AFC calls on joint agencies to preserve flexibility and modernize the strategic plan process to better serve low- and moderate-income communities

Washington, D.C. (August 21, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, today submitted a letter to the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency urging the agencies to retain and improve the flexibility afforded to banks under the Community Reinvestment Act’s (CRA) strategic plan framework.

AFC commended the joint proposal to rescind the CRA regulations that went into effect on February 1, 2024 and replace them with the March 29, 2024 framework. They stressed that strategic plans are critical for innovative banks, particularly those operating through bank–fintech partnerships, to meet their CRA obligations in ways that reflect their unique business models and better serve low- and moderate-income communities nationwide.

"Strategic plans are a proven pathway for innovative banks to meet CRA goals while addressing community needs in ways that reflect modern financial services," said Phil Goldfeder, CEO of the American Fintech Council. "Rather than forcing branch-based metrics on online-focused institutions, regulators should preserve and enhance these tools to capture the full impact of responsible bank–fintech partnerships."

The letter also recommends that the Joint Agencies fully count consumer lending under strategic plans, particularly for institutions serving low- and moderate-income borrowers in both rural and urban communities. AFC urges regulators to ensure CRA credit for activities conducted through bank–fintech partnerships, adhere to and enforce defined timeframes for strategic plan approvals, and create a more transparent and collaborative review process that allows banks to request feedback at any stage.

"These practical changes would help regulators evaluate CRA compliance in ways that recognize diverse business models while streamlining the process for all parties," said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC. "By making the strategic plan process more efficient and inclusive, we can encourage responsible innovation that expands access to affordable, high-quality financial products."

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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