You have a point, but you are missing a larger problem that is part of why the US financial system is regulated the way it is. Regulatory capture by the banks themselves. At this time the regulatory environment serves as much as a barrier to entry as it does protection for the consumer. All the "whips and bondage" compliance requirements are relatively easy to achieve if you're already a full-scale multi-billion dollar bank. But they are a formidable moat for any startup that needs to scale before they can afford to do all the necessary compliance auditing.

This is why simple.com is a friendly front-end for an existing financial institution and not a bank in it's own right.