In response to Request For Information (RFI), AFC letter calls for payments-only design, robust safeguards, and optionality needed to encourage responsible innovation

Washington, D.C. (February 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 Federal Reserve in response to its Request for Information on the proposed Reserve Bank Payment Account prototype. The letter outlines AFC’s support for a narrowly tailored, payments-only account structure that reduces structural barriers to payment system access while preserving longstanding prudential and systemic safeguards.

“Access to core payment infrastructure should reflect how the modern financial system actually works,” said Phil Goldfeder, CEO of the American Fintech Council. “A well-designed Payment Account can expand competition and responsible innovation in payments without introducing new risk or undermining the Federal Reserve’s longstanding prudential safeguards.”

In the letter, AFC explains that there is a need for the Federal Reserve to address frictions in Master Account access by enabling optionality through the pursuit of its special purpose Reserve Bank account prototype, while ensuring that eligible institutions operate in a safe and sound manner. AFC argues that a narrowly scoped Payment Account can address these challenges and help encourage innovation in the payments space.

“Regulatory clarity and proportionality are essential as payments business models continue to evolve,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “As the payments system has evolved significantly over the past two decades, it has become increasingly clear that there is a need to reconsider how eligible institutions are able to access the payments system. AFC recognizes the importance of ensuring Fed Master Account access that remains commensurate with the activities and risk profiles of account holders by offering the special purpose Reserve Bank account prototype discussed in the RFI.”

The letter also discusses the importance of ensuring that the Federal Reserve preserves optionality in full or limited Master Account access for eligible institutions based on their business activities. Specifically, AFC urges the Federal Reserve to preserve flexibility so legally eligible institutions are not locked into a single access option as their business models, technologies, or customer needs evolve over time.

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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