The American Fintech Council (AFC) has issued a comment letter addressing the request for information on bank-fintech partnerships. This request was made by the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC). The AFC represents fintech companies and innovative banks, focusing on embedded finance.
Phil Goldfeder, CEO of AFC, highlighted the importance of these partnerships in expanding access to credit and banking services for underserved communities. "As one of the only organizations that represents both innovative banks and fintech companies, we know that responsible bank-fintech partnerships have dramatically expanded access to credit and banking services in historically underserved communities and are crucial to the continued viability of community banks nationwide," said Goldfeder. He urged agencies to support these partnerships with a modern regulatory framework that encourages innovation while ensuring consumer protection.
In their submission, AFC outlined recommendations for improving agency examination processes and promoting risk management practices across financial services. They also called for clearer guidance from regulatory bodies. The organization emphasized the role of these partnerships in enhancing competition within the financial sector and supporting community banks.
Ian P. Moloney, Senior Vice President and Head of Policy and Regulatory Affairs at AFC, wrote about educating examination staff on various bank-fintech models. He stated that "the Joint Agencies pursue significant education efforts for their examination staff specifically designed to educate these staff on the various types of bank-fintech models." Moloney also suggested implementing suptech tools to improve oversight activities.
The AFC's mission is to foster a transparent financial system through responsible innovation. Their members aim to enhance competition in consumer finance while serving underserved segments more effectively.