Banks are Banks, Non Banks are Non Banks, Clarifies the American Fintech Council

The American Fintech Council (AFC) has issued a statement on the regulation of banks and non-banks. In a letter submitted to the FDIC, the CFPB, the FTC, the OCC, and the Federal Reserve, the group stated that “banks are banks, and non-banks are non-banks” and regulatory clarity must be maintained.

Phil Goldfeder, CEO of the AFC, said that not all Fintechs act in the same way as their members, which include both chartered banks and non-bank firms.

“As a standards-based trade association, it is incumbent upon us to continue advocating for all industry participants to adopt best practices. These clear distinctions bolster consumer trust and support continued responsible innovation,” said Goldfeder.

Ian P. Moloney, Chief Policy Officer at the AFC, added that accurate branding by non-banks maintains a level playing field.

While the letter does not explicitly name any firms that the AFC believes are crossing a regulatory line, it is likely that the letter was sent as digital asset firms seek to provide more bank-like services, competing with traditional banks and some Fintechs. At the same time, a good number of digital asset firms are seeking bank charters (or have already received approval) to offer banking services as lines blur, and digital finance takes over.



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Disclosure Quest

Reg A - Form 1-A Filings Beta

Beta. Initial Form 1-A only. Target raise is the stated Amount to be Raised, totaled. Compared with the same dates one year earlier.

YTD: Jan 1, 2026 - Nov 4, 2026 vs Jan 1, 2025 - Nov 4, 2025

Share this graph
Number of Filings134Prior 129 +3.9%
Target Raise, Total$3.45BPrior $3.59B -3.8%
This YTDYear priorChange
Filings 134 129 +3.9%
Target raise $3.45B $3.59B -3.8%

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Source: DisclosureQuest. Initial Form 1-A only.

Created by Crowded Media Group

This display counts initial Form 1-A filings only. It does not represent subsequent filings, including Form 1-A/A amendments or Form 1-A POS post-qualification updates filed by the issuer. Amounts are the stated Amount to be Raised on the initial filing, not capital raised and not amounts revised in later filings.

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