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. We are encouraged by the joint agency RFI, as we were with the announcement of the Novel Activity Supervisory Program from the Federal Reserve, because these efforts represent pragmatic, evidence-based approaches by regulators to understand bank-fintech partnerships as opposed to operating under preconceived notions of how the modern banking system should function.

However, certain agencies have developed an approach towards its examinations of and enforcement actions for innovative banks that has severely stifled innovation, in turn limiting consumer choice in financial services. The path to regulatory clarity requires collaborating with responsible industry participants. We need to streamline the current patchwork of rules and regulations and ensure fair and consistent enforcement throughout our industry.