“AFC supports the goals of creating a federal framework for nonbank payment service providers and developing a unified approach to regulations in the payments space. The development of novel payments innovations with national and international applications necessitates a federal regulatory framework.

AFC has long advocated for a unified and consistent approach to regulatory oversight of innovations to avoid a patchwork or inconsistent supervisory landscape. Inconsistency stemming from a patchwork regulatory framework harms consumers, industry participants, and the resilience of the financial services ecosystem by inadvertently encouraging regulatory arbitrage. Comments from Ms. Nellie Liang, Under Secretary for Domestic Finance, at the Chicago Payments Symposium on the key elements promoting innovation and competition for the benefit of consumers through a ‘calibrated, regulatory framework for bank and nonbank payments providers,’ and the creation of a level international playing field, mirror AFC’s focus on ensuring a pragmatic regulatory framework that is properly adapted to the modern banking ecosystem is established.

AFC is encouraged by the U.S. Department of the Treasury’s efforts to modernize the regulatory environment within the payments space. We believe that developing a federal regulatory framework for nonbank payment service providers will ensure that responsible innovation can continue to flourish both domestically and abroad. We applaud the Department’s steadfast commitment to engaging with all relevant stakeholders in an effort to proactively modernize the federal regulatory environment in a pragmatic manner.”

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