April 16, 2026
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 of Support for the FCRA Liability Harmonization Act and the Eliminating Fraud in the CFPB’s Complaint Database Act.
Dear Chairman Hill and Ranking Member Waters:
On behalf of the American Fintech Council (AFC), I write to express our support for H.R. 5775, the FCRA Liability Harmonization Act, and H.R. 7588, the Eliminating Fraud in the CFPB’s Complaint Database Act. Together, these bills represent important, targeted steps to improve the integrity, fairness, and functionality of the consumer financial regulatory framework.
A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.
AFC has consistently supported efforts to modernize the Fair Credit Reporting Act’s liability framework, including through a prior joint industry letter in support of FCRA litigation reform. In that letter, we emphasized the need to better align liability with actual consumer harm and to address the growing prevalence of litigation focused on technical violations. Specifically, lenders need confidence in their ability to assess risk without the constant threat of frivolous lawsuits. The proposed changes in this legislation achieve this and strike a critical balance: preserving the consumers’ ability to seek meaningful redress while curbing abusive litigation tactics that exploit an outdated law. H.R. 5775 advances this advocacy by establishing reasonable parameters around class action liability, including appropriate limitations on statutory damages and attorney fees and greater proportionality in outcomes. These reforms will help ensure that enforcement mechanisms remain focused on meaningful consumer protection while reducing incentives for abusive litigation practices. Passing the FCRA Liability Harmonization Act is an important action Congress can take to rein in abusive litigation practices while maintaining important consumer protections.
Additionally, AFC also supports efforts to improve the accuracy and reliability of the Consumer Financial Protection Bureau’s complaint database. Similar to the frivolous lawsuits discussed above, fraudulent and unauthorized consumer complaints create significant burdens for responsible industry participants, and obfuscate legitimate consumer complaints under the unending deluge of frivolous complaints. In turn, these actions undercut the intent of the consumer complaints database and hinder supervisory activities that seek to identify and stop nefarious actors. Ultimately, costing both industry and regulators significant resources that should be dedicated to ensuring legitimate consumer complaints are addressed in a fulsome and timely manner.
To that end, we applaud the Committee highlighting H.R. 7588, the Eliminating Fraud in the CFPB’s Complaint Database Act. The bill’s introduction of an attestation requirement that complaints are submitted by authorized parties and are accurate to the best of the consumer’s knowledge is a commonsense safeguard that will help address concerns around fraudulent, duplicative, or third-party-generated submissions. Ensuring the integrity of complaint data is critical, as regulators, policymakers, and the public rely on this information to identify trends and inform decision-making.
Providing financial institutions with the ability to appropriately close complaints that are duplicative, frivolous, unauthorized, or already resolved, while maintaining appropriate notification and recordkeeping, will further improve the functionality of the system and reduce unnecessary burden. In addition, protecting the confidentiality of narrative complaint data while continuing to allow for the publication of aggregated, non-identifiable information strikes the right balance between transparency, consumer privacy, and reputational fairness.
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Taken together, these reforms will help ensure that both the legal and regulatory frameworks governing consumer financial services are better aligned with real-world outcomes, supporting consumers while reducing opportunities for abuse and distortion.
We appreciate the Committee’s consistent leadership on issues that remain crucial to ensuring innovative banks and their fintech partners can serve consumers effectively and we stand ready to serve as a resource as you continue your work.
Sincerely,
Ian P. Moloney
Chief Policy Officer
American Fintech Council
CC:
Chairman Andy Barr, Subcommittee on Financial Institutions
Vice Chairman Barry Loudermilk, Subcommittee on Financial Institutions
[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, “Joint Industry Letter in Support of FCRA Litigation Reform”, (Dec. 15, 2025), available at https://american-fintech-council-new.webflow.io/advocacy/joint-industry-letter-in-support-of-fcra-litigation-reform.
[3] American Fintech Council, “AFC Letter to OMB Director Vought on CFPB Policy Priorities”, (Mar. 13, 2025), available at https://fintechcouncil.org/advocacy/federal-afc-letter-to-omb-director-vought-on-cfpb-policy-priorities.
About the American Fintech Council: The mission of the American Fintech Council is to promote an innovative, responsible, inclusive, customer-centric financial system. You can learn more at www.fintechcouncil.org.