In response to request for feedback, AFC letter urges clearer enforcement standards, streamlined regulations, and durable frameworks for emerging financial products

Washington, D.C. (April 20, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to its Draft Strategic Plan for Fiscal Years 2026–2030. AFC thanked the CFPB for their work and outlined recommendations to support a regulatory framework that is transparent, consistent, and grounded in statutory authority, enabling responsible innovation that expands access and improves consumer financial outcomes.

“A thoughtful, risk-based regulatory approach is essential to protecting consumers while ensuring that responsible innovation can continue to expand access to safe and affordable financial services,” said Phil Goldfeder, CEO of the American Fintech Council. “The CFPB’s Strategic Plan presents an important opportunity to provide greater clarity, reinforce statutory boundaries, and focus regulatory resources on high-risk actors.”

AFC supports the CFPB’s focus on a targeted, risk-based approach to consumer protection and consistent enforcement based on measurable consumer harm. To strengthen this approach, AFC suggests the CFPB clarify key concepts while maintaining focus on high-risk actors like for-profit credit repair organizations. At the same time, oversight should not discourage new financial products, which should be assessed based on structure, transparency, and demonstrated outcomes.

Additionally, AFC recommends the CFPB pursue legislative rulemaking for the Earned Wage Access (EWA) industry to establish clear, durable, and nationally consistent standards.  The CFPB’s 2025 Advisory Opinion clarified that EWA is not a loan, but noted that a formal rulemaking is still necessary to provide long-term certainty and ensure consistent consumer safeguards.

“A consistent regulatory framework grounded in clear statutory authority is critical to maintaining fair, competitive, and innovative financial markets,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “Providing regulatory clarity, particularly for emerging products like Earned Wage Access, will ensure that responsible providers can continue to meet consumer demand while operating within well-defined rules.”

The letter encourages the CFPB to reduce unnecessary regulatory burdens by advancing proportionate, risk-based measures to remove duplicative or outdated requirements. AFC also emphasizes the importance of modernizing regulatory infrastructure and strengthening technology-enabled supervision. Investments in data systems and advanced compliance tools can improve risk identification, enhance supervisory efficiency, and support more timely and targeted enforcement.

Finally, AFC supports the plan’s focus on strengthening consumer financial education to help individuals make more informed financial decisions. AFC has long supported efforts to strengthen financial literacy, including initiatives like a practical financial education program in New York focused on credit, savings, and core planning skills, reflecting the need for clear consumer understanding as financial products and payment tools continue to evolve.

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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