In July of 2025, the GENIUS Act, the first comprehensive federal framework for stablecoins, became law. Last week, the US Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPRM) to implement the GENIUS Act’s requirements for payment stablecoin issuance and related activities.

While the new proposed rulemaking makes the GENIUS Act a reality instead of just a statute, it doesn’t change the intent of the GENIUS Act. It operationalizes the GENIUS Act by creating a dedicated regulatory section for issuers, establishing the licensing mechanics and timelines, forming the capital and operational requirements, and stipulating foreign issuer treatment.

2025 GENIUS Act

The 2025 GENIUS Act had a crucial role in setting the stage for the legality of stablecoin payments. It defined what a payment stablecoin is and who is allowed to issue stablecoins. It stipulated that stablecoins require full reserve backing with liquid assets, prohibited interest-bearing stablecoins, and created a federal and state regulatory structure. Overall, the purpose of the 2025 Act was to set guardrails. With this year’s notice of proposed rulemaking, the OCC is bringing a more procedure-focused approach.

New dedicated regulation

As mentioned above, the OCC is operationalizing the GENIUS Act in four major ways, the first of which creates a dedicated regulatory section (12 CFR Part 15) that establishes standards and requirements for stablecoin issuers. Creating the new part in the CFR changes the GENIUS Act from a written requirement into more enforceable supervisory standards.

New licensing

Additionally, new licensing mechanics come into play that create a defined pathway for entering the stablecoin market. Under the OCC’s proposal, prospective permitted payment stablecoin issuers (PPSIs) must submit a formal application outlining their business model, governance structure, reserve management approach, technology infrastructure, and risk controls. The proposal establishes what constitutes a “substantially complete” application and outlines supervisory review expectations. The new licensing process makes stablecoin issuance similar to applying for a bank charter, rather than launching a new product.

New capital and operational requirements

Similarly, the 2026 capital and operational requirements make stablecoin issuance look more like running a regulated financial institution than launching a new product. While the 2025 GENIUS Act focused primarily on reserve backing, the OCC’s 2026 proposal stipulates minimum capital thresholds, liquidity buffers beyond token redemption obligations, formal governance structures, internal control standards, and explicit third-party risk management expectations.

Established banks already have these processes embedded into their operating procedures. For fintechs, however, the new requirements may call for meaningful investment in governance, compliance documentation, and risk oversight infrastructure. These new formalities raise the cost of entry into the stablecoin issuance market.

New foreign issuer treatment

The OCC’s 2026 proposal incorporates foreign issuer rules directly into the scope of the plan, meaning that non-US players can no longer rely on regulatory ambiguity as a strategy to enter the market.

Just as the proposed framework requires US issuers, foreign issuers serving US users would still be required to apply for OCC registration, provide evidence of Treasury’s comparability determination, consent to US jurisdiction and OCC access to records, and meet requirements around US-available reserves (subject to any reciprocal arrangement).

This limits offshore entities operating in regulatory gray zones while marketing to US customers. The new rulemaking makes clear that global stablecoin players will need to align with US supervisory expectations, creating a more demanding roadmap for cross-border participation.

What this means for banks and fintechs

The proposed rulemaking makes clear that stablecoins are moving closer to the core of regulated banking activity and are increasingly being treated as part of the financial infrastructure rather than as a crypto experiment. As stablecoin issuance begins to resemble supervised activity, banks enter the conversation from a position of structural advantage. With governance frameworks, capital planning, risk management, and compliance processes already embedded in their operating models, traditional financial institutions may be better positioned than fintechs to comply with the regulatory demands of stablecoin issuance.

As compliance costs associated with stablecoin issuance rise, so does the barrier to entry. Not every fintech will have the appetite or resources to meet capital, liquidity, and supervisory expectations. The increased friction, however, brings institutional credibility to a payment type once considered adjacent to Bitcoin. This credibility lowers the risk for issuers as well as for end consumers and will ultimately transform stablecoins into an everyday tool.

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In July, JPMorgan Chase (JPMC) began notifying fintech data aggregators that it intended to begin charging significant fees for access to its customers’ bank account information. The shift triggered concern among aggregators about their business models, stirred interest among other banks eyeing similar moves, and raised red flags with regulators concerned about the broader economic fallout. Now, nearly five months later, the bank and its fintech partners have struck a deal on those fees, according to CNBC.

JPMC spokesperson Drew Pusateri said that the bank has updated contracts with aggregators that make up more than 95% of the data pulls on its systems, including Yodlee, Morningstar, and Akoya. Plaid was the first player to mutually agree on a new data access contract, inking a deal in September.

“We’ve come to agreements that will make the open banking ecosystem safer and more sustainable and allow customers to continue reliably and securely accessing their favorite financial products,” Pusateri said in a statement. “The free market worked.”

In this “free market” that Pusateri referenced, JPMC ultimately agreed to charge data aggregators a lower and more predictable price than what was initially proposed in July. While still a paid model, the fact that the terms were negotiated within four months indicates that market pressure, bargaining power, and competitive dynamics shaped the final outcome without the need for regulation.

While the parties declined to disclose specific details regarding the price, as well as the term of the agreements, it is clear that the revised agreements preserve commercial viability for the aggregators while allowing JPMC to monetize the data access.

By agreeing on reasonable terms, aggregators are able to operate with certainty when it comes to data sharing and open banking as the formal agreement brings clarity to open banking operations at a time when the CFPB has paused to revise Section 1033 of Dodd-Frank.

Importantly, today’s announcement marks a sea change in financial services. JPMC, which has historically been a leader in many aspects of banking, has signaled to other firms that they can generate a new revenue stream by leveraging their consumers’ financial data. And given JPMC’s scale and market influence, the move to charge fees will not be an isolated event. Other major banks are now positioned and incentivized to adopt comparable fee structures.

Regardless of the time frame it takes others to adopt a similar strategy, the potential of a new revenue stream will reshape the economics of US open banking over the next 12 to 24 months.

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If you’ve been paying attention to the open banking conversation in the US, you are aware that it is currently on the cusp of a major shift. In July, the Consumer Financial Protection Bureau (CFPB) filed a surprise motion to pause the legal battle over its Section 1033 data access rule. The Bureau then announced its plans to rewrite the rule altogether, and initiated a call for public comments.

The purpose of Section 1033 is to align principles on how consumers access and share their financial data. The rule essentially stands as the legal backbone of open banking in the US. For its part, the CFPB’s role is to define the technical and legal framework behind the mechanics of consumer data access. The Bureau is tasked with creating standards for data access, consent, and security.

The public comment period ends tomorrow, October 21, but writing a new rule will likely be anything but smooth. Aside from the various viewpoints from opposing stakeholders, which complicates the CFPB’s effort to write a fair ruling for all parties, there is now another wrinkle in the story. Last week, White House budget director Russell Vought said on a podcast that he wants to close down the CFPB. If the CFPB were indeed dismantled, would open banking stall or survive?

When the public comments period ends tomorrow, the CFPB will begin drafting the new open banking proposal. Further complicating the matter, the rewrite is unfolding alongside ongoing litigation over the original rule. The Financial Technology Association (FTA) is defending the rule in court after the Trump administration moved to overturn it back in May. In September it argued against an effort by the Bank Policy Institute to keep the rule on hold indefinitely, saying that big banks are trying to limit how much authority the CFPB has over open banking in hopes of shaping what the new version of the rule will look like.

Between the drafting of the new rule and all of the litigation, the next six-to-twelve months are pivotal in steering the open banking conversation. And yet, even as the rule is being rewritten and argued over in court, a much bigger question looms: what happens if the CFPB itself disappears? If Vought’s comments are correct and the CFPB is indeed completely dismantled there are a few likely scenarios of what may happen moving forward:

Regulatory limbo

With no agency to finalize or enforce 1033, the rule could be delayed or stalled indefinitely. This delay would slow technological adoption and would make open banking once again driven by the market, instead of regulation.

In fact, for years, banks and fintechs have been building API-based data-sharing frameworks and forming independent networks such as FDX, which unifies the financial industry around a common standard for the secure and convenient access of permissioned consumer and business data.

In the absence of regulatory guardrails, however, big banks could set the terms of data access and possibly introduce unreasonable fees or restrictive policies. Additionally, smaller fintechs could be squeezed out, which would ultimately reduce consumer choice. As a result, the US would have a more industry-controlled version of open banking instead of a consumer-centric model.

Reassignment

The authority to shape, finalize, and enforce 1033 could shift to other agencies such as the FCC or OCC. Swapping agencies, however, may create jurisdictional confusion since neither agency has a direct consumer-data mandate. This confusion may lead to slower adoption and reduced technological innovation.

If federal leadership falters, however, individual states may step in to organize their own regulations. States like California or New York may end up writing their own data-sharing laws. This would result in a patchwork of regulations, increasing compliance costs and complexity, especially for new fintechs seeking to compete. In theory, Congress could pass national open banking legislation, but bipartisan agreement on financial regulation (or any regulation) is rare.

Wiping out the CFPB will not wipe out the underlying law, Section 1033 of the Dodd-Frank Act of 2010. However, even though the law would continue to stand on its own two feet, the rulemaking, enforcement, and coordination around the law could be thrown into disarray. If the rulemaking is stalled for too long, it is likely that we will see individual states take matters into their own hands.

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Late last week, news was released that has the potential to disrupt the trajectory of open banking in the US. JPMorgan Chase has been in discussions with data aggregators, telling them that it plans to charge them to access customer data.

Traditionally, data aggregators like Plaid, Finicity, and MX have been able to access consumer banking data at no cost by using login credentials provided through third-party services. Introducing fees for this access raises important questions around consumer data rights, portability, and the future of financial innovation—and could significantly reshape the economics of open banking in the U.S.

In the US, open banking has largely been shaped by the private sector rather than by government regulation. This means that banks, fintechs, and data aggregators have had to create their own frameworks for sharing consumer financial data, often without clear, standardized rules. Yet consumer demand for data connectivity has grown rapidly. With the rise of third-party fintech apps offering budgeting, investing, and lending services, individuals expect these tools to connect seamlessly to their bank accounts and deliver real-time balances and transaction data. To support this, banks have traditionally allowed data aggregators to access account information either free of charge or for a relatively low cost.

JPMorgan’s rationale

While JPMorgan’s decision to charge for data access may not be unreasonable, it did catch many by surprise. The bank argues that aggregators are profiting from its infrastructure without contributing value in return. Citing rising infrastructure and security costs, as well as a desire for greater control over how consumer data is accessed and used, JPMorgan framed the move as a necessary step toward a more balanced data-sharing ecosystem

“We’ve invested significant resources creating a valuable and secure system that protects customer data,” JPMorgan spokeswoman Emma Eatman told Bloomberg, which broke the news. “We’ve had productive conversations and are working with the entire ecosystem to ensure we’re all making the necessary investments in the infrastructure that keeps our customers safe.”

Impact on aggregators

For data aggregators, the news is far from welcome. As one spokesperson noted, their cost of goods sold has essentially been zero. They charge fintechs for data access but haven’t had to pay banks to obtain the data itself. If banks like JPMorgan begin charging for that access, aggregators will likely pass the added costs to fintechs, which could ultimately trickle down to consumers.

Implications for open banking

JPMorgan’s announcement comes at an interesting time for open banking in the US. Section 1033 of the Dodd Frank Act was supposed to be finalized this October, and many were looking forward to the clarity that centralized open banking rules would provide the industry. Earlier this year, however, the CFPB announced plans to rescind 1033.

Regardless of whether or not formal rules are in place, however, the argument centralizes around an age-old question in fintech–who owns the customer data? While many banks claim that the consumer data belongs to them, some advocacy groups and aggregators claim that consumers should be able to do what they want with their data freely.

Introducing new costs to access consumer financial data could have several ripple effects on the future of open banking in the US:

• It may create barriers for fintechs offering services that consumers can’t get from traditional banks. This could slow innovation and reduce incentives for new entrants to build products that meet unmet financial needs.
• Consumers may face higher costs as fintechs pass on the fees associated with data access. Services that were once free or low-cost could become more expensive, prompting some users to reconsider their primary financial institution if their bank can’t match the functionality they previously enjoyed via third-party apps.
• It could accelerate the adoption of more secure, standardized data-sharing protocols, such as those developed by the Financial Data Exchange (FDX), which aim to replace legacy methods like screen scraping with tokenized, API-based access.
• It might also incentivize more screen scraping, as aggregators seek ways to avoid new costs. While most aggregators treat screen scraping as a last resort, increased financial pressure may push some to lean more heavily on automated tools such as AI agents to extract data through less secure channels.

What’s next?

While JPMorgan was the first to notify aggregators that it plans to begin charging, we can expect more financial institutions to make similar announcements. And while the CFPB seems unwavering in its decision to rescind the open banking rule as it was stipulated in 1033 last October, JPMorgan may shape or pressure new regulatory frameworks moving forward.

If more banks adopt similar policies and create uncertainty for fintechs and aggregators, we may see renewed momentum for a revised version of 1033, especially under a new administration. As consumers, banks, fintechs, and aggregators all begin to seek greater clarity and consistency, the US could shift toward a more structured, regulated model of open banking.

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FinovateSpring wrapped up earlier this month, and one of the main discussion topics I heard repeatedly was how to proceed during an era of economic uncertainty combined with regulatory freedom. The US is taking a vastly different approach to regulation than Europe, which seems to be tightening its grip on compliance.

In the US, there are four major moves that have indicated the new administration’s stance toward regulation in banking and finance. Among the regulations that are shifting are:

The Consumer Financial Protection Bureau (CFPB)

The key rulemaking activity of the CFPB has been paused. Employees have been instructed to stop work on regulations involving overdraft fees and open banking.

Crypto enforcement actions

The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have pulled back on enforcement actions in crypto, giving more clarity on stablecoin classification and providing more room for decentralized finance projects to operate.

Capital requirement rollbacks

Capital requirement rollbacks have reduced regulatory pressure on traditional banks. Key elements, like the supplementary leverage ratio and stress testing thresholds, have been softened or delayed, especially for regional banks. These rollbacks are designed to free up capital for lending and investment, but critics argue they increase risk by removing safeguards that were put in place after the 2008 financial crisis.

Basel III changes

Discussions of finalizing Basel III, which aims to require banks to maintain sufficient capital buffers and improve liquidity management, are still ongoing. However, lobbying has delayed its final implementation and resulted in a watered down version of some of its core provisions. A return to Basel II-style flexibility would prioritize bank competitiveness and profitability over strict capital adequacy.

While the current regulatory environment may give companies more room to innovate, most of the fintechs and banks I spoke with at FinovateSpring emphasized that they are still operating well within traditional regulatory boundaries, many of which are more stringent than today’s US standards. In fact, with AI now playing a major role across financial services, one compliance specialist noted that it’s increasingly common for firms to involve data scientists early in the compliance process to ensure new technologies meet regulatory expectations from the start.

Another focal point was third-party risk management, especially in today’s BaaS-driven banking environment. During my conversation with Christina Tetreault, Deputy Commissioner, Officer of Financial Technology Innovation at the California Department of Financial Protection and Innovation, she made it clear that bank-fintech partnerships are more than just IT projects. If the fintech’s technology fails, the bank will be held responsible for the issue.

As fintechs and financial institutions navigate this evolving landscape, the message from regulators and industry leaders is clear: regulatory freedom does not equal regulatory absence. Even as rules shift or stall, expectations remain high, especially when it comes to emerging technologies and third-party partnerships. In today’s environment, staying ahead means embedding compliance into innovation from the start of the project, proactively managing risks, and recognizing that regulatory clarity is still a moving target.

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The youth banking market has seen growth over the past decade, but it still has a long way to go. Throughout the years, banks have focused much of their efforts on chasing the customers with the most money. Higher net worth customers can increase a bank’s deposits, be willing to take advantage of more of the bank’s product offerings, and often come with lower risk of default. Children and teens, however, are less appealing of a market, as they generally do not add a lot of assets and can come with additional headaches, such as special regulatory requirements.

That said, 2025 may be a breakout year for youth banking, which is set to experience significant growth as enabling technologies, evolving customer needs, and market opportunities create a perfect storm.

FinTok is making finance cool

Short form video platforms like TikTok, YouTube, and Instagram have evolved from places to post fun dance videos to become hubs for financial education and empowerment. This is especially true for Gen Z users, who spend a lot of time on these social platforms. The financial niche of TikTok, FinTok, has turned into a channel in which influencers simplify financial concepts, share savings and investing tips, and make financial education entertaining.

Banks and fintechs have yet to fully embrace this style of communication, largely because of the regulatory implications. Whether or not they are trying to reach out to clients on the social platforms, however, the fresh content is working to promote new interest in finance among younger generations. In 2025, banks that embrace the FinTok trend could stand out as financial partners for a new generation of financially curious consumers.

Financial education is on an upswing

The U.S. historically has been poor at integrating financial literacy in education systems, but that is rapidly changing. Schools, nonprofits, fintechs, and banks have increasingly prioritized financial education, integrating it into curricula and offering free resources to both parents and children. We’ve also seen a rise in apps that gamify learning about savings, budgeting, and investing. For banks, this means that now in 2025, young consumers not only have interest in the financial ecosystem, but they are also starting off with a strong foundation and a greater appetite for digital financial tools.

Youth-centric features are increasingly common

Gone are the days when “youth banking” meant a basic savings account with parental oversight. In 2025, you can expect to see these platforms include a wider range of features, including gamified savings goals, allowance management, safe spending controls, and even investment tools tailored to teenagers.

Banks and fintechs that prioritize these youth-centric tools with intuitive design elements will create stickier products. Many are doubling down on youth-friendly offerings via partnerships with companies such as Greenlight, which partners with a wide range of banks, including U.S. Bank, to empower families with financial tools.

Youth banking tools offer a means of differentiation

With the fintech landscape becoming increasingly crowded, youth banking tools provide an opportunity for differentiation. By offering new, unique features for traditionally underserved kids and teens, firms can stand out while capturing an untapped market segment.

Youth-focused offerings also serve as a way to engage the entire family, as parents will likely appreciate tools that not only educate their children about money, but also offer a starting point for them to establish their financial standing. As the banking landscape becomes more crowded in 2025, we can expect to see more youth tools that serve as a differentiator.

The great wealth transfer is already underway

The great wealth transfer, the impending movement of $84 trillion in wealth from Baby Boomers to Millennials and Gen Z is one of the most significant financial shifts of our time. In fact, the funds transfer is already underway as some Millennials and Gen Z have already started receiving inheritance. As organizations seek to capture this wealth, marketing to children and teens will allow firms to capture some of the wealth from those who are just starting their financial journeys.

Millennial parents are seeking to break the cycle

Millennials experienced financial hardship during the 2008 recession and some are still reeling from a combination of that downturn and burdensome student loans. The majority of Millennials are now parents, and because many feel like they were shortchanged in financial education and opportunities, they are are determined to equip their children with better financial habits.

Unlike previous generations, many Millennials are actively seeking to teach their kids about money management from a young age. Youth banking platforms, with features like savings goals and educational resources, align well with this parental mindset.

For banks and fintechs, 2025 is a great time to take advantage of dual opportunity. Not only can they capture the next generation of customers, but they can also strengthen relationships with their existing customer base of Millennial parents.

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