The CFPB is requesting granular feedback on fixed and marginal cost modeling. Fixed costs, such as building APIs, standardizing data formats and deploying secure authorization systems, can range markedly.
Small financial institutions in the United States may face costs tied to open banking that depress profitability, as discussed in the June paper "Global perspectives on open banking: Regulatory impacts and market response" published in the Journal of International Financial Markets, Institutions and Money.
Meanwhile, the paper "Do Banking Regulations Disproportionately Impact Smaller Community Banks?" by an economist with the Conference of State Bank Supervisors estimated that compliance costs are a higher burden for small financial institutions versus their larger brethren.
The CFPB wants detailed evidence on balancing benefits with risks.
"One unfortunate byproduct of the transition to a largely digital information architecture is the increased number of threat vectors to the secure storage and transmission of data," the ANPR said.
The PYMNTS Intelligence report "Consumer Sentiment About Open Banking Payments" found that 46% of banking customers are highly interested in using open banking options, yet only 11% had real-world experience with open banking payments in the last year. The emergence of faster payment infrastructure and instant payments sent in bank-to-bank fund flows (with third-party providers in the mix) comes as PYMNTS Intelligence also found that about 40% of users are willing to pay for instant access.
Large banks must now assess whether multiyear, multimillion-dollar API systems are justified, while small institutions may grapple with steep relative burdens. JPMorgan, for example, is pivoting to a fee-for-access model. FinTechs are advocating for flexibility and affordability, while regulators must balance market momentum with fair cost sharing.
With the comment period closing in October, these coming weeks will shape not only policy but also how the financial industry divides the bill for consumer data access.