Our Mission

Promoting a transparent, inclusive, and customer-centric financial system

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative BaaS banks. 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.

Empower underserved consumer segments & geographies

AFC differentiates itself from other trade organizations through its focus on the following standards and core principles:

Innovative

Utilize technology and data to create safe and accessible financial services to reach underserved and underbanked communities.

Responsible

Offer only affordable, transparent, responsible products that help families build financial health; Align our business success with the success of our customers.

Inclusive

Foster transparent partnerships and products that promote competition, consumer protection, regulatory compliance, financial inclusion and equity.

Constructive

Embrace industry best practice, appropriate government regulation and robust standards; Engage in pragmatic collaboration to educate, shape public opinion and drive results.

Advocacy

Discover how we are driving sound public policymaking for responsible innovation.

Advocacy

Membership standards

AFC Members provide access to responsible financial products. To ensure trust and integrity, membership is only open to U.S. operating companies that adhere to our outlined criteria.

Standards for Lenders

  1. Financial services products must not be characterized as something otherwise to avoid regulation.

  2. Members may not offer “payday” or “high-cost installment loans” as defined by the CFPB.

  3. Small business financing must adhere to the responsible lending standards of the Small Business Borrowers' Bill of Rights.

  4. Members advance standards of fairness and nondiscrimination.

  5. Have 1 year of operating history.

Standards for Buy Now Pay Later (BNPL) Companies

  1. It’s deemed a loan, so consumers receive TILA disclosures clearly stating APR.

  2. It’s underwritten and ability to repay ascertained.

  3. If late fees are applied, they are fully disclosed and do not exceed 36% APR.

  4. The business pledges to work with credit bureaus to avoid harming consumer credit scores and improve reporting, since BNPL can appear as multiple trade lines.

Standards for Earned Wage Access (EWA)

  1. EWA is not a loan or credit product: Unlike loan products, earned wage access (EWA) services do not: (1) perform credit checks/inquiries, (3) assess fees or base access on creditworthiness, (3) charge a fee in installments, (4) charge interest, (5) charge late fees, (6)  report to credit bureaus, and (7) conduct collection activity of any kind on past due balances.

  2. Companies must agree to register and/ or obtain appropriate licenses: (1) integrates with businesses (employer-integrated) and (2) direct to the consumer to provide access to earned wages (direct-to-consumer) as appropriate based on product offering.

  3. A “No Cost” option must be offered to all EWA users.

  4. Commit to data sharing with appropriate state and federal regulatory authorities including describing updated or new features of products and services being offered.

  5. Conduct due diligence on payroll information using reliable data sources.

  6. Amount of each transaction cannot exceed the employee’s earned wages at the time of the withdrawal.

  7. Strong fee disclosures, represented in a clear and transparent manner, not to be hidden in any way.

  8. For providers that charge tips, strong tip disclosures in close proximity to point of decision, including: (1) a tip may be zero, (2) a tip is voluntary, (3) that there is no special treatment for users regardless of who tips and who does not, (4) that access to EWA, or frequency of access is not contingent on a tip or its size, (5) an explicit ban against misleading or deceiving users about the voluntary nature of tips, and (6) a requirement to explicitly state that tips do not benefit any specific, individual person.

  9. Develop and implement policies and procedures to respond to inquiries raised by consumers and address complaints from consumers in an expedient manner.

  10. Ability for users to cancel their EWA services at any time.

  11. For providers that debit bank accounts, reimburse overdraft fees: EWA providers must take full responsibility and reimburse any overdraft fees they cause by attempting to debit on the wrong date or incorrect amount.

  1. Financial services products must not be characterized as something otherwise to avoid regulation.

  2. Members may not offer “payday” or “high-cost installment loans” as defined by the CFPB.

  3. Small business financing must adhere to the responsible lending standards of the Small Business Borrowers' Bill of Rights.

  4. Members advance standards of fairness and nondiscrimination.

  5. Have 1 year of operating history.

Standards for Buy Now Pay Later (BNPL) Companies

  1. It’s deemed a loan, so consumers receive TILA disclosures clearly stating APR.

  2. It’s underwritten and ability to repay ascertained.

  3. If late fees are applied, they are fully disclosed and do not exceed 36% APR.

  4. The business pledges to work with credit bureaus to avoid harming consumer credit scores and improve reporting, since BNPL can appear as multiple trade lines.

Standards for Earned Wage Access (EWA)

  1. EWA is not a loan or credit product: Unlike loan products, earned wage access (EWA) services do not: (1) perform credit checks/inquiries, (3) assess fees or base access on creditworthiness, (3) charge a fee in installments, (4) charge interest, (5) charge late fees, (6)  report to credit bureaus, and (7) conduct collection activity of any kind on past due balances.

  2. Companies must agree to register and/ or obtain appropriate licenses: (1) integrates with businesses (employer-integrated) and (2) direct to the consumer to provide access to earned wages (direct-to-consumer) as appropriate based on product offering.

  3. A “No Cost” option must be offered to all EWA users.

  4. Commit to data sharing with appropriate state and federal regulatory authorities including describing updated or new features of products and services being offered.

  5. Conduct due diligence on payroll information using reliable data sources.

  6. Amount of each transaction cannot exceed the employee’s earned wages at the time of the withdrawal.

  7. Strong fee disclosures, represented in a clear and transparent manner, not to be hidden in any way.

  8. For providers that charge tips, strong tip disclosures in close proximity to point of decision, including: (1) a tip may be zero, (2) a tip is voluntary, (3) that there is no special treatment for users regardless of who tips and who does not, (4) that access to EWA, or frequency of access is not contingent on a tip or its size, (5) an explicit ban against misleading or deceiving users about the voluntary nature of tips, and (6) a requirement to explicitly state that tips do not benefit any specific, individual person.

  9. Develop and implement policies and procedures to respond to inquiries raised by consumers and address complaints from consumers in an expedient manner.

  10. Ability for users to cancel their EWA services at any time.

  11. For providers that debit bank accounts, reimburse overdraft fees: EWA providers must take full responsibility and reimburse any overdraft fees they cause by attempting to debit on the wrong date or incorrect amount.

Our membership

Our people and companies help AFC advance a more responsible, inclusive, customer-centric financial system.

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AACUC

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Above Lending

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Accion Opportunity Fund

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Affirm, Inc.

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Alloy Labs

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American Deposit Management

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Arnold & Porter

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Association of Military Banks of America

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Atlantic Federal Credit Union

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Augustana University

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Avant, LLC.

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Baselayer

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Best Egg

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Bloom Credit

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Bmgmoney

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Borrowers Bill of Rights

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Boston University

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Bradley

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Brigit

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CLYDE

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Cafe

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Candidly

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Capital Good Fund

Community Advisory Board

Carvertise

CAFE Cohort Program

Chapman

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Cleo

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Coastal Community Bank

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College Ave

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CompliSun

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Continental Finance

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Credit Builders Alliance

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Cross River Bank

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Customers Bank

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DR Bank

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Dailypay

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DataSeers

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Dave

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Davis Wright Tremaine

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EarnIn

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Earnest

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Emprise Bank

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Evolve Open Banking

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Experian

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FS Vector

Strategic Partners

Fairplay

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Federal Home Loan Bank of New York

Members

Financial Security Program

Community Advisory Board

Finmkt

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Five Star Bank

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Footprint

Members

Our leadership

Our leaders are driving change, expanding inclusivity and promoting financial health.

Phil Goldfeder

CEO

[email protected]

Becky O’Mara

Senior Vice President, Member Benefits & Chief Financial Officer

[email protected]

Ian P. Moloney

Senior Vice President, Head of Policy and Regulatory Affairs

[email protected]

Taylor McCarthy

VP, Head of Events

[email protected]

Colin Darke

Senior Advisor for Fintech Training and Educational Programing

[email protected]

Hayden Cole

Director, Government Affairs

[email protected]

Frank R. Borchert, III

Senior Advisor

[email protected]

Careers

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