From the desk of Melissa Feldsher:

Americans are using more digital financial tools than ever — to budget, save, invest, pay, borrow and manage their financial lives in real time. That is good for consumers, competition, and financial services innovation. But it also depends on something basic: trust.

At Chase, we support open banking and consumers’ right to access and share their financial data with the apps and services they choose. For our customers, trust is built through the accountability and everyday investments banks make to protect their most sensitive information. For us, this means securely connecting our 25 million customers to share their data with the more than 20,000 apps they choose to use for budgeting, payments, financial planning, and account verification.

Trust is not simply about whether data can be shared. It is about how data is collected, used, protected, and governed after it leaves a bank — and whether consumers have meaningful control and confidence their information is accessed only when necessary and only for authorized purposes.

When it comes to trusted data sharing, consumer control and consumer protection must go hand in hand. According to a survey conducted by The Clearing House, more than 80% of financial app users are not aware that apps may use third parties to access consumers’ personal and financial information and 78% didn’t know data aggregators regularly access personal data even when the app is closed or deleted.

As the Consumer Financial Protection Bureau (CFPB) prepares its next Section 1033 proposal, policymakers face a clear choice: advance open banking in a way that builds trust and strengthens the data sharing system or adopt a one-sided framework that gives data aggregators unfettered access while requiring regulated financial institutions to shoulder the cost of keeping the system safe.

The issue is not access. It is who supports the ecosystem.

For years, data aggregators, acting as data middlemen, have built profitable businesses on bank-built infrastructure by accessing secure data at no cost, repackaging that data and then charging downstream fintech apps. They monetize access to consumer financial data while expecting banks to build, maintain, and secure the infrastructure — and provide the data itself — at no cost. That's not a foundation for trust.

Secure data-sharing infrastructure does not appear out of thin air. Since launching our secure data sharing channels, we estimate we have spent hundreds of millions on building and hardening our data-sharing environment, ensuring a secure way for aggregators, payment processors and fintechs to access our customers’ data.

Banks invest continuously in cybersecurity, engineering, monitoring, fraud prevention, resiliency, and customer support to protect customers and their data. A policy that lets one side of the market charge while requiring another to provide access for free is not pro-consumer or pro-competition. It is a government-protected subsidy for data middlemen.

We have negotiated data-sharing agreements with 100% of data aggregators who access data through our secure channels. These commercial access agreements and fees offer one real-world example of what a modest, market-based approach can look like. Data aggregators — not consumers — pay just a quarter of a cent on average each time they pull data from our systems. Aggregators charge their clients multiple times more for the same data. Our purpose is simple: ensure all market participants support the secure infrastructure that makes data sharing possible.

These agreements, based on good-faith negotiations, yielded favorable results for aggregators too. We’ve increased investment to make data sharing faster, more reliable, and efficient, including enhancements to our secure data access channels and processes. In other words, fees help fund the innovation and infrastructure that benefit customers, fintechs, aggregators, and banks alike.

Some critics argue that data access fees for middlemen will limit consumer choice and slow innovation. Our experience demonstrates the exact opposite. Since introducing these agreements last year, the number of apps connected through our secure channels has grown by 80%, to more than 20,000 apps, enabling 25 million customers to continue connecting to the financial tools they choose. Customer adoption continues to grow, and data sharing continues to increase. Open banking and market-based commercial agreements are not competing ideas. They are how a secure, sustainable open banking system flourishes.

That should be the goal of open banking policy: consumer choice with consumer protection; innovation with accountability; and access with incentives that encourage secure use and lasting consumer trust.

What a strong Section 1033 framework should do

A strong Section 1033 framework should be grounded in a few common-sense principles:

• Protect consumers’ right to access and share their data. Consumers should be able to share their financial data and connect to the tools they choose, with clear consent and meaningful control over what data is shared, with whom, and how often.
• Require transparency from every participant. Consumers should know who is accessing their data, what data is accessed, how often it is accessed, and for how long.
• Make revocation simple and real. If a customer closes an account or no longer wants a service, the data connection should end.
• Hold data recipients accountable. Any company that accesses, stores or uses sensitive financial information should meet strong security, privacy, data-use and liability standards.
• Support secure, modern access. Open banking should rely on secure connections — not outdated practices that put consumers’ information at risk.
• Avoid mandates that distort competition. The CFPB should not require one group of private companies to provide infrastructure for free while another monetizes access. Such a mandate would undermine resilience, accountability, and fairness in the system.

The bottom line

The past year has demonstrated that innovation, consumer choice, and responsible data access can thrive together. Consumers continue to benefit from a growing ecosystem of financial apps and services, while industry participants have successfully implemented more secure data-sharing models — evidence that the market is working as intended. We're excited to continue building on that progress.

The beneficiaries of a well-designed open banking system are clear: consumers who can safely use the tools they choose; fintechs that can innovate on secure infrastructure; financial institutions that can continue investing in secure access; and a financial system that earns trust by protecting both money and data. The CFPB should build on this momentum by advancing a durable framework built on clear consent, strong security, real accountability, easy revocation, responsible data use and fair, market-based agreements.

That is how open banking is delivering on its promise — by building trust.

This material has not been reviewed, endorsed, or otherwise approved by, and is not a work product of, any research department of JPMorgan Chase & Co. and/or its affiliates. Information contained in this document has been obtained from sources, including those publicly available, believed to be reliable, but no representation or warranty is made by the document’s author or JPMorganChase as to the quality, completeness, accuracy, fitness for a particular purpose or non-infringement of such information. Sources of third-party information referred to herein retain all rights with respect to such data and use of such data by JPMorganChase herein shall not be deemed to grant a license to any third party. All information contained herein is as of the date referenced and is subject to change without notice.