As Autumn turned to Winter and the Christmas tree went up, I’ve found myself daydreaming of a European holiday somewhere sunny. Maybe it’s the Instagram feed full of friends on a sojourn to Italy, France, or Germany, or the constant barrage of Premier League adverts on the NBC Networks (Let’s Go Gunners!), but earlier this year it was something else entirely that had me drifting off into a memory-induced Nutella-crepe state of euphoria.

The US Treasury Department released what can only be called a “canary in a coal mine” report. The report made a slew of recommendations to basically overhaul the entire US financial technology sector and to move the US back to the top of the innovation discussion (at least in terms of financial services).

You may be saying to yourself, “Mark, you are certifiably crazy; 1) chèvre (goat cheese) crepes are where the crepe pyramid of tasty hits its apex and 2) we have been talking about a lot of these things for years – this is just someone in Washington catching up to the rest of us because we are a competition-driven economy and sector.

While we all have our differences on the sweet vs savoury crepe discussion, Nutella is a gift, and while your logic is sound on point number 2, it misses the point. In the US, we are being driven by competition to a certain extent, but what we have learned in the aftermath of PSD2 and Open Banking is that competition can only get us so far. There is a very high barrier to entry that must be overcome. And for the flaws in those regulations, the overall intent has become clear; get more ideas into the market to drive us all forward. In the US, that bar was artificially lowered by the large amount of investment into FinTech startups, but at the end of the day, more than 75 percent of our accounts are held with just five institutions. So, while innovation can happen, it hasn’t spread as quickly as it potentially could.

To me, the most interesting part of the regulation vs competition pushing innovation debate, is the discussion on who “wins” and “loses” in each model. By splitting participants into winners and losers we fundamentally miss the point of where the “Open” discussion is leading, as this division assumes the current business models will remain the same. Ultimately, they can’t. Existing business models must adapt to their surroundings in an evolving FinTech sector if we are to unlock the potential windfall sitting on the other side of this debate. The saying may have been over-used in recent years when discussing the New Payments Ecosystem, however it still bears repeating here; a rising tide raises all boats. And the US just let us know that they are readying the harbour for the incoming tide – we can only hope it’s not too late!