I was at Money20/20 in Vegas when the shutdown news broke, and the thing that stopped me wasn't the politics. It was a technical detail buried in the coverage: the Federal Reserve lost access to its ADP payroll feed. The same data series Waller had cited days earlier to flag a cooling labor market just vanished. Policymakers cut rates to 3.75%-4% using stale numbers. That's not a policy debate. That's a data infrastructure failure, and it hit close to home.
If the Fed can lose its preferred real-time series because a private vendor pulled a voluntary feed, then every builder leaning on third-party data sharing is one dispute away from the same thing. ADP shared access as a goodwill gesture. The moment that data anchored a public speech, the feed disappeared. Expect more private vendors to set tight access rules going forward.
Markets caught the disconnect immediately. The Nasdaq closed at a record high on the second rate cut. Two-year yields jumped 10 bps. Traders trimmed December odds from 90% to 67%. Powell still sounded hawkish because his team had lost its high-frequency reads. The gap between what the Fed knew and what the market priced was visible in real time.
This matters for anyone building in vertical banking or healthcare fintech. Open banking is still voluntary. Treasury's comment window is open, but aggregators can throttle access whenever their incentives shift. Underwriting pipelines need buffers for that reality. And healthcare finance already lives with reimbursement lag and credentialing backlog. Clearinghouses can miss a file the same way ADP did.
So I'm updating our playbook. We now dual-source every critical feed (payroll, claims, transactions) with a primary and secondary path, so we degrade gracefully instead of freezing risk models. We document our vendor dependencies and the outage script we'll run, and we show that work to sponsor banks, auditors, and clients up front. We added alerts for stale files, delayed timestamps, and abnormal gaps in ACH or ERA data, because the Fed didn't spot its gap until decision day. And when I comment on open banking rules, I name the specific failure modes and the controls we fund today, because regulators respond to concrete mitigations, not slogans.
The risk here isn't permanent data loss. It's the growing expectation that every builder can describe a fallback. Instant payments, private credit exposure, AI-led underwriting: all of it leans on data we don't own. If one vendor disappearing would cripple your ledger, October was the warning.