Letter to federal financial regulators emphasizes the importance of market participants ensuring consumer clarity in responsible bank-fintech partnerships

Washington, D.C. (January 7, 2026) – The American Fintech Council (AFC), the premier industry association representing both responsible fintech companies and innovative banks, submitted a letter to federal financial regulators underscoring the importance of maintaining clear distinctions between chartered, insured depository institutions and non-bank fintech companies.

“At a time when the line between banking and commerce is increasingly blurred, we must reinforce a simple, foundational principle: banks are banks, and non-banks are non-banks. AFC members have consistently sought to ensure consumers understand the distinct roles of the fintech companies and banks with whom they partner, but not all fintech companies act in the same manner as our members” said Phil Goldfeder, CEO of the American Fintech Council. “As a standards-based trade association, it is incumbent upon us to continue advocating for all industry participants to adopt best practices. These clear distinctions bolster consumer trust and support continued responsible innovation.”

The letter emphasizes that well-structured and responsible bank-fintech partnerships have expanded access to financial services, particularly for historically underserved communities, while preserving safety and soundness through clear accountability. AFC notes that chartered, insured depository institutions must remain clearly identified as the bank in any partnership, with ultimate responsibility for compliance, while non-bank fintech companies accurately describe their roles as technology providers, servicers, or distributors subject to their own regulatory obligations.

“Responsible banks and fintech companies within AFC membership exemplify best practices,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “Ensuring accurate disclosures and preventing bank-like branding by non-banks without a charter preserves the integrity of deposit insurance and maintains a level playing field to encourage competition across the financial services sector. This ensures that consumers understand who they are engaging with throughout a given transaction.”

AFC reiterates its commitment to working with regulators to promote transparent disclosures, robust risk management, and responsible bank-fintech partnerships that both expand access to financial services and protect consumers.

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC’s 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.

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