Data now moves through more systems, more business models, and more hands than anyone designed for. Screen scraping gave way to APIs. APIs multiplied the participants. AI is about to multiply them again.

And somewhere in that chain — between the bank, the aggregator, the fintech, and the consumer — something goes wrong.

When it does, everyone points somewhere else.

That’s not a technology problem. It’s a governance problem. And it’s the question that keeps general counsel, chief risk officers, open finance leads and regulators awake at night — because the existing frameworks weren’t built for this world.

The risk isn’t one thing. It’s a stack. And most organizations operating in open finance today are only managing part of it.

At the FDX Global Summit, four of the sharpest minds in US open finance — a banker, a lawyer, an aggregator & third-party provider, and an infrastructure provider — sat down to map it properly. What the risk actually is. Where liability should sit. Why the current model has already broken down. And what it will actually take to fix it.

The debate was unvarnished. The conclusions were uncomfortable. And the framework they arrived at has direct implications for every bank, credit union, aggregator, and fintech operating in the ecosystem today.

Download the report to find out what they said.