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The US operates a dual instant-payments landscape: The Clearing House's RTP (launched 2017) and the Federal Reserve's FedNow (launched July 2023). Both are 24/7/365 and irrevocable; FedNow settles in central-bank money while RTP settles between participating banks. Adoption is accelerating but lacks a government mandate, and interoperability between the two rails remains a barrier. Open banking (CFPB §1033) is in regulatory limbo after the 2024 rule was reopened and enjoined. A retail CBDC is not being pursued; FedNow is distinct from a CBDC.
The regulatory theme is the status of open banking. The CFPB's Section 1033 Personal Financial Data Rights rule was finalised in October 2024 and challenged by banks; in 2025 the CFPB moved to vacate it and reopened rulemaking via an August 2025 advance notice of proposed rulemaking, with a December 2025 planned 'interim' final rule that may permit data-access fees. Open banking is therefore in regulatory limbo. A data-access fee permission would reshape the economics of fintech data aggregation — a theme illustrated by the JPMorgan-Plaid pricing deal tracked under W13 — and the regulatory uncertainty is a material planning risk.
Outlook
The instant-payments trajectory is accelerating, with RTP volume growth and FedNow institutional adoption both rising, though the interoperability gap persists as a structural friction. On open banking, the CFPB Section 1033 interim final rule is expected around the first quarter of 2026, potentially permitting data-access fees after the Bureau moved to vacate the 2024 rule; this remains at proposed stage and is asserted at Assessed confidence. The convergence of accelerating rail adoption and unsettled open-banking rules defines the near-term product environment.
Product Innovation & Market Development
The Commodity Futures Trading Commission's October 9, 2026 actions represent the defining product-access development for event-contract and prediction-market platforms this cycle. The interim final rule, effective immediately, excludes sportsbook and casino-style wagers from the Commodity Exchange Act's definition of a "swap." The companion notice of proposed rulemaking, issued the same day, proposes bringing sports, political, cultural and weather event contracts within that same swap definition, which would place these products under exclusive CFTC jurisdiction as federally regulated derivatives rather than leaving them to state-by-state gambling regulation.
For payment-service providers, acquirers and banking partners serving event-contract trading platforms, this regulatory action directly affects how these products should be classified, underwritten and risk-rated. A platform operating under the assumption that its event contracts are not swaps, and are therefore subject to state gambling law, faces a live possibility that the CFTC's rulemaking — if finalized as proposed — would reclassify its products as federally regulated derivatives, changing which licensing, registration and compliance framework applies to payment flows supporting the platform. This uncertainty sits on top of an unresolved circuit split regarding whether such contracts are subject to federal preemption, meaning payment providers currently face differing legal treatment of the same product category depending on which jurisdiction's law applies.
Outlook
The CFTC's NPRM process, together with the ongoing circuit-level litigation over federal preemption of state gambling law for event contracts, is the key development to watch for product-access and payment-classification purposes. Finalization of the NPRM, in either direction, would materially change the compliance framework payment providers and acquirers must apply to event-contract and prediction-market platforms.
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Product Innovation & Market Development
The US instant-payments landscape comprises two competing, non-interoperable rails. FedNow, launched by the Federal Reserve in July 2023, settles in central-bank money, while RTP, launched by The Clearing House in 2017, operates on a bank-owned model; both operate 24/7/365 with irrevocable settlement. Neither rail carries an adoption mandate, and the absence of FedNow-RTP interoperability continues to impede growth of the instant-payments ecosystem as a whole, even though more than 1,500 financial institutions had joined FedNow by early 2026, FedNow processed approximately 8.4 million transactions worth $853.4bn in 2025, and RTP surpassed $1.3 trillion in transaction value in 2025 — up 428% from $246bn in 2024. A majority of US banks (58%) now use both rails, reflecting a pragmatic multi-rail adoption strategy rather than a resolution of the interoperability gap. FedNow is distinct from a central bank digital currency; no US retail CBDC is being pursued.
Open banking remains in regulatory limbo. The CFPB's October 2024 Section 1033 Personal Financial Data Rights final rule was challenged by banks in litigation, and during 2025 the CFPB itself moved to vacate its own rule and reopened rulemaking via an August 2025 advance notice of proposed rulemaking. A planned December 2025 'interim' final rule may, for the first time, permit data-access fees — a potential reversal of the free-access presumption embedded in the original rule.
Outlook
The interim final rule on Section 1033, if and when issued, will be the pivotal event determining whether data-access fees become a permanent feature of US open banking; on instant payments, continued dual-rail growth without interoperability resolution is likely to remain the near-term pattern, with multi-rail bank adoption serving as the market's practical workaround.
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Sources and findings (4)
- T3Spherepay / ClearingPost — The US operates two competing instant payment rails — FedNow (Federal Reserve, launched July 2023, settling in central-bank money with zero counterparty risk) and RTP (The Clearing House, launched 2017) — both 24/7/365 and irrevocable.
- T3Spherepay / ClearingPost — More than 1,500 financial institutions participate in FedNow as of early 2026; in 2025 FedNow processed roughly 8.4 million transactions worth $853.4bn, while RTP surpassed $1.3 trillion in 2025 (a 428% increase from $246bn in 2024).
- T3American Banker / PYMNTS — There is no US mandate to adopt faster payments, and lack of interoperability between FedNow and RTP impedes growth; banks increasingly adopt a multi-rail strategy with 58% of US banks using both.
- T2Cooley / American Banker / CFPB — The CFPB's October 2024 Personal Financial Data Rights (§1033 open banking) final rule was challenged by banks, and in 2025 the CFPB moved to vacate it and reopened rulemaking via an August 2025 ANPR; in December 2025 it planned an 'interim' final rule that may permit data-access fees.