White Paper - Monetizing Consumer Financial Data - Part 3
- Bryan Hahn
- Nov 4
- 1 min read
Since the original publication of Part 1 of this series, the regulatory and commercial context of Open Banking has continued to evolve. Two significant developments – the CFPB’s reversal of the implementation dates for the Section 1033 rule and Plaid's agreement with JPMorgan Chase – have underscored a global recalibration of how financial data access is monetized. At the same time, industry leaders have reframed the debate, urging financial institutions to treat APIs not as compliance costs but as strategic channels for engagement, distribution, and growth.
The first paper in this series emphasized the legal and philosophical cornerstone of open banking and the strict boundaries around monetization, whether data can be sold or traded as an asset, and if/how banks can monetize the infrastructure — the pipes through which that data flows — by offering differentiated service levels and value-added products.
The second paper drew on historical analogies of toll roads, Roman highways, and Genghis Khan’s Yam system to show that charging for infrastructure use is not new. The lesson is clear: infrastructure is often free at the point of regulation but becomes monetizable when layered with guarantees, protections, or enhancements.
Part three builds on this foundation by exploring specific pricing and partnership models, showing how financial institutions can create durable revenues without undermining the regulatory principle of free baseline access. See summary slides below or download the white paper below.
