It is unclear what the future of the Consumer Financial Protection Bureau looks like, and that’s raising questions about the enforcement of its regulations, including its open banking rule finalized last year. Enforcement’s absence would lift a looming compliance obligation for financial institutions (FIs), effectively eliminating the need to treat open banking as a compliance task. This possibility could lead many bankers to breathe a sigh of relief — but that would likely be a mistake.

Banks and credit unions have already been installing open banking infrastructure in response to consumers’ demand for fintech apps that rely on connections to consumers’ bank accounts. And a growing number of uses for consumer-permissioned, API-based data access should make supporting this infrastructure more attractive. Use cases include account aggregation and personal financial management; authentication, account verification, and KYC; cash flow-based underwriting and credit scoring; and risk assessment and fraud mitigation for payments.

There are also security, privacy, and reputational risks for banks and credit unions associated with not adopting APIs for consumer-permissioned data access. Screen scraping, by which apps log into a consumer’s digital banking using their credentials and “scrape” data virtually unrestricted does nothing to protect information consumers want hidden. It also provides innumerable third parties with access to the FI’s digital banking system.

Banks and credit unions should recognize the competitive reasons to adopt APIs for consumer-permissioned data sharing — because consumers demand the products they enable; and consumers who use those products will most likely want to bank with an institution that makes it easy and secure to use their apps of choice, especially when the FI can’t provide the same customer experiences. If the moral cause for consumers’ open access to their data doesn’t resonate, the dollars and cents should.

In our research, we’ve found some institutions embracing open banking as a competitive advantage and backing it up with infrastructure, including extensive developer resources. Other institutions don’t have the technology in place at all. Those in the first bucket understand something the others don’t: This isn’t about policy, it’s about opportunity.

This article previews some of our recent findings on the state of bank technology, based on interviews across the banking industry. Stay tuned for a deep dive on core, payments, and digital in our upcoming report.