Organizations urge targeted updates to support effective supervision and responsible bank-fintech partnerships

Washington, D.C. (January 14, 2026) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, today submitted a joint letter with the Independent Community Bankers of America (ICBA) urging federal banking regulators to modernize the framework governing Confidential Supervisory Information (CSI). The letter calls on the Federal Reserve, FDIC, and OCC to align CSI practices with today’s partnership-driven banking ecosystem while preserving the core purpose of supervisory confidentiality.

“Regulatory clarity and purposeful transparency in examinations is essential for effective supervision, especially in a financial system that increasingly incorporates third-party technology partners into banks’ activities,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “Prudential regulators should exercise their authority to allow narrowly tailored, purpose-limited sharing of supervisory information with agents and key service providers to improve examination efficiency without weakening confidentiality or risking regulatory overreach.”

The letter emphasizes that AFC and ICBA fully support the foundational goals of CSI, including protecting depositor confidence and preserving candid supervision. At the same time, it warns that outdated approaches to information sharing can slow remediation, increase supervisory burden, and undermine effective risk management when critical third-party partners are excluded from examinations and follow-up discussions.

“Bank-fintech partnerships are essential to how consumers access safe, affordable, and innovative financial services today,” said Michael Emancipator, Senior Vice President, Regulatory Counsel for the Independent Community Bankers of America. “When the rules around supervisory information prevent the actual operators of key systems from understanding issues and fixing them quickly, it creates unnecessary friction for banks, and ultimately the consumers they serve.”

The letter recommends coordinated interagency action to clarify the scope of CSI and to enable supervised institutions, with appropriate safeguards, to share relevant supervisory information with agents and fintech partners responsible for remediation or ongoing operations. AFC and ICBA stress that modernization would strengthen supervision, accelerate corrective action, and better reflect how regulated financial services are delivered today.

AFC reaffirmed its commitment to working constructively with regulators to ensure supervision remains rigorous and efficient while encouraging responsible innovation. The organizations urged the agencies to pursue a transparent, interagency process that includes input from banks, fintech companies, and other stakeholders.

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC’s 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.

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