Roqqett Blog

The Role of CMA9 in Modern Banking

Explore the strategic importance, strengths, and market insights of CMA9 banks in the era of open banking.

Quick Summary


The role of the CMA9 banks in modern banking is evolving rapidly, driven by the advent of open banking and the strategic opportunities it presents. These nine largest banks in the UK are uniquely positioned to leverage their extensive reach, physical infrastructure, and strong reputations to provide innovative, customer-centered services. By embracing open finance, CMA9 banks can enhance their service offerings, expand their market share, and maintain competitive parity in an increasingly dynamic financial landscape.

Key Takeaways

  • CMA9 banks understand the strategic importance of open finance for improving services and increasing market share.
  • The unique strengths of CMA9 banks, including their reputational investment in data protection, position them well in the open banking landscape.
  • The Open Banking Implementation Entity (OBIE) plays a crucial role in API implementation, data structures, and security, funded by CMA9 banks.
  • The 'leapfrog' model offers a bespoke approach for CMA9 banks to gain strategic and competitive benefits in open banking.
  • Market insights and cultural change are essential for CMA9 banks to build a case for transparency and greater market reach.

Strategic Importance of Open Finance for CMA9 Banks

CMA9 banks well understand the strategic importance of open finance, both in terms of the opportunities it offers to improve services to existing customers and to increase market share by reaching new ones, as well as the potential costs of failing to match innovation by competitors in the marketplace. However, there has been little divergence among CMA9 banks on open banking strategy and, as a group, large banks are taking relatively modest steps to provide services or access beyond those required by regulation.

Unique Strengths of CMA9 Banks in Open Banking

Reputational Investment in Data Protection

CMA9 banks have made significant reputational investments in protecting customer data and financial assets. This aligns well with consumer concerns about the risks of open banking. The synergy between these investments and consumer concerns creates a robust foundation for trust in open banking initiatives.

Synergy with Consumer Concerns

There is a clear synergy between the large banks' efforts to protect customer data and the concerns many consumers have about open banking. This alignment helps in building a secure and trustworthy environment for open banking payments, which is a win-win for both customers and businesses.

Combining Physical and Digital Interactions

By embracing open banking, CMA9 banks can combine their global reach and physical infrastructure with innovative, customer-centered digital services. This unique blend allows them to offer highly personal services that smaller, more agile financial services companies may not be able to match.

Traditional banks remain in a unique position to take a leap that others cannot. Their ability to combine physical and digital interactions sets them apart in the open banking landscape.

Role of the Open Banking Implementation Entity (OBIE)

The Open Banking Implementation Entity (OBIE) has been instrumental in the successful implementation of open banking in the UK. Established by the nine largest current account providers in Great Britain and Northern Ireland (the CMA9), the OBIE has created a standardized framework for easy and secure account access, enhancing competition and innovation within the financial services sector. This marks a pivotal milestone that has benefited businesses, consumers, and the wider UK fintech sector.

Leapfrog Model for Open Banking

We developed a four-step “leapfrog” model that helps CMA9 banks grapple with both of these principles by taking a bespoke approach to reap the rewards and address the challenges of open banking. Based on our research, expertise and client engagements, we have grouped open banking interventions into four categories of increasing strategic and competitive benefit. These categories comprise a model that is helping large banks:

  1. Prioritize and sequence open banking initiatives.
  2. Reduce possible new product features and service enhancements to three customer pathways.
  3. Deliver tangible results that address specific customer issues.
  4. Create a clear, focused, and actionable plan.

The leapfrog model offers significant strategic and competitive benefits for CMA9 banks. By prioritizing and sequencing initiatives, banks can focus on delivering optimal returns. This model helps banks to stay ahead of competitors by addressing specific customer issues through targeted pathways. The result is a clear, focused, and actionable plan that drives tangible results.

Our experience on both sides of the open banking equation has helped our clients achieve and act on these insights. Using the leapfrog model, we have helped a client prioritize and sequence its open banking initiatives to deliver optimal returns. Working with the client, we have reduced over 50 possible new product features and service enhancements to three customer pathways. These pathways deliver tangible results that address specific customer issues.

The leapfrog model is a bespoke approach that allows CMA9 banks to reap the rewards and address the challenges of open banking effectively.

Market Insights and Cultural Change

Building a Case for Change

The market insights that underpin this model also have an important role in helping CMA9 banks build a case for cultural change where it enables greater reach. Discover how a financial institution's culture and mindset impacts their digital maturity when it comes to leveraging digital banking solutions.

Transparency in Product Offerings

Whilst offering products such as mortgages via a third-party platform like Mortgage Engine can demand a new level of transparency from CMA9 banks on pricing and sales figures, including to competitors, establishing the number of products and services available is crucial.

Leveraging Market Insights for Greater Reach

Market insights are essential for understanding consumer behavior and preferences. By leveraging these insights, CMA9 banks can tailor their offerings to meet the needs of their customers more effectively. This not only helps in retaining existing customers but also in attracting new ones.

Navigating cultural change is a complex but necessary journey for modern banks. The ability to adapt and evolve in response to market insights can set a financial institution apart from its competitors.


By embracing the open banking model, CMA9 banks can effectively merge the innovative, customer-centric approach of modern financial services with the traditional strengths of established banking institutions. This includes their global reach, physical infrastructure, and the deeply personal service they offer. The strategic importance of open finance is well understood by CMA9 banks, both in terms of enhancing services for existing customers and expanding market share. Despite the relatively modest steps taken so far, the unique strengths of CMA9 banks—such as their reputational investment in protecting customer data—position them uniquely to leverage the benefits of open banking. By integrating physical and digital interactions, these banks can reclaim the branch experience to educate customers on open banking, ultimately leading to greater customer satisfaction and loyalty. The synergy between traditional banking values and modern financial innovation places CMA9 banks in a unique position to lead the industry forward.

Frequently Asked Questions

What is the CMA9?

The CMA9 refers to the nine largest banks in the UK, which have been mandated by the Competition and Markets Authority (CMA) to implement open banking standards. This includes creating APIs to facilitate secure data sharing with authorized third-party providers.

Why is open finance strategically important for CMA9 banks?

Open finance offers CMA9 banks opportunities to improve services for existing customers and expand their market share by reaching new customers. It also helps them stay competitive by matching or surpassing innovations from other market players.

What are the unique strengths of CMA9 banks in open banking?

CMA9 banks have a strong reputational investment in protecting customer data and financial assets. They can combine physical and digital interactions to provide a highly personal and responsible service, leveraging their global reach and physical infrastructure.

What role does the Open Banking Implementation Entity (OBIE) play?

The OBIE was created by the CMA to aid in the implementation of APIs, data structures, and security architecture. It ensures that individuals and SMEs can safely and easily share their financial information with third parties. The OBIE is funded by the CMA9 banks.

How does the leapfrog model benefit CMA9 banks?

The leapfrog model helps CMA9 banks identify areas where open banking approaches can align with their strategic priorities. It offers a four-step approach to reap strategic and competitive benefits, providing bespoke solutions tailored to the banks' needs.

What role do market insights play in open banking for CMA9 banks?

Market insights help CMA9 banks build a case for cultural change and greater reach. They enable transparency in product offerings and help banks leverage data to offer more competitive and customer-centric services.

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