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Education

branding requirements. ISOs are obligated to solicit Where does this take us in the long term?
merchants for merchant services under a name that
is registered with the payment networks. Each open In the short term, clients (like me) are awestruck by the
banking/fintech platform will wish to build its own brand speed and ease of accessing financial services through
and may have to either register itself, become a registered these new platforms. This initial "aha" streak will drive
sub-ISO of the ISO, or accommodate some exception so a lot of sales. As the ease of opening accounts becomes
that the ISO can be true to the payment network rules and more the norm and less of a novelty, the real promise of
continue to use its own name. open banking is that clients will be able to opt in and out
of financial services in the way that we install or remove
On the flip side, the fintech may lean on the ISO to apps from our phones.
sell other services such as banking services or money
transmission services for which the ISO would, in turn, Transfer of financial services-related data to the cloud
have to learn specific disclosure requirements so as to will also allow for more transparency and, theoretically,
keep the providers of those services in line with their greater competition in financial services.
respective rules and regulations.
In Europe the driving force behind open banking was to
Is there anything mind blowing here? foster competition between banks as well as innovation
amongst fintechs. That increased competition is yet to be
Yes. The speed by which a company can go from having apparent in the United States, but 2020 looks like a year
no accounts to having a full suite of financial service when it might begin in earnest.
accounts that includes a checking account, prepaid card,
credit card and merchant account is astonishing, as it can In publishing The Green Sheet, neither the author nor the publisher is
be reduced to minutes or even seconds. In the past, each of engaged in rendering legal, accounting, or other professional services. If
these accounts took pages of paperwork, visits to branches legal advice or other expert assistance is required, the services of a com-
and encounters with salespeople. That is all gone now, and petent professional should be sought. For further information on this
the whole package can be rolled out quickly as part of a article, please contact Adam Atlas, Attorney at Law by email at atlas@
very friendly user experience. adamatlas.com or by phone at 514-842-0886.

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