Open Banking in US – Quick Take CPFB Proposed Rule

Before listening to anyone on this topic its important to get a feeling for experience. I’ve been fortunate to run two of the largest online banks: Citi and Wachovia. Wachovia was the very first customer of Yodlee (1999), a service our customers loved. My banks were also scraped endlessly, representing over 30% of our traffic and 20% of our call center complaints. We were also the largest PFM bank (think MS Money and Quicken), keeping our OFX servers up and running was key. After my banking life I spent time rearchitecting payment data flows from point of sale to payment at Google. Then spent 8 years creating Commerce Signals, a payment data business. 
CPFB’s Proposed Rule

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Consumer Data Bureau?

Short blog today as opposed to the 9 page monster in identity and attribution Friday.  Today I’m providing my thoughts on what a consumer data bureau would look like.  Summary: Banks have a unique opportunity to create a consumer data bureau and be the key “switch” for regulated and permissioned data. Will they seize it?

Per blog yesterday, everyone has a partial view of you based upon their observations and what you trust them to hold (see Payments and Observer Effect). The more often you interact with a single entity, the more they learn about you. Today Google and Amazon know you much better than your bank. Any unique insights that a bank may have is limited by their ability to take part in that transaction. Thus entities, with the ability to initiate transactions, have the most control (summary of Identity will Define Future of Trust Blog).

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Incentives – How will Visa Amazon Play Out?

I outlined the Visa Amazon dispute in my blog 4 weeks ago. Today, Visa is confidently projecting it can bring the issue to a close. For the exec team to communicate confidence, my presumption is that they have both a primary strategy and a fall back strategy.  Given that the big players influence payments so heavily, let me lay out a few scenarios on how this could wrap up. 

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Plaid – Quick Take

I’m back to blogging after a successful exit last month. The Plaid acquisition is a great way for me to jump back in. Why read this? A key to understanding payments, banking and data is to balance historical knowledge with a network of people that know what is really happening behind the scenes. As the former head of two direct banks, former Senior Director of Oracle’s advanced technology solution’s practice and Yodlee’s first customer I have an informed perspective on the market for this one. 

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Data Tipping Point.. Good things will happen

Recent issues with Facebook, Equifax, GDPR compliance, … have brought us to a tipping point in data. The basic structure of how data is: permissioned, shared, used, accumulated, analyzed, sold, regulated, … must change. Google and FB operate in a Big Data 1.0 architecture powered by the “virtuous cycle”. Edward Snowden showed us how the NSA also acts in this centralized model as a data vacuum (not so virtuously). Literature and entertainment have created broad awareness of the dangers of centralization and loss of privacy: 1984, the Borg, The Circle, Black Mirror, … etc.  

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Banks as a Data Business – Example Amex Advance/Acxiom

Traditionally the core of bank margin is in risk management. The core of risk management is data.. thus Banks have been the among the best data businesses (as IBM knows). Banks “learn” about their customers through bank interaction: payroll, card transactions, lending. This has helped banks make better risk decisions (both credit and fraud/identity). Within the bank data cycle the traditional use of data is for an internal benefit: risk and cross sale of the bank’s products and services (not that of consumers or merchants).  However the “virtuous cycle of banking data” is very different from that enjoyed by Amazon and Google, both in the scale and type of data and consumer facing use. 

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