"Requiring banks to build and maintain a portal for third-party access is already a significant burden. The burden is amplified for smaller banks [where some have] expressed that sufficient time would range from five to eight years, and that implementation time be staggered based on asset size."

https://www.pymnts.com/bank-regulation/2024/journey-from-screen-scraping-to-open-banking-will-be-more-marathon-than-sprint/