Financial Data Exchange (“FDX”) is an industry standards body comprised of financial institutions, data access platforms, fintech companies, consumer organizations, and other interested parties organized to address the need for an industry-wide standard for the secure exchange of consumer-permissioned financial information among financial services companies. The availability of such a royalty-free standard promises to unleash innovation in the provision of financial services to consumers, bringing new competitors seeking to assist consumers in achieving their financial needs, better managing their finances, and improving their financial health. FDX’s mission is one that can only be achieved efficiently through collaboration among industry participants, and the group approached its work from the outset with sensitivity to the requirements of the antitrust laws, delivering an unmistakably procompetitive outcome for consumers.

By Brad Jacobsen & David Kully1

           

I. BACKGROUND

On a cold day in March 2017, in the skiing village of Park City, Utah, a group of financial industry participants gathered to discuss how to better improve the permissioned sharing of financial data. The group referred to itself as “Initiative X” and would later become the “Financial Data Exchange” (“FDX”) when it launched on October 18, 2018. FDX addressed a critical need for the development of a standard to allow the

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