In response to OCC Request for Information (RFI), AFC letter emphasizes flexibility for innovative banks and greater procedural clarity in CRA goal-setting

Washington, D.C. (February 23, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its Request for Information on a proposed simplified strategic plan process under the Community Reinvestment Act (CRA) for community banks. In its letter, AFC underscores the importance of maintaining flexibility, clarity, and accessibility within the strategic plan option, particularly for innovative banks that serve low and moderate-income communities through digital channels and responsible bank-fintech partnerships.

The OCC’s proposal would establish a standardized, simplified strategic plan framework for community banks seeking to meet their CRA obligations outside of traditional examination methods. The plan introduces clearer measurable goal-setting, a streamlined submission process, and more predictable review timelines to reduce administrative burdens while maintaining accountability and public transparency under the CRA.

“A modernized and simplified strategic plan process can ensure that community banks, including those operating with innovative and non-traditional business models, have a workable pathway to meet their CRA obligations,” said Phil Goldfeder, CEO of the American Fintech Council. “The goal should be to reduce unnecessary procedural burden while preserving the flexibility that allows banks to serve underserved communities wherever they are.”

AFC details that many innovative banks rely on the strategic plan option because traditional CRA assessments are often tied to physical branch locations and may not fully capture lending and services delivered nationwide through partnership-based and digital models. As a result, banks extending credit beyond their designated assessment areas may not receive appropriate recognition under conventional evaluation methods. AFC urges the OCC to promote flexibility in the strategic plan process by clarifying that measurable goals may account for lending and services delivered through responsible bank-fintech partnerships, confirming that strategic plans can include activities benefiting low and moderate-income communities beyond a bank’s footprint, and by providing practical examples of custom goals reflecting modern delivery channels and community development strategies. AFC also encourages the OCC to provide guidance on when a strategic plan is the appropriate framework for deposit-focused institutions and to clarify that measurable goals may include metrics related to deposit product accessibility for low- and moderate-income communities.

“Greater clarity and predictability in the strategic plan development and review process will help community banks focus on delivering meaningful community reinvestment outcomes rather than navigating procedural uncertainty,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “The OCC has an opportunity to modernize this framework in a way that promotes responsible innovation while maintaining strong safeguards and transparency.”

AFC also recommends clearer guidance on review stages, including expectations for complete submissions, interim feedback, and transparent timelines, while maintaining safeguards for public participation, confidential information, and plan amendments to preserve meaningful CRA accountability.

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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