In his excellent book “Banking As A Service”, Jason Mikula examines the viability of various business models and notes the rise of “headless” banking: He points at a group of banks — eg, Column, Lead, and Cross River — who built new API-centric systems rather than put a middleware layer on legacy infrasturcture. These “headless” banks direct much or all of their banking business through partnerships in which third parties integrate directly with the bank tech stacks. Jason refers to this as a sort of wholesale/retail model, in which the bank provides the core capabilities of banking to the partners who build specific retail products for end customers.
Jason is right to highlight this stable model as a way forward in the U.S., which lacks the regulatory equivalent of the Payment Institutions (PIs) or Electronic Money Institutions (ELMIs) found in other jurisdictions. In other words, fintech firms in the US will continue to be dependent on banks if they wish to offer regulated products and services.