The IIF welcomes the recent BCBS report on open banking and application programming interfaces (APIs), published on November 19. In this letter to the BCBS Secretary-General, we convey our commendation for the report’s informative analysis, while also adding our views on areas that warrant further exploration and attention. The BCBS report provides informative analysis of the key security and liability issues - issues that are central to safe innovation. Together with greater API standardization over time, this can help to promote superior consumer outcomes.

Our main concern is where open banking frameworks may create asymmetrical data flows across sectors, which could in fact distort competition. Recognizing that this may extend beyond the scope of some banking supervisory mandates, we believe this merits a cross-sectoral view on data sharing, and we urge the BCBS and its member authorities to engage further with other agencies (such as data, privacy, and competition commissioners) to help promote design features that will support competition on a more sustained basis.