. apple. pay, ” register, april 3, 2017, www. theregister. co. uk / 2017 / 04 / 03 / banking _ group _ denied _ access _ to _ iphones _ nfc _ chips _ for _ altapplepay / see, e. g., chance miller, apple maps now used 3x as often as google maps on ios, serving 5b requests per week, 9to5mac, december 7, 2015, https : / / 9to5mac. com / 2015 / 12 / 07 / apple - maps - usage - numbers /. for example, small business lender kabbage, inc. has entered agreements with large banks, where kabbage licenses its data analysis - heavy customer acquisition platform to banking partners who then go on to originate, fund, and service the underlying loans. see, e. g., kabbage inc., “ kabbage and santander uk partner to accelerate smb growth, ” press release, april 3, 2016, www. kabbage. com / blog / kabbage - santander - uk - partner - accelerate - smbgrowth /. - 13 - regulatory developments as regulators, we have a responsibility to ensure that the institutions subject to our supervision are operated safely and soundly and that they comply with applicable statutes and regulations. more broadly, we have a strong interest in permitting socially beneficial innovations to flourish, while ensuring the risks that they may present are appropriately managed, consistent with the legal requirements. we do not want to unnecessarily restrict innovations that can benefit consumers and small businesses through expanded access to financial services or greater efficiency, convenience, and reduced transaction costs. nor do we want to drive these activities away from regulated banks and toward less governed spaces in the financial system. regulators in the united kingdom and continental europe have recently outlined new approaches to facilitate connectivity in financial services, while attempting to mitigate the associated risks. in august 2016, the uk competition & markets authority ( cma ) released a package of mandates aimed at increasing competition for consumer and small business current accounts ( akin to u. s. checking accounts ). 27 this year nine of the country ’ s largest banks were required to create open apis to share nonsensitive, non - consumer - specific information, like pricing, fees, terms, and conditions as well as branch and automated teller machine locations. 28 uk competition & markets authority, “ cma paves the

to. wants to use a different api to monitor the history of a consumer ’ s physical locations over the previous week. and in some cases, the competitive interests of google and a third - party app developer may diverge over time, such that the original terms of access are no longer acceptable. 16 the fact that it is possible and indeed relatively common for the api provider - - the platform - - to require specific controls and protections over the use of that api raises complicated issues when imported to the banking world. as banks have considered how to facilitate connectivity, the considerations include not only technical issues and the associated investment, but also the important legal questions associated with operating in a highly regulated sector. the banks ’ terms of access may be determined in third - party service provider agreements that may offer different degrees of access. these may affect not only what types of protections and vetting are appropriate for different types of access over consumers ’ funds and data held at a bank in order to enable the bank to fulfill its obligations for data security and other consumer protections, but also the competitive position of the bank relative to third - party developers. there is a second broad type of approach in which many banks have entered into agreements with specialized companies that essentially act as middlemen, frequently described as “ data aggregators. ” these banks may lack the budgets and expertise to create their own open apis or may not see that as a key element in their business strategies. data aggregators collect consumer financial account data from banks, on the one hand, and then provide access to that data to fintech developers, on the other hand. 17 data aggregators organize the data they collect the financial times reported that uber will invest half a billion dollars into developing its own mapping software as it continues its push into driverless cars, thereby reducing its reliance on google maps. leslie hook, “ uber to pour $ 500m into global mapping project, ” financial times, july 31, 2016, www. ft. com / cms / s / 0 % 2fe0dfa45e5522 - 11e6 - befd - 2fc0c26b3c60. html? ft _ site = falcon & desktop = true # axzz4g0m5oyu8. for example, one major data aggregator reports that about 70 percent of the data it collects from over 15, 000 sources is collected via “ structured feeds ” under contractual agreements with financial institutions. see envestnet, inc.,