Our Mission
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.
Discover how the American Fintech Council is driving positive change within the financial industry through our three-fold approach:
We advocate for sound public policy that encourages responsible innovation and regulatory clarity, to ensure our members can offer fair and inclusive financial products.
Our extensive network allows us to foster meaningful collaborations between our members and across the broader fintech ecosystem.
We empower policy makers, regulators and all relevant stakeholders with the knowledge and resources to drive responsible policy.
AFC differentiates itself from other trade organizations through its focus on the following standards and core principles:
Utilize technology and data to create safe and accessible financial services to reach underserved and underbanked communities.
Offer only affordable, transparent, responsible products that help families build financial health; Align our business success with the success of our customers.
Foster transparent partnerships and products that promote competition, consumer protection, regulatory compliance, financial inclusion and equity.
Embrace industry best practice, appropriate government regulation and robust standards; Engage in pragmatic collaboration to educate, shape public opinion and drive results.
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.
Financial services products must not be characterized as something otherwise to avoid regulation.
Members may not offer “payday” or “high-cost installment loans” as defined by the CFPB.
Small business financing must adhere to the responsible lending standards of the Small Business Borrowers' Bill of Rights.
Members advance standards of fairness and nondiscrimination.
Have 1 year of operating history.
It’s deemed a loan, so consumers receive TILA disclosures clearly stating APR.
It’s underwritten and ability to repay ascertained.
If late fees are applied, they are fully disclosed and do not exceed 36% APR.
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.
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.
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.
A “No Cost” option must be offered to all EWA users.
Commit to data sharing with appropriate state and federal regulatory authorities including describing updated or new features of products and services being offered.
Conduct due diligence on payroll information using reliable data sources.
Amount of each transaction cannot exceed the employee’s earned wages at the time of the withdrawal.
Strong fee disclosures, represented in a clear and transparent manner, not to be hidden in any way.
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.
Develop and implement policies and procedures to respond to inquiries raised by consumers and address complaints from consumers in an expedient manner.
Ability for users to cancel their EWA services at any time.
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.
Financial services products must not be characterized as something otherwise to avoid regulation.
Members may not offer “payday” or “high-cost installment loans” as defined by the CFPB.
Small business financing must adhere to the responsible lending standards of the Small Business Borrowers' Bill of Rights.
Members advance standards of fairness and nondiscrimination.
Have 1 year of operating history.
It’s deemed a loan, so consumers receive TILA disclosures clearly stating APR.
It’s underwritten and ability to repay ascertained.
If late fees are applied, they are fully disclosed and do not exceed 36% APR.
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.
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.
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.
A “No Cost” option must be offered to all EWA users.
Commit to data sharing with appropriate state and federal regulatory authorities including describing updated or new features of products and services being offered.
Conduct due diligence on payroll information using reliable data sources.
Amount of each transaction cannot exceed the employee’s earned wages at the time of the withdrawal.
Strong fee disclosures, represented in a clear and transparent manner, not to be hidden in any way.
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.
Develop and implement policies and procedures to respond to inquiries raised by consumers and address complaints from consumers in an expedient manner.
Ability for users to cancel their EWA services at any time.
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.
Download the AFC Fact Sheet on EWA
Our people and companies help AFC advance a more responsible, inclusive, customer-centric financial system.
Our leaders are driving change, expanding inclusivity and promoting financial health.
CEO
[email protected]With nearly two decades of experience at the intersection of the public and private sectors, Phil Goldfeder currently serves as Chief Executive Officer of the American Fintech Council (AFC), a leading industry association representing responsible financial technology (fintech) companies creating critical access to safe and affordable financial services. AFC, comprised of the nation’s largest fintech companies, fosters innovative, transparent, and responsible products that promote competition, consumer protection, and financial health, inclusion, and equity. AFC is committed to robust industry standards, with a focus on consumer protection and regulatory compliance, in addition to advocating for and embracing appropriate government regulation.
Before joining AFC, Goldfeder served as Senior Vice President of Global Public Affairs at Cross River, a financial institution and technology infrastructure provider that offers embedded financial solutions. In this role, Goldfeder founded the Online Lending Policy Institute (OLPI) and has been a leader in shaping the new financial services landscape since early 2015. At the onset of the COVID-19 pandemic and the passage of the CARES Act in March 2020, Goldfeder helped lead the Cross River team to mobilize internally and offer a streamlined and automated system to provide more than $12 billion in PPP funding to the most vulnerable small businesses in every state, as well as additional short-term relief efforts to communities in the company’s footprint and beyond.
He previously served as an elected member of the New York State Assembly representing diverse neighborhoods of Queens, N.Y. After most of his district was devastated during Superstorm Sandy, Goldfeder lead recovery efforts with a specific focus on partnering with the banking and insurance industry to help rebuild his community and reform outdated policies. He was the author of transformative banking and insurance modernization legislation and was also a key legislative leader on a diverse array of issues. Prior to his election, he served as a senior advisor to Senate Majority Leader Chuck Schumer (D-NY) and New York City Mayor Michael Bloomberg.
Phil’s career in public service and expertise in leadership, crisis management, as well as his ability to enact positive change and develop deep relationships with diverse leaders on both the local and national levels, has put him at the forefront of innovation across banking and technology industries. He is an active industry leader as he engages policy makers and regulators, provides thought-leadership, and is frequently invited to speak on panels, roundtables, and conferences globally on banking, technology, financial literacy, and the new financial services landscape.
Senior Vice President, Member Benefits & Chief Financial Officer
[email protected]Becky O’Mara is Chief Financial Officer and Senior Vice President, Head of Member Benefits at the American Fintech Council (AFC). Prior to joining the AFC, Becky was a Senior Principal at Promontory Financial Group, where she provided regulatory and strategic consulting services for a variety of high-profile consumer finance clients and was a key member of the Compliance Practice Group. Prior to Promontory, she worked at Fenway Summer LLC in its advisory business, FS Advisory LLC, where she acted as engagement manager, producing tailored regulatory, financial, and market entrance analyses. Prior to consulting, Becky worked in Deutsche Bank’s Equity Capital Markets group, where she participated in the execution of 100+ equity and equity-linked offerings for Financial Institutions and Real Estate issuers, raising over $75 billion in equity for clients, including numerous TARP repayments by financial institutions for the U.S. Treasury.
Senior Vice President, Head of Policy and Regulatory Affairs
[email protected]Ian P. Moloney is Senior Vice President, Head of Policy and Regulatory Affairs for the American Fintech Council (AFC) leading the association’s policy strategy across the fintech ecosystem. Prior to AFC, Ian was Head of Policy and Regulatory Affairs at Cross River where he was responsible for leading the bank’s regulatory strategy, focusing on fintech and traditional banking regulations, and representing the bank as a regulatory expert to direct Cross River’s public policy objectives and positions to engage effectively with key federal and state regulators and policymakers. Ian was also previously with the U.S. Government Accountability Office (GAO) in Washington D.C. as a Senior Analyst of Financial Markets & Community Investment, where he worked on fintech, small business lending, and digital identity issues. He has been involved in the fintech space since 2017 and has published multiple reports on fintech topics, both domestically and internationally. Ian has written on fintech issues for the Federation of American Scientists, Cambridge Centre for Alternative Finance, and the United Nations.
Ian holds a Bachelor’s degree in Political Science, History, and Philosophy with an Ethics Minor from Central Michigan University. Ian also has an MBA from Johns Hopkins University.
VP, Head of Events
[email protected]Taylor McCarthy, CEM, CMP, is VP, Head of Events at the American Fintech Council (AFC). Prior to joining AFC, Taylor was the Director of Events at Cross River, where she led events strategy including the production of 350+ internal and external experiences. Prior to Cross River, she worked at the Biomedical Engineering Society (BMES), overseeing one annual conference and two regional meetings. Before BMES, Taylor managed program development, marketing, sales, and operations for the Healthcare portfolio of events at Access Intelligence, Inc. Taylor graduated from Elon University with a Bachelor’s degree in Sport & Event Management.
Senior Advisor for Fintech Training and Educational Programing
[email protected]With over 19 years of experience in the banking and fintech law sectors, I am the CEO of Colin Darke Solutions, a company that provides compliance solutions for fintech companies. I am also an attorney and advisor at GwC, a law firm that specializes in helping emerging companies and their investors (and I am in charge of their fintech focused practice). As part of my compliance work, I am currently the interim director of compliance at Scratch Financial, a fintech company that offers patient finance solutions for veterinary services. I am also a senior advisor at American Fintech Council, an industry association that advocates for responsible innovation and inclusion in fintech. I hold an LL.M. in Banking and Financial Law from Boston University School of Law, and I am admitted to practice law in Illinois, Michigan, and Massachusetts. My core competencies include consumer protection laws, fintech regulations, and complex financial transactional matters. I am passionate about creating and supporting fintech solutions that improve financial access and inclusion for underserved communities and markets. I am also an artist and illustrator, and I run a website called Colin Darke - The Ambidextrous Artist, where I showcase my artworks and share my creative process. I believe that my artistic background gives me a unique perspective and a competitive edge in the fintech industry, as I can combine creativity, innovation, and problem-solving skills to deliver effective and compliant solutions.
Director, Government Affairs
[email protected]Hayden Cole is Director of Government Affairs at the American Fintech Council (AFC). Prior to AFC, Hayden served as a public policy associate for Pathward (formerly MetaBank) where he assisted in advancing the company’s thought leadership with Congress, the Administration, and other national industry stakeholders through a comprehensive understanding of the legislative and regulatory process.
Prior to Pathward, Hayden worked on initiated ballot measures and for the City of Lincoln, Nebraska’s Commission on Human Rights. Hayden is a South Dakota native and holds a bachelor’s degree in political science from the University of Nebraska-Lincoln.
Senior Advisor
[email protected]Frank has extensive experience in the financial services industry from Fintech to traditional banking. In serving consumers and small businesses through innovation, he has advocated for strong, clear, and sensible regulation and promoted strong corporate governance. Most recently, he was Chief Administrative, Chief Legal Officer and Chief Risk Officer of Best Egg, Inc., a leading Fintech platform. Prior roles have included Chief Regulatory Counsel for the consumer businesses at JPMorgan Chase, General Counsel for Chase Card Services, and EVP & Deputy General Counsel at Capital One Financial Corp., where he was responsible for managing the Company’s legal and government relations teams. In addition, Frank served in the Administration of George W. Bush as Senior Advisor, Counselor to the Secretary of Housing and Urban Development and General Counsel at the Small Business Administration. He began his legal career in private legal practice at Cleary, Gottlieb.
Frank also has extensive experience working with industry trade associations to support balanced and successful legislative and regulatory policy, including serving as a founding Board member of the American Fintech Council (and its predecessor associations MLA and OLPI), a founding leader of the ABA’s Card Policy Council, a Board member of AFSA and other roles. He has also served as a Board member of several community non-profit organizations. He is currently President-Elect of the Board of Directors of ACC-Greater Philadelphia. He received a B.A. from Swarthmore College, a law degree from N.Y.U. School of Law, completed the Stanford Business School Executive Program ,and was a Fulbright Fellow in Tokyo, Japan at the University of Tokyo and the Japanese Ministry of Finance.
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