Letter highlights importance of account portability, interoperability, and flexible contribution mechanisms to expand financial access

Washington, D.C. (April 9, 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) on the Notice of Proposed Rulemaking for the Trump Accounts Contribution Pilot Program. AFC calls for a flexible, interoperable savings framework designed to expand access, protect consumer choice, and promote long-term financial stability.

“A thoughtfully designed pilot program can make it easier for Americans to build long-term financial security,” said Phil Goldfeder, CEO of the American Fintech Council. “By emphasizing portability, integration with existing financial systems, and flexible contribution options, this program can help more Americans save effectively while maintaining control over their accounts.”

In its letter, AFC emphasizes the importance of designing the program to maximize accessibility and account portability. Without streamlined eligibility, digital-first enrollment, and flexible contribution options, participation could be limited, particularly for communities that stand to benefit most from structured savings opportunities. The letter also highlights the need for interoperable infrastructure, flexible custodial arrangements, and standardized, real-time transfer protocols to ensure account continuity across platforms, preserve consumer choice, and support efficient, scalable program implementation.

“Incorporating portability and interoperability is critical to creating a program that works for both consumers and providers,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “A flexible, well-structured pilot program will generate valuable insights to guide future design and support the development of a scalable, sustainable framework for long-term financial security.”

Additionally, AFC underscores the need for clear, transparent, and sustainable fee and investment frameworks to protect consumers and support provider participation. The letter calls for well-defined distinctions between investment and administrative fees, transparent disclosures, and investment options that reflect modern market practices, including low-cost ETFs and index-based products. Standardized, scalable structures would promote interoperability, reduce friction in account transfers, and ensure the program operates efficiently while safeguarding participant contributions.

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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