AFC calls for secure data sharing, federal preemption of conflicting state laws, and adoption of innovative technologies to safeguard consumers

Washington, DC (September 18, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, today submitted a comment letter in response to the Request for Information on Potential Actions to Address Payments Fraud issued jointly by the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC). AFC emphasized the need for a coordinated, data-driven strategy that leverages responsible innovation to ensure consumers are safeguarded from increasingly sophisticated fraud schemes.

“Payments fraud is one of the fastest-growing threats to consumers and the financial system right now,” said Phil Goldfeder, CEO of the American Fintech Council. “Through this process, federal regulators have an opportunity to build on existing industry efforts, promote responsible innovation, and develop a coordinated framework that both protects consumers and strengthens the integrity of our financial system.”

AFC urged the Joint Agencies to establish a program that enables secure, real-time sharing of potential payments fraud data across the industry, while providing analysis and feedback to improve fraud prevention practices. The letter also called on regulators to affirm that federal rules preempt conflicting state privacy laws, so institutions can use data for fraud detection without legal uncertainty. Finally, AFC encouraged support for innovative tools — such as advanced analytics, artificial intelligence, and behavioral monitoring — to spot fraud in real time, and recommended training examiners to effectively evaluate these technologies.

“Fraudsters are increasingly turning to new technologies, from generative AI to advanced bots, to evade fraud prevention efforts,” said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at the American Fintech Council. “Simply put, payments fraud thrives on exploiting regulatory and market gaps. To counter these efforts, prudential regulators must adopt a comprehensive, unified approach that facilitates secure data sharing and analysis throughout the financial services ecosystem, closes regulatory gaps, and ensures regulators are equipped to evaluate and use modern fraud prevention tools both in the market and at the agencies.”

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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