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