Letter to IRS emphasizes the need for uniform standards, regulatory clarity, and technological interoperability to expand savings access

Washington, D.C. (May 11, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a comment letter to the Internal Revenue Service (IRS) in response to the Notice of Proposed Rulemaking regarding the Trump Accounts Contribution Pilot Program. In the letter, AFC emphasizes that a durable framework for Trump Accounts requires a precisely defined regulatory architecture that is consistent across market participants and operates within modern financial infrastructure without creating unnecessary friction.

“AFC supports efforts to expand access to savings and promote long-term asset growth through clear, administrable, and platform-agnostic frameworks,” said Phil Goldfeder, CEO of the American Fintech Council. “The viability of Trump Accounts depends on a fiscal and compliance architecture that ensures clarity and consistency across the account lifecycle. By relying on familiar compliance channels and establishing uniform standards, the IRS can reduce administrative burdens while still preserving appropriate oversight and protecting consumers.”  

In its letter, AFC calls for a clearly defined statutory and regulatory framework that ensures consistent eligibility, contribution, and account standards. AFC stresses that the framework should provide explicit guidance regarding the treatment of contributions, earnings, and distributions, and should align reporting obligations with existing IRA compliance regimes to ensure tax and compliance clarity.

“Achieving the program’s objectives of expanding access to savings and promoting long-term financial security requires a stable and predictable regulatory structure,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “A national Trump Accounts program must establish clear, durable standards capable of consistent application over time. AFC and its members stand ready to engage further with the IRS and the Department of the Treasury to support a framework that advances these goals while preserving innovation and competition.”

Beyond administrative standards, AFC advocates for a standardized consumer protection and disclosure framework that ensures transparency and consistent treatment across all providers, regardless of the delivery channel. To ensure the program remains future-proof, AFC recommends a technology-agnostic approach that accommodates modern financial services delivery models, allowing for interoperability and portability across providers through standardized transfer protocols.

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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