Letter in response to agency RFI encourages OCC to support innovation through collaborative fintech partnerships and pragmatic oversight

Washington, D.C. (July 2, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, has submitted a comment letter in response to the Office of the Comptroller of the Currency’s (OCC) recent Request for Information (RFI) on community bank digitalization. The letter urges OCC to adopt a forward-looking regulatory approach that supports responsible innovation and enables community banks to compete in an evolving financial ecosystem.

“As we navigate a rapidly changing financial services landscape, community banks must have the tools, flexibility, and regulatory clarity to embrace responsible digital modernization,” said Phil Goldfeder, CEO of the American Fintech Council. “OCC’s continued engagement on this issue is a meaningful step forward. We look forward to working with the agency to ensure regulatory modernization and examiner education so that smaller institutions can continue serving their communities through innovative, accessible, and secure financial products.”

AFC highlighted the importance of fostering bank-fintech partnerships that deliver digital-first services to underserved communities and small businesses. The letter also emphasizes the need for clear, consistent oversight that enables community banks to modernize their offerings without facing disproportionate compliance burdens. AFC commends OCC for its focus on community bank digital transformation and encourages the agency to recognize the value of technology partnerships as part of its broader mission to ensure fair access, consumer protection, and financial stability.

“The future of community banking depends on access to responsible innovation,” said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC. “By supporting well-structured bank-fintech partnerships and providing consistent oversight, OCC can ensure that local financial institutions are empowered to evolve and compete in a digital economy.”

The letter also encourages OCC to provide guidance that promotes consistent examiner training and transparency while avoiding one-size-fits-all approaches that could inadvertently stifle innovation at smaller institutions.

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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