Letter to the Fed supports proposed amendments to Regulation J that will enhance competition, improve settlement efficiency, and reduce frictions for cross-border payments

Washington, DC (June 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 Board of Governors of the Federal Reserve System expressing support for proposed amendments to Regulation J governing the FedNow Service. The letter commends the Federal Reserve’s efforts to establish a more flexible and operationally efficient framework by permitting FedNow participants to utilize intermediary institutions and cross-border payment flows.

“Modernizing our payment systems to be faster, resilient, and globally interconnected is critical to giving consumers and businesses access to the best financial tools available,” said Phil Goldfeder, CEO of the American Fintech Council. “The Federal Reserve’s proposal to integrate intermediary banking relationships into FedNow is a meaningful and constructive step that recognizes the operational realities of modern payments while preserving the foundational speed and certainty of domestic instant settlement.”

AFC emphasizes that interoperability is a defining feature of modern payment infrastructure. By aligning FedNow more closely with the longstanding operational structure of the Fedwire Funds Service, the proposed rulemaking will mitigate the historical inefficiencies of fragmented payment chains, inconsistent messaging standards, and operational delays. This change will allow financial institutions to leverage existing correspondent banking arrangements and liquidity management frameworks to transact more seamlessly across differing platforms and jurisdictions.

AFC also underscores the importance of maintaining a risk-based and operationally consistent supervisory framework. AFC highlights that relying on intermediary banks within FedNow does not increase risks in correspondent banking, as institutions already operate under robust Bank Secrecy Act and sanctions compliance obligations. AFC strongly supports the Federal Reserve’s focus on preserving Regulation J’s immediate funds availability requirements for domestic beneficiary banks participating in FedNow transactions, while encouraging further guidance on cross-border transaction timing, exceptions, and messaging standards.

“Clear, risk-based frameworks are essential to ensuring the integrity of our financial system while fostering responsible innovation,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “By providing operational consistency and regulatory clarity, the Federal Reserve can encourage broader participation in the FedNow Service and strengthen the ability of U.S. financial institutions to compete effectively in an evolving global payments ecosystem.”

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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