Following an order by the Competition and Markets Authority (CMA), the OBIE was set up in 2017 by the UK’s nine biggest banks to implement the open banking regime. With Open Banking well established, the OBIE, currently overseen by the CMA, will be transitioned to a new entity next year. In her end of implementation roadmap summery report, Crosswell notes that while Open Banking has demonstrated its effectiveness, it is still only used by three in 20 digitally active UK Adults and that Account Information Services users has stalled. Writes Crosswell: "One of the impediments to progress has been the absence of clear cross-department vison for developing the UK into a Smart Data economy, where people and businesses have rights to access their data, wherever it may be held, and benefit from a wide range of new choices and innovations. "This lack of clear long-term vision for Smart Data has made it increasingly difficult to develop a roadmap to move from the current Open Banking ecosystem to a full Smart Data ecosystem." She warns: "If the UK is to retain its leadership position in fintech, it must be a leader in Open Banking/Open Finance/Smart Data." Crosswell recommends that Open Banking Limited (OBL) continues in its current state as it moves to the interim state to secure the ongoing four key requirements of directory, monitoring, standards and promotion of Open Banking. As for the longer-term future of OBL, Crosswell writes: "OBL is recognised by ecosystem participants for its holistic understanding of the UK Open Banking ecosystem, and there is a strong desire from some ecosystem participants and others to evolve OBL into a Future Entity that continues to champion the development of Open Banking. "Whatever OBL’s future, a failure to outline a clear plan to transition to a Future Entity creates uncertainty which creates a significant risk of losing expertise, experience, and knowledge."

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