US banks are operating in a different environment to their European or Asian peers. The regulators are different, the real-time rails are different, the consumer protection regime is different, and the 2023 regional bank stress reset what every US bank board now expects of its IT estate. The question for a US bank CTO heading into 2026 is no longer whether to invest in software but where the next dollar goes, and that calculus looks different in the US than it does anywhere else.
The US regulatory shift that is redrawing IT priorities
Three regulatory currents are driving spend right now. The Consumer Financial Protection Bureau finalised the Personal Financial Data Rights rule under Dodd-Frank Section 1033 in late 2024, mandating standardised consumer-permissioned access to financial data. Implementation timelines run through 2026 and 2027, and most banks are well behind on the API platform work required to comply at scale. The OCC has continued to clarify expectations on AI and machine learning risk management. The FFIEC has refreshed cloud and third-party guidance to reflect the realities of multi-tenant cloud and managed AI services.
The practical implication for engineering teams is that any roadmap built before 2024 needs a revisit. Section 1033 alone is a meaningful API platform programme. Layer on the AI governance build that the OCC bulletin requires, and the ICT third-party oversight that FFIEC guidance is steering toward, and the picture is a multi-year regulatory engineering programme dressed as compliance work.
FedNow and the US real-time payments build
The Federal Reserve's FedNow service launched in mid-2023 and now has over a thousand participating institutions. Adoption is climbing and several national use cases (real-time payroll, instant insurance disbursements, digital wallet top-ups) are pulling demand into the system. The Clearing House's RTP network has been operational longer and continues to expand.
For a US bank's engineering team, the build is non-trivial. Real-time payments require 24/7/365 uptime on the messaging stack, integrated fraud screening that runs in milliseconds, exception handling that does not depend on overnight batch reconciliation, and a customer experience that surfaces real-time confirmation in mobile and online banking. Banks running FedNow against legacy cores via vendor adapters tend to discover the cost of that shortcut at the second wave of volume.
What the 2023 regional bank stress surfaced about IT
The collapses of Silicon Valley Bank, Signature Bank, and First Republic in early 2023 surfaced more than balance-sheet issues. Post-mortems from the Federal Reserve and FDIC highlighted how IT and risk-data infrastructure shape what a bank's executive team can see and act on under stress. Banks that had invested in modern data platforms could trace deposit flows, customer concentrations, and liquidity exposures in real time. Banks that had not were running spreadsheets and end-of-day batches at exactly the moment that hours mattered.
The lesson has reshaped how regional and mid-size US banks are sequencing their IT investments. Real-time data platforms, granular customer concentration analytics, and resilient liquidity dashboards are no longer aspirational items on a strategic plan. Bank examiners are asking about them. Boards are asking about them. The custom software work that previously sat in a "nice to have" tier is now closer to mandatory infrastructure.
Where custom software actually wins for US banks
Five categories consistently produce outsized returns for US banks investing in custom software in 2026.
Open banking and API platform work for Section 1033
Most banks will not pass the rule with their existing data plumbing. The work is API design, consent and entitlement management, audit logging, performance hardening, and developer experience for the third-party data recipients that will come knocking. Banks that build this as a product capability rather than a compliance project will be able to participate in the embedded finance economy that Section 1033 unlocks.
Real-time data platforms for risk and liquidity visibility
The post-2023 regulatory tone is unambiguous. Real-time visibility into deposits, lending exposure, customer concentration, and operational health is now table stakes. Custom software work here typically involves a unified event stream, a governed feature store, and dashboards engineered for the executive and risk audiences, not just the analytics team.
AI delivery on a governed platform
AI is delivering measurable value in fraud, customer operations, compliance drafting, and engineering productivity across US banks. The differentiator is the platform: evaluation harness, observability, model risk management integration, and clear lineage from prompt through tool call to output. Banks that treat AI as a feature stall. Banks that treat AI as a platform capability compound.
Customer experience beyond the mobile app
The first generation of US bank mobile apps reached parity with branch capability. The next wave is proactive: surfacing savings opportunities, flagging cash flow risk, renegotiating recurring expenses, automating fraud disputes. This requires the data platform, the AI capability, and the API depth to compose the experience, which is why it lags real-time data and AI platform work in most roadmaps.
Modern core extension and product configuration
Few US mid-market or large banks will replace their core in the next three years. Most are extending the core with a modern API gateway, a modern product configuration layer, and selective new-product cores from Thought Machine, Mambu, 10x Banking, or Tuum. The custom software work is the integration and the product configuration tooling that lets product managers ship without an engineering sprint. For more on the underlying architecture, see modern banking architecture.
Common failure modes in US bank digital programmes
Three patterns show up repeatedly in US bank programmes that have stalled.
- Treating Section 1033 as a compliance project. Banks that scope it narrowly as "expose the data, pass the audit" deliver a brittle, expensive system that they then have to rebuild as a real product platform. Banks that scope it as a permanent product capability ship something they can extend.
- Underinvesting in the platform layer. US banks fund visible features faster than they fund shared platforms. Total cost of ownership balloons. Velocity falls. The pattern is universal across banking, but particularly common in US regional banks where vendor-led roadmaps dominate.
- Vendor monoculture. Banks that hand strategy to a single systems integrator or a single core vendor end up with that vendor's business case, not their own. Roadmap ownership matters.
For the broader global view of where digital programmes stall, see our piece on where banks should invest next. For the operational resilience picture, see our DORA compliance guide.
How Scrums.com partners with US banks and FinTech
Scrums.com partners with US banks, credit unions, and FinTech platforms to design and deliver the software that defines modern financial services. Our banking software development services span Section 1033 implementation, FedNow integration, real-time data platforms, AI delivery, core extension, and customer experience builds, all engineered for the security, resilience, and regulatory expectations of the US sector.
If your US digital programme needs a partner with engineering depth and regulated experience, start a project with us.
FAQ
What is the most important regulatory shift for US bank IT in 2026?
The CFPB's Personal Financial Data Rights rule under Section 1033, finalised in late 2024, is the largest single driver of new IT investment for US banks heading into 2026. Compliance timelines through 2026 and 2027 require a real API platform, consent management, and developer experience for third-party data recipients.
How does FedNow change US bank engineering priorities?
FedNow requires 24/7/365 uptime on the messaging stack, sub-second fraud screening, exception handling that does not depend on overnight batch reconciliation, and a customer experience that surfaces real-time confirmation. Banks running FedNow on legacy cores via vendor adapters typically discover the limitation at the second volume wave.
What did the 2023 regional bank stress teach the sector about IT?
It surfaced how dependent executive decision-making is on real-time data infrastructure. Banks with modern data platforms could trace deposits, exposures, and liquidity in real time. Banks running on overnight batches were behind events. The lesson has accelerated investment in real-time risk and liquidity visibility across mid-size and regional US banks.
Should a US bank replace its core or extend it?
Most are extending the core with modern APIs and product configuration tooling, while running selective new products on a modern core platform from vendors such as Thought Machine, Mambu, 10x Banking, or Tuum. Full core replacement is rare in the next three years, and when chosen, runs as a multi-year strangler programme.
What is the right balance of in-house and external engineering for a US bank?
Strong in-house leadership is non-negotiable. Specialist partners add capacity, velocity, and domain depth, especially for time-bound programmes such as Section 1033 implementation, FedNow integration, AI platform delivery, or regulated-grade mobile builds. The worst outcome is full dependency on a single external party with no succession plan.
