Title VI now includes the Community Bank Deposit Access Act, the SMART and TRUST Acts, and the Financial Agent Mentor-Protégé Program, collectively

These bills are focused on modernizing deposit frameworks, strengthening risk-based supervision, and supporting community bank innovation.

Washington, D.C. (February 9, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, expressed strong support for Title VI of the Housing for the 21st Century Act (H.R. 6644) while also offering a critically important amendment as the House of Representatives prepares to vote on the bipartisan legislation. In a letter to House Speaker Mike Johnson and Minority Leader Hakeem Jeffries, AFC noted that Title VI, Strengthening Community Banks’ Role in Housing, advances risk-based community banking reforms which AFC has long supported that will modernize supervision, reinforce accountability, and expand access to safe and affordable financial services. The letter also encouraged removing the 20% cap on custodial deposits, arguing it will create an artificial barrier for institutions seeking to responsibly scale deposit account access through bank-fintech partnerships.

“This bill aligns policy with the responsible innovation that community banks and their fintech partners are already doing to better serve their consumers and expand access to important financial services,” said Phil Goldfeder, CEO of the American Fintech Council. “We thank the House for recognizing that one-size-fits-all regulation does not work and that smart, tailored oversight is essential to expanding safe, affordable access to financial services.”

The Housing for the 21st Century Act includes long-standing AFC priorities by emphasizing supervision tailored to risk and business model, including through the SMART Act’s streamlined, limited-scope examination process and the TRUST Act’s updated framework for extended 18-month exam cycles. The legislation also strengthens community bank capacity through the Treasury-led Mentor-Protégé Program, providing guidance and support to smaller, rural, and minority-serving institutions while promoting responsible innovation and expanded access to safe, affordable financial services.

AFC also supports the bill’s clarification of custodial deposit treatment in Section 601, but urged lawmakers to amend the provision’s proposed 20 percent cap to avoid unnecessarily constraining stable deposits facilitated through responsible bank-fintech partnerships that expand consumer access without increasing risk. Adjusting the cap would allow community banks to responsibly scale access to digital-first deposit products, particularly for historically underserved communities, while supporting broader financial inclusion.

“A thoughtful, risk-based regulatory framework is critical to maintaining safety and soundness while allowing community banks and fintech partners to innovate responsibly,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “This legislation reflects an evidence-based understanding of how modern financial services operate and how transparency and accountability can lead to more effective oversight.”

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.

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