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Insights and Expertise

Banking-as-a-Service

A complete 360

Section 1033 of the 2010 Dodd-Frank Act introduced provi-
sions to give consumers a right to data held on their behalf
by financial providers. Section 1033 remains Federal Law
and states, in part, "A covered person shall make available
to a consumer, upon request, information in the control or
possession of the covered person concerning the consum-
er financial product or service that the consumer obtained
from such covered person."

Consumers remain legally entitled to access to their fi-
nancial data. The CFBP is obligated to create rules gov-
erning how that access should work. In October 2024, the
CFBP published its Final Rule, titled Personal Financial Data
Rights Rule. It required financial institutions and other
covered entities to provide consumers’ financial data to
By Ken Musante qualified third parties (including data aggregators) upon
Napa Payments and Consulting request, for free, via secure, standardized APIs.

anking-as-a-Service (BaaS) is white-label
banking. It describes a business model
wherein a financial institution provisions
B its banking infrastructure (payment system COMPANY
PROFILE
access, licensing, compliance) to third-parties who in Get the right
turn seek to provide digital banking, payment ser- Company Name
o
go
vices and/or other bank-type products. I define BaaS to L Logo Contact folks talking
Position
include both banks that have integrated a solution pro- Phone Number
viders’ digital offering and fintechs that have integrated Email Address about your
Website
into a bank. Company’s story: business with a

Lorem ipsum dolor sit amet, consectetur adipiscing
BaaS refers to a financial infrastructure platform. It is elit, sed do eiusmod tempor incididunt ut labore et Green Sheet
dolore magna aliqua.
distinct from open banking, which focuses on data ac- Ut enim ad minim veniam, quis nostrud exercitation
ullamco laboris nisi ut aliquip ex ea commodo conse-
cess, and embedded banking, which delivers banking quat. Duis aute irure dolor in reprehenderit. Company profile!
services within non-bank apps. Think of BaaS as the
plumbing and embedded banking as the faucet, while
open banking is the meter.
We’ll help you showcase
Bond, for example, is a platform that integrates with Your products and services
partner banks and provides a compliance layer for fin- Your mission
techs to provide their end customers a UI/UX frame- Your skills and expetise
work. Fintechs that partner with Bond have a readily We’ll tell the world
scalable and compliant BaaS platform to launch debit
and credit products. Why your company matters
Take steps now to
BaaS differs from (but also benefits from) open banking Enhance your visibility
or fintechs that aggregate and provide banking data. Boost your credibility
Open banking allows an app to read your bank data to
assist clients with making optimal financial decisions. Gain industry recognition
Unlock networking opportunities
Plaid, for example, acts as a bridge between a user’s Stir investor interest
bank account and a third-party app that might monitor Don’t delay!
spending at discretionary businesses. Data aggregators Contact Rick Aston today at
are similar to open banking providers, but the open-
banking term implies both banking and compliance. 707-284-1693 or rick@greensheet.com
Not all data aggregators are compliant.

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