AFC has long advocated for a clear and consistent regulatory framework that reflects responsible industry developments and clarifies supervisory expectations for innovative banks and financial services business models, products, and services. The organization expressed encouragement regarding the joint agency Request for Information (RFI), as well as the announcement of the Novel Activity Supervisory Program from the Federal Reserve. According to AFC, these efforts represent pragmatic, evidence-based approaches by regulators to understand bank-fintech partnerships rather than operating under preconceived notions of how the modern banking system should function.
However, AFC noted that certain agencies have developed an approach towards examinations and enforcement actions for innovative banks that has severely stifled innovation, thereby limiting consumer choice in financial services. "The path to regulatory clarity requires collaborating with responsible industry participants," stated AFC. They emphasized the need to streamline the current patchwork of rules and regulations and ensure fair and consistent enforcement throughout the industry.