In response to OCC Request for Information (RFI), letter highlights structural barriers and the need for competition and regulatory clarity

Washington, D.C. (January 29, 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 community banks’ engagement with core and essential third-party service providers. In its letter, AFC outlines how market concentration, contractual lock-in, and limited optionality among core providers are restricting innovative community banks’ ability to compete and expand access to financial services, particularly in rural and underserved communities.

“Community banks play a critical role in the financial services industry, but too often their core service offerings are limited,” said Phil Goldfeder, CEO of the American Fintech Council. “Without optionality, responsible innovation slows, costs go up, and consumers don’t get the financial services access they deserve. Regulators should focus on encouraging competition and an open market that allows community banks to serve their customers.”

In the letter, AFC explains that consolidation among core banking service providers has given community banks fewer real choices for the technology that runs their institutions, placing these critical institutions at a disadvantage as they work to bring innovative products and services to their customers. Because switching providers is costly and disruptive, banks are often locked into long-term relationships even when pricing, service, or functionality no longer meets their needs. That lack of choice makes it harder for community banks to modernize, manage risk, and compete.

“The OCC has an opportunity to promote competition and encourage diversity of core provider offerings in the market while recognizing the practical challenges community banks face when upgrading critical technology,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “Both programmatic and cultural changes to how regulators understand and respond to innovative community banks’ core service needs, if done correctly, can result in a greatly expanded market, as well as improved banking options for consumers.”

AFC reiterated its commitment to working constructively with regulators to ensure community banks remain competitive, resilient, and well positioned to meet the needs of consumers and small businesses in an evolving financial services landscape.

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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