This Executive Brief examines the current state of open banking implementation in the U.S. under Section 1033, highlighting that despite regulatory uncertainty and legal challenges, the movement toward data sharing through APIs continues to gain momentum. The presentation outlines key challenges facing financial institutions, including security concerns, technological complexity, and political uncertainty, while emphasizing that large banks and data aggregators have already made significant investments in this ecosystem. For financial institutions, particularly those with under US$850 million in assets, critical decision points include determining strategic alignment, implementation approach, timeline, risk management strategies, cost considerations, and success metrics. This brief suggests that institutions should prepare for open banking’s evolution regardless of regulatory mandates, as customer expectations and competitive pressures will drive adoption in the coming 18 months.
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