Federal: AFC Letter in Support of Bank Fintech Partnership Enhancement Act

The Honorable French Hill
Chairman
Committee on Financial Services
United States House of Representatives
Washington, DC 20515

The Honorable Maxine Waters
Ranking Member
Committee on Financial Services
United States House of Representatives
Washington, DC 20515

Re: Letter in Support of Bank-Fintech Partnership Enhancement Act

Dear Chairman Hill and Ranking Member Waters,

On behalf of the American Fintech Council (AFC) and its members, I am writing to express our strong support for H.R. 6552, the Bank-Fintech Partnership Enhancement Act (the Act).

AFC’s mission is to promote an innovative, transparent, inclusive, and customer-centric financial system by fostering responsible innovation in financial services and encouraging sound public policy. AFC members are at the forefront of fostering competition in consumer finance and pioneering ways to better serve underserved consumer segments and geographies. Our members are also improving access to financial services and increasing overall competition in the financial services industry by supporting the responsible growth of lending and lowering the cost of financial transactions, allowing them to help meet demand for high-quality, affordable financial products.

AFC has consistently advocated for policymakers and regulators to: (1) engage in regulatory modernization that encourages competition and innovation; (2) develop a unified and consistent approach to oversight of bank-fintech partnerships; (3) increase clarity of supervisory expectations for regulated entities engaging in novel or innovative business models; and (4) avoid a patchwork or inconsistent supervisory landscape that can harm consumers and encourage regulatory arbitrage.

Fintech companies arose out of the combination of a dearth of consumer trust in traditional financial institutions in the wake of the 2008 financial crisis and increasing demand for modern, digital-first banking services.  Through partnerships with innovative financial institutions, fintech companies have been able to increase access to historically underserved communities, expand offerings, and create a robust and competitive market that has the ability to mitigate certain types of contagion risks in the financial services industry. As noted in multiple reports by the U.S. Government Accountability Office (GAO), responsible fintech providers provide the opportunity for significant consumer and market benefits.  Consistent with AFC’s March 31, 2025, letter to the Committee on the “Make Community Banking Great Again” principles, we believe Congress has a timely opportunity to build a pragmatic legislative agenda that strengthens community banks, supports responsible bank-fintech partnerships, and modernizes supervisory frameworks to reflect today’s digital-first financial system.

To that end, the Act would direct the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency to conduct a study on the impact of partnerships between fintech companies and banking organizations, including the extent to which such partnerships support community bank health, and the impact of these partnerships on the banking sector, competition, innovation, consumer protection, and the availability of financial products and services. The Act further directs the agencies to determine what changes to federal banking laws, or to agency rules or guidance, may help promote effective bank-fintech partnerships. The National Credit Union Administration is also required to conduct a similar report for partnerships between fintech companies and credit unions. This report to Congress would be required within one year of enactment of the Act.

AFC believes requiring an interagency study can help move the policy conversation toward durable “rules of the road” that encourage responsible innovation while reinforcing the distinct roles and responsibilities of regulated depository institutions and their fintech partners. Passage of this legislation would build upon the significant work of both the Committee and the prudential banking regulators to improve the policy landscape for responsible bank-fintech partnerships.

AFC appreciates the Committee’s continued focus on strengthening community banking and ensuring that U.S. regulatory frameworks keep pace with technology-driven change. H.R. 6552 is a pragmatic step that can help ground policymaking in facts about how partnerships impact community bank health, competition, and consumer outcomes, while identifying specific, actionable reforms to improve clarity and consistency across the federal banking agencies.

The American Fintech Council applauds Representative Andy Barr’s leadership on this important issue, and the continued focus on innovative community banks and their fintech partners by the Committee. We strongly support this legislation and urge its swift passage. AFC stands ready to serve as a resource to the Committee and prudential regulators as this work proceeds.

Sincerely,

Ian P. Moloney
Chief Policy Officer
American Fintech Council

[1] AFC’s membership spans technology platforms, non-bank lenders, banks, payments providers, loan servicers, credit bureaus, and personal financial management companies.
[2] American Fintech Council, "Federal: Advocacy Letter on Interagency Bank-Fintech Arrangements RFI," October 30, 2024, available at https://www.fintechcouncil.org/advocacy/federal-advocacy-letter-on-interagency-bank-fintech-arrangements-rfi.
[3] U.S. Department of the Treasury, A Financial System That Creates Economic Opportunities: Nonbank Financials, Fintech, and Innovation, (July 2018), available at https://home.treasury.gov/system/files/136/A-Financial-System-that-Creates-Economic-Opportunities---Nonbank-Financials-Fintech-and-Innovation_0.pdf.
[4] U.S. Government Accountability Office, Financial Technology: Additional Steps by Regulators Could Better Protect Consumers and Aid Regulatory Oversight, GAO-18-254, (Mar. 22, 2018), available at https://www.gao.gov/products/gao-18-254; and U.S. Government Accountability Office, Financial Technology: Products Have Benefits and Risks to Underserved Consumers, and Regulatory Clarity Is Needed, GAO-23-105536, (Mar. 08, 2023), available at https://www.gao.gov/products/gao-23-105536.

 American Fintech Council, “Request for Feedback on “Make Community Banking Great Again” Principles and Slate of Bills (Mar. 31, 2025), https://www.fintechcouncil.org/advocacy/federal-afc-letter-to-house-financial-services-committee-on-principles-to-make-community-banking-great-again.

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