Open Finance is hanging by a thread.

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Stripe has enabled stablecoins in 101 markets. If I were a bank CEO, I’d be terrified. Citi is directly in 90 markets, HSBC is in 60, and it’s on the correspondent banking network. What CFO doesn’t want instant, 24/7 US dollar liquidity in 101 markets? Many more thoughts this week in Things to Know. 👀

Stablecoins are now arguably hotter than AI. Meta is said to be launching them; Ramp launched stablecoin-linked expense cards, and it’s a policy priority. My worry is we’re opening a can of worms for AML risk that will become painful. I’ve written a round-up in Things to Know 👀

The CFPB said it will vacate and rewrite the 1033 open banking rule this week. Cue a facepalm from all of Fintech. I have a counter-narrative here. I think the US still has the most vibrant and exciting open finance market. Your 📣 Weekly Rant is why you should be excited about open finance in the US and how we make it incredible.

Here's this week's Brainfood in summary

📣 Rant:

💸 4 Fintech Companies:

1. Finvest - The wealth aggregator

2. Acoru - The scam predictor

3. Zest Equity - SPV as a Service for the GCC

4. Next Generation - Stablecoin infrastructure and EuroF (EURF)

👀 Things to Know:

1. Stripe’s launches stablecoin accounts. A foundation model for fraud and its Order Intents API

2. Meta doing stablecoins? The GENIUS bill fails to pass by one vote.

📚 Good Read: Open Letter to the Democrats on Stablecoins

Weekly Rant 📣

Is Open Finance Hanging by a Thread?

Bloomberg reports the CFPB will vacate and rewrite the 1033 open banking rule entirely. An industry that spent a decade working toward rules now faces starting over with a skeleton CFPB staff.

But maybe, just maybe, this reset is what open finance needs (put the pitchfork down policy wonks, I’m going somewhere with this). 

The original rule was built for 2015's problems, not 2025's opportunities. 

Today:

• The scorched earth: 1033 is likely gone, what now?

• The reality check: Regulated open finance has underdelivered globally 

• The shifting landscape: Four fundamental changes since 2015

• The path forward: Building open finance with or without regulation

• The opportunity: Creating the infrastructure for the AI age

1033 is gone, what now?

How do you rewrite a rule that took 5 years to make, with 5% of the staff?: 

The original rule had finally established: 

• Clear data access rights for consumers 

• Standards for secure data transfer 

• Basic liability frameworks between parties 

• Requirements for data accuracy and dispute resolution 

Alex Johnson covered the consequences well. Here's what's at stake:

All of these would be very bad outcomes for consumers, banks and innovation. And rightly, the fintech lobby will fight hard to prevent it. The open finance genie is out of the bottle, consumers and industry use it daily, cashflow underwriting is normal. It’s not going away. 

Let me be clear: If you work in fintech and care about innovation, better underwriting, and a better payments ecosystem, you can and should support the American Fintech Council and Fintech Association’s fight against these moves. The latter has already filed a motion to intervene.

Now we're back to square one. But rather than just mourning what's lost, smart players will see opportunity in chaos.

The silver lining here is that the US actually has the best open finance market in the world. Not by regulation, but by market forces. Those market forces have historically been aggregators, fintech companies and VCs. But increasingly its companies like Experian, banks themselves and non banks.

Open finance is a rising tide that lifts the whole industry.

Maybe its my optimism bias. But I think if we take an honest look at the reality of other global regulatory regimes, and where we are in 2025, there’s plenty we can do in lieu of regulation and rules appearing.

The reality: Regulating Open Finance has under-delivered.

Don’t get me wrong, open finance itself has delivered miracles.

1. Speedier onboarding was a lifeline during the pandemic. When people couldn’t get paid, digital accounts became a literal lifeline.

2. Using cash flow (bank and fintech account) data to underwrite lending has been so effective that regulators now force banks to offer similar capabilities.

3. Pay by bank is showing real promise with payment volumes that make stablecoins look tiny.

The hard truth? Where robust regulation exists, open finance hasn't lived up to its promise.

In Europe, it’s regulated but not solved.

• Uptime and reliability isn’t solved: Banks report "99.9% uptime" while conveniently scheduling "maintenance" during peak usage hours

• The scope is very narrow: Most implementations cover only basic checking accounts, not the full financial picture

• Europe is incredibly fragmented: A different dominant player exists in UK, DACH region, Southern Europe, and the Nordics

• Payments aren’t solved: Nearly 10 years since the UK went live with open banking (in 2016), we’re finally getting “commercial variable recurring payments,” AKA subscriptions via pay by bank. 31 companies have agreed to fund a new entity that will setup and manage this standard. When will it go live? Great question.

(As an aside, I’m curious to hear from my European readers. What do you use open finance for, and what are your thoughts? I’m running a survey with M2020, and we’ll reveal the results in Amsterdam)

In the US, it was the Wild West, but it sort of works better.

Without clear regulation, the market created solutions anyway. Plaid became so ubiquitous we use it as a verb. Despite complaints about conversion rates and ecosystem fragmentation, the US built working infrastructure that millions use daily.

Nobody wants to return to 2015 to 2020. An era typified by a battle between screen scraping vs “secure tokenization.” One where a “secure” connection could only work when aggregators signed bi-lateral agreements with each individual financial institution. 

That was never going to scale. And frankly, it was a shakedown (despite having legitimate concerns about liability).

"Better" is relative, of course. US open finance still suffers from inconsistent experiences, occasional connection breakages, and opaque control systems and dirty games. But market competition has driven relentless improvement in conversion rates, connectivity, and user interfaces that regulatory-first markets haven't matched.

The world has shifted since 2015.

1033 is policy for 2015 in 2025, and four things have changed.

1. We learned payments are the killer app for open finance

2. We learned cashflow underwriting is the next best app for open finance

3. Fraud prevention, identity and data are huge opportunities

4. Stablecoins are now a thing.

The killer app for Open Finance is payments. 1033 largely doesn’t address this. Whereas in the UK, we have a definition of Payment Initiation Service Providers (PISPs): 

Plaid and Stripe tell me their volume on pay by bank is growing in the US too, often for surprising use cases like higher value purchases (e.g., a car deposit).

The second-best app for Open Finance is credit. This is a huge opportunity. Cashflow-based underwriting is becoming mainstream for SMBs (“revenue-based finance”) and consumers with entire categories like earned wage access. Even Experian has launched the “Cashflow score” as a new take on the FICO score. 

Fraud is the top-of-mind issue in payments because it’s growing so fast. Since 2015, fraud (and therefore liability) has become a much bigger problem. As wallets like Zelle, Venmo, and now pay by bank become normal, they lack some of the consumer protections traditional card networks offer (like chargebacks). The flip side of this conversation is that open finance data (and secure, tokenized bank connectivity) is a fantastic fraud prevention signal. What we’re missing is a logo mark, and a standard that makes this consumable and easy to d,o and consistent. 

Stablecoins are a thing. While stablecoin payment volumes are still smaller than pay by bank, they’re also growing at a faster rate and have captivated the mind-share of the payments industry and bankers alike. What they lack is a comprehensive, consistent anchor back to real-world identities and the world of fiat. Open finance is perfectly suited to be that gateway. 

There is no good, global example of open finance policy.

Except maybe Singapore, and even there it's not led to market traction.

• 1033 wasn’t it. It commoditised the banks, left gaps for liability and excluded some high-value use cases.

• PSD2 in Europe or CMA wasn’t it. It limited the use cases the market could offer, and didn’t fix the fragmentation.

My point here is that I think the US has a late-mover advantage. 

So while many won’t relish re-litigating the past half decade of 1033 lobbying wars, there’s also an opportunity to fix some foundational challenges.

Building a better ecosystem even without regulation.

Where’s the Dee Hock of open finance?

Dee Hock - Visa's founder created a system that aligned everyone's incentives.

How can we do that with open finance?

We need a clearer, broader revenue model for data providers. Telcos and ISPs built a new revenue model when the internet came along. Moving from a metered (per minute), to a data plan and then an all-you-can-eat, speed-based plan.If the value is in payments, cashflow data and fraud prevention, the consumer may own and permission access to that data, but who secures it and what happens when things go wrong?

We need a liability model for payments and data (cards show us the way). The genius of card networks isn't just technology - it's their liability framework that determines who pays when things go wrong. This creates the trust that keeps the system working. What would that look like in a modern context?

We need a trust mark for open banking-initiated payments. There is no uniform pay by bank experience. The lack of consistency creates a lack of trust. There’s nowhere this conversation is happening with real momentum. Whomever creates the logo-mark would also create the liability model and revenue model. What if we build this together at Fintech Nerdcon? Who’s with me?

Look.

It’s easy for some guy online to talk about what we need. Actually getting adoption through a web of lobbyists, vested interests and regulators who may or may not be there tomorrow is non trivial. 

Yet, I can’t unsee open finance as our on-ramp for digital finance, digital identity and potentially a secure anchor between humans, their assets and AI Agents.

We need world-class open finance infrastructure.

Open Finance is critical infrastructure.

As AI transforms finance, secure connections between people, their money, and their agents are critical.

AI financial assistants will need consistent, reliable access to: 

• Transaction data for personalization 

• Account access for payments and transfers 

• Identity verification to prevent fraud

We’re living through an authentication crisis, already. Customers have no trust anchor, no central point to manage their sprawling data and financial lives. They’re at risk of scams, overwhelmed by choice and paperwork, and we’re about to unleash AI against all of that.

Open finance provides the secure rails these systems will run on. If you can aggregate my financial life, you're best positioned to secure it against the coming wave of AI-powered scams. 

I hope we don’t have to rip up 1033 and start again.

But I also hope we take some of that lobbying energy and turn it into action.

Banks, fintech companies, infrastructure providers. If we unite around three things

1. A shared incentive model

2. A shared liability model

3. A shared security model 

We can unlock an open finance that is ready for stablecoins, ready for AI and ready for the future.

The card networks didn't wait for perfect regulation to establish their systems. Neither did Plaid, TrueLayer, or Stripe. In the coming uncertainty, the industry can choose: wait for Washington, or build the frameworks we need ourselves. The companies that thrive will be those that invest in solving collective action problems, not just their own product roadmaps.

It won’t be easy. When lobbyists and lawyers are involved it never is.

Let’s make a start and build it.

ST. 

4 Fintech Companies 💸

1. Finvest - The wealth aggregator

Finvest lets users find, connect and aggregate their investment accounts into a single view. It uses that to power an AI service it calls “discover” which offers “tailored insights” to your portfolio and interests

🧠If someone can make one of these that actually works it will fly. If you’ve been in the industry for a while, its easy to get jaded by “just another PFM app.” The question in the age of AI is, how good are these portfolio insights and will they cause me to behave differently? If the answer for enough users is yes, they’ll have something. But you’ll notice, Robinhood is launching similar features. So is this a feature or a product? It would be a product I’d pay for if it consistently helped me move money around. So far, I’m yet to find one that does.

2. Acoru - The scam predictor

Acoru aims to identify scams by looking for pre-fraud signals. Their site says they “learn from the past to predict a better future” which suggests you’re baselining good user behavior to look for deviations that signal scam or mule activity. 

🧠This is best practice and you should be doing this already. Detecting scams before they happen is the whole point, and the single biggest bang for buck on that is to baseline good user behavior and detect deviations from that baseline. It’s something Soups has been saying since I met the guy, generally considered best practice, but also, still surprisingly rare. Let’s fix that.

3. Zest Equity - SPV as a Service for the GCC

Zest Equity helps private equity issuers and buyers to transact on a single platform. It handles investor onboarding, creation of dedicated SPVs, document automation and closing. 

🧠 Setting up SPVs is the hidden work of fundraising. The paperwork mountain is enormous, and legal fees can quickly make it not worth the effort. At earlier stages smaller investors can be huge value add, so grouping them into an SPV makes a lot of sense for cap table management. Simplifying that for a market that’s starting to open up like the GCC is great timing. MENA is going to have an incredible decade.

4. Next Generation - Stablecoin infrastructure and EuroF (EURF)

Next Generation powers EuroF, a full backed MiCA compliant stablecoin that is redeemable 24/7 for cash. This enables zero cost, instant payments for anyone who uses the EuroF stablecoin.

🧠This is a relatively small group competing with Circle, and banks like SocGen and Banking Circle. I respect the hustle. They’ve been at this since 2017, long before regulation existed for stablecoins. Their wedge is connecting IBAN accounts to stablecoins and they just secured a $5m seed. Maybe survival is half the battle in this game. 

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Things to know 👀

1. Stripe’s launches stablecoin accounts. A foundation model for fraud and its Order Intents API

Stripe has launched global financial accounts. This dollar-based global financial account system in 101 countries. They also launched a transformer model for payments (to help detect fraud), and their order intents API (which is super cool)

Banks should be terrified of the stablecoin account:

🧠 What Stripe just launched threatens the core cash management business of global banks.

• Citi offers accounts in 94 countries (180 via network) and that took decades to build

• HSBC offers accounts in 60 countries

• Their two moats were the accounts and payments

• To a corporate treasurer, what Stripe just launched fits those needs better than the banks

🧠What corporate treasury team doesn’t want this? 

• 24/7 instant dollar transfers globally

• Programmable treasury operations

• Instant yield optimization

🧠 I'm hearing from insiders that bank middle management is dismissing stablecoins as "crypto hype."Big mistake. This isn't about crypto - it's about INFRASTRUCTURE. Stripe's growth trajectory for stablecoin adoption exceeds their own core payment processing growth.

🧠 The banks have closed loop competitors but they’re not gonna get the same traction. The closest competitor is JP Morgan's Kinexsys, but it lacks the developer accessibility and global reach that Stripe offers out of the box. It’s closed loop.

🧠 Banks are right to worry about narrow banking, but should we be? The banking lobby is already pushing back against the GENIUS Act - because community banks recognize the existential threat. But regulation won't save them from innovation. Stablecoins have product market fit.

🧠 There will be a handful of winning banks in stablecoins. I wrote a couple of weeks ago about the 8 ways banks can make money from stablecoins. Like BaaS, there’s a giant opportunity here if you’re on the front foot instead of lobbying on the back foot.

🧠Whenever someone has “incredible growth” in finance the former banker in me is SCREAMING about AML risk. Stablecoins operate in high risk markets, abstracting lots of intermediaries, with varying last mile KYC capabilities. This is less of an issue for the corporate treasury use case but still. I fear AML horror stories in ~2 to 3 years time. However…

🧠Stripe’s now foundation model for payments is genius. Their specialized transformer model for payments increased card testing fraud detection rates from 59% to 97. We’re still lost in the “LLM” hype, and missing the value of transformers IMO. (Low key, that before number wasn’t very solid, sorry)

🧠Order intents guides AI Agents through product selection and fulfilment. It gives merchants an ability to elegantly handle AI Agents that land on site. The volumes here are still low, but AI has this annoying habit of going from 0 to 1000mph every few months. Better to be ready.

2. Roundup of other big news.

Meta is apparently doing stablecoins 3 years after abandoning libra. 

• 🧠Regulators hated Libra, but are much more open to stablecoins. Stripe’s massive, 101 countries launch would have major overlap with the 2.7bn users Meta has. Most of whom have a much lower ARPU than the US customers. Payments unlock that. 

The Senate blocked the Genius act

• 🧠 The banker worry is narrow banking, deposit flight and yield. The irony being, SVB was a bigger risk to stablecoins than 1:1 backed stablecoins have ever been to banking. 

• 🧠 The political push back is anti corruption provisions. While I agree with the concern here, it’s also a very political point. We desperately need rules to pass because stablecoins are growing incredibly fast. Not sure how this gets solved but it needs to happen fast.

Coinbase launches x402 a new protocol for money

In the same week they agreed $.29bn for Derbit, what caught my eye is the launch of x402. It is a protocol to recognize a payment needs to be made, and handle AI Agents, stablecoins and settlement without a checkout, partnering with AWS, Anthropic and Circle.

• 🧠IF this could get traction, it would be a game changer. AI Agents need a web protocol. Coinbase has a habit of launching things that seem weird or esoteric that go on to do well (e.g. Coinbase Wallet, Base)

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Good Reads 📚

Open Letter to the Democrats on Stablecoins

Austin implicitly states stablecoins are an alternative to bank monopolies, and calls out the Democrats for being servants to the bank lobby since the financial crisis. The context here is we’re close to a bill that would regulate stablecoins (GENIUS), but it looks like Democrats are holding this up on the basis of financial crime risk.

🧠 I dislike the partisan idea that either banks are good for consumers because they are less risky and better at compliance. Or similarly, stablecoins are cheaper and could be more transparent and fair. Life is rarely that simple. 

🧠 Austin’s core point is much of the regulation and legacy tech of banks create cost and in turn, that creates financial exclusion. That I agree with, and all the regulation in the world won’t fix a regulation and legacy tech problem. New tech will. New tech like stablecoins. 

🧠 The battle lines are being drawn on financial crime. Again, here Austin is right. If you care about this issue, the best outcome is fixing our existing system. Bankers engage in lots of “whataboutism” when it comes to stablecoins to try and distract us from the dumpster fire that is SWIFT and existing legacy financial crime norms. 

🧠 Do you know what % of crypto is money laundering? Best estimates put that at 0.14%. Vs 1 to 3% in TradFi. There’s bad things in crypto for sure, but its transparent, we see it all, we can follow the money with all of it. Not true in TradFi.

🧠The vast majority of SARs are never investigated by Government. If there’s a bottleneck in the system that needs fixing its at law enforcement. 

🧠 Austin runs through ever single misconcept about stablecoins and takes them on one by one (like stability risk, consumer harm). I would strongly encourage you to read this. Austin is logical, consistent, and compelling. 

Tweets of the week 🕊

I really don’t like sports betting as a category. There I said it.

Ramp is leaning into stablecoins because they consistently execute on whatever is hot. But this gave me high risk heebie jeebies, NGL.

That's all, folks. 👋

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