Welcome back to Fintech Takes. I’m Alex Johnson, joined (as always) by my partner-in-recapping, Jason Mikula. 

First up, the open banking saga continues with a new 13-paged ANPR (Advance Notice of Proposed Rulemaking) that reopens every fight. From whether “representatives” can access your data, if banks can charge cost-recovery fees, how liability hides under “security,” what counts as privacy vs. secondary use, and whether deadlines can be punted at all. With Chevron overturned and Corner Post wiping out time limits, every rule is now a lawsuit waiting to happen (even Visa has suddenly decided U.S. open banking isn’t worth the headache).

From there we head to our old friend BaaS Island, where Synapse’s implosion has left customers stranded. The CFPB’s novel UDAP claim and a symbolic $1 penalty may unlock redress, but only after years (while distressed-debt investors eye Evolve and Mercury). 

And then it’s on to Congress’s GENIUS Act, which hands stablecoins their first federal framework but also plenty of landmines. We discuss winners and losers, why Section 16(d) supercharges state preemption, and how Wyoming’s state “token” exploits the gap.

Plus, in our Can’t Let It Go corner, it’s  finance-as-casino: Chamath’s new American Exceptionalism Acquisition Corp SPAC, Robinhood suing Nevada and New Jersey to push prediction markets, and a Polymarket bettor who called Taylor’s engagement early and banked about $3,500 (the kind of thing that’d be called insider trading anywhere else!).

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