspectives from fintechs so far on this topic, we’re interested in hearing from bankers on why any of these lemons are worth the squeeze, especially since paralysis will only delay the sunsetting of screen scraping and the other pro-bank components of the original rule. We await Jamie Dimon’s submission.

3. Reforming regulators and supervision

Raj Date penned Open Banker’s very first article entitled “Banks aren’t over-regulated, they are over-supervised.” This article kicked off a number of lively perspectives on supervision and supervision reform on Open Banker, a theme that largely anticipated the administration’s deregulatory focus. 

Jonah Crane kicked off the year with an essay arguing that the new administration should focus on the ‘how’ of financial regulation encouraging new approaches to supervision prioritization, technology and people, and engaging with innovators. Similarly, Amias Gerety and Shruti Batra discussed how regulators can guide AI driven models for AML compliance to ‘encode’ the judgment that examiners typically look for in banks. Likewise, Dan Gorfine and Natalia Bailey argued for greater reliance by regulators on recognized standard setters, given the pace of change in the market. 

Outside of supervisory activities, Phil Goldfeder and Jay Long argued for a tech-enabled transformation of SBA lending programs to improve speed and rigor of its programs.  Alexei Alexandrov made the case for DOGEing the Fed, while Tim Mahedy recommended a fix to the Fed’s approach to communicating its policy decisions. 

Many in Open Banker also argued for new frameworks and new rules delving into the ‘what’ of supervision. Alexei Alexandrov suggested that the administration could achieve its goals of limited bailouts and regulatory relief by offering banks a choice: more capital for regulatory relief. The trio of Meg Tayhar, Steve Gannon, and Graham Steele (who “usually do not find themselves in agreement”), made the legal case that confidential supervisory information (CSI) should not be considered a regulator’s property (and therefore not carry criminal penalties for disclosure). Meg Tayhar wrote again in December, lending support to Vice Chair Bowman’s efforts to strengthen supervision. Kayce Siefert argued for reform in how banks share CSI with their partners (particularly relevant for fintech-bank partnerships). And lastly Todd Phillips described how the focus on restricting the management component of “CAMELS” ratings might be better served by giving institutions clear paths to challenge ratings in court. 

Eds: Across all these articles, there is a general theme (motivated in part by the Silicon Valley Bank collapse) that supervision and agencies need reforming. This comes at a time when agencies are reducing examiner headcount and also changing expectations for banks and other supervised entities. Technology, new frameworks, and new rights around CSI are all part of the debate.   At the same time, we’d like to invite more perspectives on the unintended consequences of the changes underway. 

2. Stablecoin and Crypto

It was undeniably a crypto and stablecoin year. Early in the year, Dante Disparte started us off with an article entitled “A Thousand Crypto Flowers Blooming,” heralding much legislative and regulatory blossoming. And G Clay Miller walked us through the game theory behind proposals to establish a strategic bitcoin reserve.

As the GENIUS Act worked its way through Congress, Open Banker hosted a number of supportive and critical perspectives. Alex Barrage and Jai Massari wrote in March rebutting key ‘myths’ around payment stablecoins such as volatility and deposit displacement. Amanda Fischer responded pointing out operational challenges, bank dependence, stability issues and murky resolution regimes. Similarly Brian Shearer argued that the then drafted GENIUS Act would encourage financial instability and further concentrate power in big tech companies. Professor Art Wilmuth called on Congress to reject the GENIUS Act for numerous weaknesses. And Jai Massari contributed again to rebut the Bank of International Settlement’s claim that stablecoins could not satisfy the ‘singleness’ of money. Lastly, Tom Brown wrote twice on the topic, first to question the logic of bank-led consortiums to issue stablecoins, and second to step us all back to point out the fundamental transformation of money underway. 

Eds: There is much more to come here as the GENIUS Act requires multiple implementing rulemakings. As noted above, there are already controversies around the prohibitions prohibiting yield on payment stablecoins. And more recently, the OCC’s conditional approval of charters for some stablecoin issuers, has raised eyebrows from banking trades. Open Banker hasn’t hosted nearly as much content on the pending CLARITY Act, or the regulatory actions at the SEC, OCC and elsewhere, and we think we should hear more from those corners of the finreg world.

1. The Big Pendulum Swing 

All this leads us to where we started — that the big story this year has been massive change. Stakeholders were either cheering the swinging pendulum, futilely trying to catch the bob, or just watching in horror, certain the whole thing was going to break. In January, Todd Baker celebrated an imminent flood of bank charter applications, after a decade of minimal de novo bank creation. Similarly, in January, Sima Gandhi argued for restored balance in financial regulation, with dual mandates, risk management over risk elimination, and embrace of public-private partnerships.

Of course in some corners, we got more than balance, as the sections above on the CFPB and Open Banking illustrate. And, across regulators, staff has been cut and capacity reduced. For example, Delicia Hand outlined a new approach to addressing long-term inequities in racial wealth in an environment where race-conscious remedies face a political backlash. Vikas Raj argued that the administration’s deregulatory instincts are leading to policies without clear consumer benefit, and that policy making should focus on helping households find greater resilience. Lastly, Art Wilmarth stitches together the many warning signs in the broader economy, arguing that the current deregulatory euphoria is leading us down the path to another financial crisis.

Eds:  The pendulum will presumably swing a bit less next year (the first years of administrations are often the most consequential in terms of energy to reform major policy). As midterms loom, and lawsuits pile up we expect the pace of change to mitigate somewhat. And we should be talking more about the consequences of these policy changes in the coming years.

That’s the year in review from Open Banker. Thanks again to all our authors for contributing this past year. There’s a lot that we didn’t even get to in 2025 — climate regulations, bank capital, debanking, reputational risk, and much much more. Stay tuned. Thank you all for reading and wishing you and your families a Happy Holidays.

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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