5 key questions with Robert Courtneidge – Open Banking


by Analytics Insight

January 12, 2022

Robert Courtneidge has worked in the payments industry since he started working at Citibank in 1990. He had qualified as a solicitor that year and moved in-house to look after UK consumer banking, Citibank Life and Diners Club, where he got his first taste of the payments that were to follow him the rest of his career. Always a commercial lawyer with a penchant for technology, Courtneidge’s career has taken him to several roles in law firms working for many big name clients but always there to help new players. These start-ups have become more prevalent as FinTech became a major force after 2000. In this series, Courtneidge will examine critical topics in the payments industry today and provide her insightful answers!

The 5 key questions

Q1: What is Open Banking?

“Open Banking” is the term used to describe the framework that allows third-party providers to access the information needed to create online applications for banks and other financial institutions so that they can facilitate transactions and account switching at the name of their clients.

Source: Emerging Payments Pricing

Q2: What are the origins of Open Banking?

The starting signal for Open Banking came in 1983 when Deutsche Bundespost, a German public postal service that dealt with the telecommunications industry, launched a field test with around 2,000 private participants and 300 vendors on the side of the company. They offered participants the opportunity to test a new online banking service requiring a telephone connection and, among other things, made it possible to make electronic transfers by dialing this number *300#.

Q3: What is account aggregation and how did it fit into the Open Banking journey?

When banks started offering online banking services, it allowed smart guys from fintech companies to find ways to piggyback on their services and offer aggregated solutions. Yodlee was one of the first to enter this market and used what was known as “screen scraping” techniques to allow customers to view their online banking services through a central port, allowing them to view all their accounts together (aggregated) even if their accounts were with different banks.

Q4: How is Open Banking regulated today?

The introduction of the second Payment Services Directive in 2015 (PSD2) (i.e. Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market) has finally given third party providers (FinTech) the legal right to access the accounts of customers of banks and other account providers to offer their services to these customers.

In the UK, to do this, the third party provider must be registered as an “account information service provider” (i.e. a payment service provider who provides an online service for provide consolidated information about one or more payment accounts held by the payment service user with another payment service provider or with several payment service providers, and includes such a service, whether the information is provided: (a) in their original form or after processing; (b) only to the Payment Service User or to the Payment Service User and another person at the Payment Service User’s instructions;) or a ” payment initiation service provider” (i.e. a payment service provider which provides an online service to initiate a payment order at the request of the payment service user ent regarding a payment account held with another payment service provider) to the FCA under the Payment Services Regulations 2017. Other European countries have also implemented the directive.

Q5: Is Open Banking regulated in other countries outside of the UK and Europe?

Let’s look at a few countries that have implemented Open Banking laws:


The Monetary Authority of Singapore (MAS) has provided a framework and guidelines for Open Banking. In addition, the Association of Banks of Singapore (ABS) and MAS have jointly produced the Finance-As-A-Service Playbook to provide guidance to financial institutions, FinTech players and other interested entities in the development and adoption of an open API architecture.


Japan’s banking law was amended in June 2018 to promote Open Banking, and although implementation was voluntary, around 130 chartered banks in Japan were expected to offer open APIs in 2020. The implementation deadline was originally set for May 31, 2020, but progress has been slow, and the regulator has taken advantage of the current pandemic to extend the deadline. The plan is to cover all bank accounts, including savings and deposits.

Hong Kong

The Hong Kong Monetary Authority released an Open API Framework in July 2018, setting out a four-phase approach for banks to implement open APIs, starting with sharing product and service information and moving forward. ending with the sharing of transactional information and payment initiation services.


Brazilian regulators have issued new rules divided into three phases; banks, payment institutions and others authorized by the Banco Central do Brazil. At the discretion of customers, they may share registration and transaction data of natural or legal persons. The central bank has set a timetable for phased implementation in 2021. The rules will cover everything from register information to loan proposals to foreign exchange transaction data. In addition, it is planned to cover current accounts, credit cards, loans, insurance and KYC information.


Mexico passed a FinTech law in 2018 to set the standards for Open Banking over the next two years. FinTech law in Mexico applies to almost all financial entities and transactional data and products, but it does not include payment transactions. In addition, authorities are developing common API standards.

United States

A 2020 US Treasury report recommended developing regulatory approaches to secure data sharing in financial services. However, due to the highly fragmented and state-owned nature of banking and banking regulation in the United States, as well as a cultural aversion to “bureaucracy”, there is currently little discernible appetite to move forward. and issue a standard federal policy on Open Banking, although this may come with policy change. Interestingly, only 45% of US adults have heard of open banking, compared to 56% of adults in the UK.

Final thoughts

The global growth of Open Banking is reducing costs, increasing competition, and making banking and the ability to make and receive payments easier and faster. This can only be good for businesses and consumers alike. It certainly won’t be slowing down any time soon, so we can look forward to a better banking future for everyone.

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