Country _ Name
United States
SectionTitle
Online banking services
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FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).

API-Banking:

API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
 
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.

Introduction

Attitude of the country towards online-banking services

Online banking is well-established in the United States, with a significant portion of the population utilizing these services. As of recent reports, over 85% of adults in the U.S. have engaged in online or mobile banking, reflecting a high level of digital adoption. While a few institutions operate exclusively online, the majority of online banking services are provided by traditional banks that also maintain physical branches. The trend of white-label banking services, where traditional banks provide backend solutions for non-bank FinTechs, is increasing but remains relatively nascent compared to established banking practices. This reflects a broader shift towards digital financial services while continuing to integrate traditional banking structures.



Legal affairs

Obligations and requirements to provide online-banking services described above

All federally and state-chartered banking institutions, including those operating primarily online, are subject to rigorous regulatory oversight comparable to that of traditional brick-and-mortar banks. Oversight is provided by several federal and state agencies, including the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Consumer Financial Protection Bureau (CFPB), and various state banking authorities. The regulatory framework encompasses a broad range of requirements, including adherence to banking laws, consumer -protection standards, anti-money-laundering (AML) obligations, and data -privacy regulations

Online banks are not exempt from these obligations and face the same level of scrutiny and compliance requirements as their traditional counterparts. Compliance costs remain substantial, reflecting both the complexity of the regulatory environment and the resources required for internal governance, technology, and staffing.

The emergence of Banking-as-a-Service (BaaS) providers has introduced an additional layer to the online -banking ecosystem. BaaS providers use the licenses of regulated banks to offer banking services through non-bank platforms, effectively “white -labeling” the bank’s regulated infrastructure. This modelenables FinTechs to deliver products such as deposit accounts, credit cards, or lending services under their own brand. BaaS arrangements generally take two forms: one where the BaaS provider acts as the bank’s primary client, and another where the bank maintains direct relationships with end-users through the provider’s platform. This structure also facilitates embedding banking functionality into non-financial apps and online environments, such as offering debit cards, savings products, or short-term credit..




Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area

Using a Banking-as-a-Service (BaaS) model can be an efficient way for FinTechs to offer banking products without obtaining a full banking charter. However, participation in this model still places both FinTechs and their partner banks within a complex and evolving regulatory framework. While the regulated institution retains ultimate responsibility for compliance, regulators increasingly expect both parties to demonstrate clear operational controls and documented accountability across all consumer-facing activities..

Key considerations include:

  • Regulatory Compliance: FinTechs must ensure adherence to applicable federal and state laws, including consumer-protection, anti-money-laundering (AML), and data-privacy requirements, even when relying on a bank’s regulatory infrastructure.
  • Partnership Agreements: Comprehensive agreements with banking partners are essential to delineate responsibilities, oversight mechanisms, and compliance-reporting obligations. Regulators have recently emphasized the need for enhanced third-party risk management within such partnership.
  • Consumer Protection: Disclosures, marketing, and complaint handling must be transparent and subject to monitoring and remediation.
  • Data Security: Robust cybersecurity and data-governance measures are required to protect consumer information and maintain regulatory trust.


Economic conditions

Market size for online-banking services and biggest companies in this business area

Online and mobile banking are integral parts of the U.S. banking landscape. As of 2025, approximately 85% of American adults use mobile or online banking. In fact, a large majority of consumers now prefer to manage their accounts through mobile apps or online platforms rather than visiting physical branches. Most major U.S. banks—including JPMorgan Chase, Bank of America, Wells Fargo, and Citibank—offer comprehensive digital platforms, while digital-only banks such as Chime, SoFi, and Varo continue to expand their customer base.

In the United States, the Banking-as-a-Service (BaaS) market is estimated to be anywhere from USD 2 billion to USD 10 billion in 2024, with most forecasts projecting continued double-digit annual growth and potential expansion toward USD 30 billion over the next decade.




Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area

The U.S. online -banking sector continues to expand, supported by strong consumer adoption and the growing role of FinTech partnerships. FinTechs should be aware of several ongoing dynamics:

  • Increased Competition: Traditional banks, digital-only institutions, and FinTech platforms are competing directly for customer relationships. This competition is driving innovation in user experience, pricing, and service.
  • Regulatory: Federal regulators have increased scrutiny of bank–FinTech partnerships, emphasizing third-party risk management, consumer protection, and fair-lending compliance. Banks are expected to exercise full oversight of their partners, and FinTechs must demonstrate operational readiness and transparent governance structures.
  • Consumer Expectations: Users now expect fully digital, seamless, and secure financial interactions. Meeting these expectations requires continuous investment in cybersecurity, user interface design, and responsive customer support, as well as alignment with privacy and data-protection obligations..
  • Technology Integration: Strong integration with banking APIs, payment rails, and data-sharing infrastructure is critical for scalability and compliance. FinTechs that can deploy reliable and secure integrations with minimal disruption to partner banks’ systems are best positioned to compete in a highly regulated and fast-evolving environment.


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