Building When the Rules Keep Moving
Watching the open banking rule play out has been a lesson in what regulatory uncertainty does to a small bank. The rule was finalized, challenged in court almost immediately, and eventually sent back toward the drawing board. From inside a community bank, I followed it less as a policy drama and more as a planning problem, because that is what it became.
Startup Lessons, Seen From Inside a Bank
Distance changes how you read your own history. With some years between me and the startup chapter, and a stretch on the other side of the table inside a bank, a lot of what used to feel like friction or bad timing looks different now. Some of the walls I spent energy resenting turned out to be the actual shape of the business. Here is what I would tell the version of me who was building back then.
What the Middleware Collapse Revealed
For a few years, Banking as a Service looked like the rare arrangement where everyone won. Fintechs got to offer bank accounts without a charter, small banks got fee income and a foot in the digital door, and the people using the apps got slick products. I wanted that arrangement to work. Years ago, when I was building a payments product, a partnership like this was exactly what I was looking for and couldn't get. So when the model started breaking in the most visible way possible, I paid close attention, this time from inside a bank rather than outside trying to get in.
Mostly a Vendor Management Problem
The hardest part of using AI in banking is not the technology. It is figuring out where AI usage fits inside the vendor management discipline that banks already practice.
How the Three Layers Work
Banking as a Service has been a buzzword for a few years now, but the mechanics of how it actually works are often misunderstood. People use "BaaS" and "embedded banking" interchangeably. They are not the same thing, and the distinction matters.
A First Look at Identity in Banking
I've been turning over how many banking processes start the same way. Someone needs to prove they are who they say they are. Account opening, wire transfers, loan applications, address changes. Every single one begins with identity.
Making Sense of the CFPB's Data-Sharing Proposal
The CFPB put out a proposal last fall for what's being called open banking, and it has been on my mind since. The idea is that clients should be able to share their financial data with third parties through secure APIs, and that banks should be required to make that possible. I read most regulatory proposals trying to picture what I'll eventually have to build. This one I read as someone who has spent years building data plumbing, and from that angle it's the most interesting thing to cross my desk in a while.
What the Collapse Means for Banks and Digital Assets
FTX is gone. Filed for bankruptcy on November 11, and within days the picture went from bad to catastrophic. Roughly $8 billion in client funds, not lost to a market crash or a hack, but moved. Transferred to Alameda Research, a trading firm also run by Sam Bankman-Fried, and spent on trades, investments, and who knows what else.
Many Authorities, One Hard Problem
I had what felt like a straightforward question. What are the actual rules around crypto?
Even after spending real time on this, I don't have a clean picture. Multiple agencies have authority over different pieces, the federal framework is still being developed, and the right thing to do is acknowledge that and think out loud about what I can see from where I sit.
