Federal: AFC Letter in Support of Legislation Enabling 21st Century AI Innovation in Financial Services

The Honorable French Hill
Chair
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 Legislation Enabling 21st Century AI Innovation in Financial Services

Dear Chair Hill and Ranking Member Waters:

On behalf of the American Fintech Council (AFC), I write to express our support for the robust discussion and consideration of bipartisan legislation that will help foster responsible AI innovation in financial services. The slate of bills proposed by the Committee represent a pragmatic, holistic approach to crafting a prudent federal regulatory framework for AI.

AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks who power them. Our mission is to promote 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. Our members are lowering the cost of financial transactions, allowing them to help meet demand for high-quality, affordable products.

AFC has long advocated for pragmatic, context-specific regulation of AI within financial services and believe it is essential to foster responsible innovation and competition in the use of AI. AFC strongly advocates for the development of policies that provide innovative financial institutions and fintech companies the ability to use AI as a tool to improve their products and services being offered for the benefit of consumers. Additionally, we have advocated for regulators to employ a risk-based approach to regulation, ensuring that guidelines are specific enough to address the complexities of AI systems, while being flexible to accommodate the diversity of applications in the market.

In August, AFC submitted a letter supporting the Unleashing AI Innovation in Financial Services Act (S. 2528 and H.R. 4801), which would establish supervised AI innovation labs within federal financial regulatory agencies and provide clear, risk-based “rules of the road” for the use of AI in financial services. We believe the additional legislation under consideration by the Committee complements that framework by strengthening defenses against AI-enabled financial crime, clarifying expectations for responsible AI use, and ensuring regulators themselves have the tools and data needed to oversee innovation.

Specifically, AFC supports H.R. 1734, the Preventing Deep Fake Scams Act, which would establish a task force on artificial intelligence in the financial services sector to consult industry stakeholders, standardize core AI definitions, and recommend best practices and policy responses to AI-driven fraud and identity theft. We also urge consideration of the proposals found within H.R. 2152, the Artificial Intelligence Practices, Logistics, Actions, and Necessities (PLAN) Act, which directs key departments to develop an interagency strategy to defend U.S. financial markets, businesses, and consumers from AI-enabled fraud, deepfakes, synthetic identities, and related financial crimes.

In addition, AFC supports the discussion draft House resolution Expressing the sense of the House of Representatives with respect to the use of artificial intelligence in the financial services and housing industries, which embraces a pro-innovation but risk-based approach, recognizes the importance of regulatory innovation labs, affirms that existing consumer protection and anti-discrimination laws continue to apply, and calls for any AI framework to be tailored so it does not disproportionately burden smaller institutions. We support the Artificial Intelligence Innovation Sandbox Information Generation and Harmonization of Testing (AI INSIGHT) Act discussion draft, which would task the Secretary of the Treasury to conduct a study on best practices for data sharing in regulatory sandboxes focused on the use of artificial intelligence tools in financial services. Finally, we support the Fostering the Use of Technology to Uphold Regulatory Effectiveness in Supervision (FUTURES) Act discussion draft, which would require financial regulators assess how outdated technology impairs their oversight, evaluate procurement, and workforce needs.

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Taken together with the Unleashing AI Innovation in Financial Services Act, these proposals would move federal policy toward a more coherent, risk-based framework that enables responsible AI innovation while enhancing consumer protection, financial integrity, and regulatory effectiveness. AFC appreciates your leadership in advancing bipartisan solutions in this space and stands ready to serve as a resource as you refine and advance these bills.

Sincerely,

Ian P. Moloney
Chief Policy Officer
American Fintech Council

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[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, “Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector” (Aug. 18, 2024), available at https://www.fintechcouncil.org/advocacy/federal-ai-letter.
[3] See, American Fintech Council, “AFC Letter in Support for the Unleashing AI Innovation in Financial Services Act” (Aug. 13, 2025), https://fintechcouncil.org/advocacy/federal-afc-letter-in-support-for-the-unleashing-ai-innovation-in-financial-services-act

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