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FIN Response to CFPB Payments Data Orders

October 21, 2021 – Today FIN responded to CFPB orders sent to specific FIN member companies. The following statement is attributed to Brian Peters, Executive Director, Financial Innovation Now.

“FIN member companies offer exceptional products that are helping solve Americans’ financial challenges. FIN member companies deeply value consumer protection and their best practices exceed U.S. law. Unlike others to be named in the orders, FIN member companies’ financial products are enjoyed by millions of Americans, and we have been working diligently with U.S. regulators for years to raise the consumer protection bar for all stakeholders in financial services. We will continue working with the Bureau to raise expectations across all providers of financial services and welcome continued engagement to show the value provided to Americans by FIN members.”

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FIN Urges Fed to Promote Competition in Card Payments Online

August 11, 2021 – Today Financial Innovation Now urged the Federal Reserve Board of Governors to adopt its proposed rule to promote competition in debit card routing networks online.

In a letter to the Board, FIN states, “Following the onset of the COVID-19 pandemic, card-not-present transactions have become an increasingly large portion of all debit card transactions.  Throughout the pandemic, FIN members have provided services that helped American businesses and their customers make and process transactions online and have observed how limited routing options for card-not-present transactions have reduced competition for online transactions.”

The Board recently proposed clarifying that debit card transactions must be able to be processed on at least to unaffiliated payment card networks, including ‘card-not-present’ transactions online.

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FIN to Fed: Don’t Raise Barriers to Payment Innovators

July 12, 2021 – Financial Innovation Now today urged the Federal Reserve to expand access to its payment systems to payment innovators with adequate regulatory oversight. The Federal Reserve runs various payment systems and only permits banks to access them.

FIN’s letter states, “At a time of significant technological change, we believe that innovative institutions can deliver new benefits to consumers, businesses and the broader U.S. economy—to include increased competition, greater financial inclusion and enhanced and innovative delivery of financial services.  FIN members therefore encourage the Board to ensure that the proposed guidelines, as well as any implementation of such guidelines, promote responsible innovation in the financial services industry and do not result in unduly limited Reserve Bank access for non-traditional charter types.”

A copy of FIN’s letter can be found at: https://financialinnovationnow.org/fin-comment-letter-re-federal-reserve-bank-access-final/

FIN Outlines Artificial Intelligence Principles for Federal Bank Regulators

July 1, 2021 – Today Financial Innovation Now submitted comments to federal banking regulators outlining principles for the use of artificial intelligence (AI) in financial services.

FIN states, “We believe that financial institutions can develop and implement best practices to maximize the benefits of AI while effectively mitigating the key risks associated with use of this new technology. Indeed, many financial institutions have already begun carefully implementing AI to enhance existing systems, with the potential for greater use of AI to increase efficiency, effectiveness and fairness.”

FIN’s comment letter is available at: https://downloads.regulations.gov/OCC-2020-0049-0064/attachment_1.pdf

FIN to Treasury: Re-open IRS Portal for Direct Deposit of Stimulus Checks

March 5th, 2021 – As Congress nears enactment of another round of stimulus payments, today Financial Innovation Now urged the Treasury Department to re-open the IRS portal for stimulus check recipients to sign up for direct deposit. This single change will help get money in the hands of people faster, more efficiently, and with greater accuracy.

A copy of FIN’s letter is below and available at the following link: http://financialinnovationnow.org/wp-content/uploads/2021/03/irs-portal-for-digital-eip.pdf

March 5th, 2021

The Honorable Janet Yellen
Secretary of the Department of Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Dear Secretary Yellen:

The Electronic Transaction Association (ETA) and Financial Innovation Now (FIN) congratulates you on your confirmation as Secretary. Thank you for your leadership as we continue to navigate through the multiple crises brought on by COVID-19. Our companies share in your commitment to provide much needed financial assistance to American households who are struggling through this pandemic.

Our member companies have been proud to process hundreds of millions of dollars in economic impact payments from the US Treasury to individuals over the course of the last twelve months. We look forward to playing a similar role in the next round that may be authorized by Congress.

Providing people with the option to receive their payments digitally through direct deposit capabilities is of the utmost importance to improve the accuracy, efficiency, security, and speed of getting the money in the hands of people who are entitled to it. We are writing today to encourage you to re-open the Treasury’s IRS portal for all recipients to update their information in your system. This would provide recipients the opportunity to choose to utilize the direct deposit feature to the account of their choice. Millions of Americans had to wait months for their checks or never received their payment. Reopening the IRS portal will dramatically cut back on the amount of paper checks that are mistakenly thrown away, misplaced, or received erroneously.

The second round of stimulus payments did not provide recipients with an option to change their method of receipt. If they received a paper check the first time, they did not have an option to receive it through another method of their choice (like direct deposit, prepaid accounts, or mobile wallets) the second time. This single change will help get money in the hands of people faster, more efficiently, and with greater accuracy.

We stand ready to assist in any way we can. We sincerely thank you and your staff for your ongoing work to help the nation beat the pandemic and recover.

Respectfully submitted,

Scott Talbott, Senior Vice President
Electronic Transactions Association
1650 L St NW
Washington, DC 20036

Brian Peters, Executive Director
Financial Innovation Now
1155 F Street NW
Washington, DC 20004

C.C.
The Honorable Charles P. Rettig, Commissioner of the Internal Revenue Service
Mark Mazur, Acting Assistant Secretary for Tax Policy, U.S. Treasury
David A. Lebryk, Fiscal Assistant Secretary, U.S. Treasury

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FIN Encourages CFPB to Empower Consumers with Technology and Data

February 4, 2021 – Today Financial Innovation Now urged the Consumer Financial Protection Bureau to move forward with a rulemaking to help preserve and expand consumer access to financial data.

“FIN applauds the CFPB’s efforts to develop regulations implementing Section 1033 to ensure that consumers can efficiently and safely . . . make smarter financial decisions and gain access to a broader range of consumer financial products and services,” states FIN’s letter to the Bureau.  “These benefits will only be fully realized if consumers are empowered to permit access to consumer financial account data securely and easily, without charges that favor any one application or technology over another.”

Consumers use many kinds of technologies, from web browsers to many different third party applications, to manage finances and find better deals. Unfortunately, some financial institutions have blocked such consumer access. Congress passed Section 1033 in the Dodd-Frank Act to remedy these barriers.

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FIN Condemns Capital Violence

January 11, 2021 – The following statement can be attributed to Brian Peters, Executive Director, Financial Innovation Now:

“FIN and its member companies strongly condemn the violence of January 6th at our nation’s capital.  We call on elected officials to honor and respect our democratic process and the rule of law, including the peaceful transition of power. FIN looks forward to working with policymakers who we can trust to uphold these values.”

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FIN Supports Legislation to Provide Automatic PPP Loan Forgiveness to Small Businesses

June 30, 2020 – U.S. Senators Kevin Cramer (R-ND), Bob Menendez (D-NJ), Thom Tillis (R-NC), and Kyrsten Sinema (D-AZ) today introduced legislation to automatically forgive loans made to small businesses under the Paycheck Protection Program. Financial Innovation Now supports this legislation.

The following statement can be attributed to Brian Peters, Executive Director, Financial Innovation Now:

“Financial Innovation Now commends Senators Cramer, Menendez, Tillis, and Sinema for introducing the Paycheck Protection Small Business Forgiveness Act. FIN member companies are proud to have facilitated thousands of PPP loans to truly small businesses that are suffering hardest during the Covid-19 pandemic. As these businesses struggle with unprecedented challenges, the last thing they need is more burdensome paperwork. The Paycheck Protection Small Business Forgiveness Act will enable America’s small businesses to concentrate on surviving. FIN urges Congress to pass this legislation as soon as possible.”

FIN member companies PayPal, Intuit, and Square are active lenders in the PPP program, collectively enabling thousands of truly small business to access PPP loans thus far.

The Paycheck Protection Small Business Forgiveness Act would provide automatic forgiveness for PPP loans below $150,000 via a one-page online form.

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FIN Commends OCC Rule Promoting National Credit Access

May 29, 2020 – The Office of the Comptroller of the Currency today issued a rule to restore consistent, nationwide access to credit. The rule will help ensure regulatory clarity for loans made available nationally via financial technology companies in partnership with banks.

The following statement can be attributed to Brian Peters, Executive Director, Financial Innovation Now:

“The Comptroller’s rule will restore consistent access to credit in the United States, and FIN commends the agency for addressing regulatory uncertainty. Today the OCC is bringing smart leadership to the intersection of financial services and technology, a helpful step for consumers and small businesses across America, particularly given the acceleration of online access to financial services during the challenging Covid-19 pandemic. We look forward to our ongoing work with the OCC to promote innovation in lending, payments, and financial access.”

FIN has advocated for this regulatory clarity on Capitol Hill and at federal financial regulators for the past four years. The FDIC is also considering issuing a similar rule.

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FIN Calls on Congress to Help Small Businesses ASAP – Use Speedy Alternative Lenders to Distribute Stimulus Loans

March 19, 2020 – In response to the COVID-19 economic crisis, Financial Innovation Now today called on Congress to help small businesses immediately by using alternative lenders to help distribute loans digitally. FIN is concerned that many small businesses will run out of working capital in less than three weeks. Small businesses are not well served by traditional financial institutions, nor will existing federal small business loan programs deliver funds soon enough.

FIN’s letter is below and linked here: http://financialinnovationnow.org/wp-content/uploads/2020/03/fin-coronavirus-alternative-lender-stimulus-letter-final.pdf

March 19, 2020

Dear Speaker Pelosi, Leader McConnell, Leader McCarthy and Leader Schumer,

Thank you for your bipartisan work to keep Americans safe from COVID-19 and mitigate this unprecedented economic crisis. The member companies of Financial Innovation Now (FIN) are committed to working with lawmakers to help ensure that economic stimulus measures are effective and expeditious, particularly for small businesses.

FIN strongly supports Treasury’s proposal to create a small business loan interruption program. However, millions of truly small businesses, those most likely to fail in the coming weeks, will not be well-served by loan guarantees made available exclusively through financial institutions. Small businesses need capital immediately. Small businesses are shut down, business owners are isolated in their homes, and many physical bank branches are closed. Any federal small business loan program must leverage digital advances in the marketplace to ensure that stimulus can reach those business most in need.

Alternative online lenders, such as Square, PayPal, Stripe, Intuit and many others, have pioneered fast and accessible working capital programs that have served tens of millions of small businesses. FIN companies alone have made over $10 billion available in the past several years. Alternative online lenders have the reach, relationships, and digital capabilities to reach those businesses most vulnerable – right now.

To ensure the success of the proposed small business loan interruption program, FIN urges Congress to direct Treasury to 1) provide conditional capital to alternative online lenders; 2) permit these non-bank lenders to disburse loans, including via partnership with financial institutions; and 3) allocate a portion of funds for distribution via these lenders.

An emergency Treasury facility will get funding to small businesses in a timely manner. FIN welcomes Congressional efforts to dramatically streamline Small Business Administration loans and include alternative lenders in this process as well.

Collectively, FIN member companies alone have a direct deposit and underwriting capability with over 20 million small business. FIN estimates that our companies could rapidly disburse approximately $100 billion in capital to vulnerable small businesses, in many cases within weeks. Through payment processing data and other technologies,[2] these alternative online lenders have direct visibility into real-time hardship of a small businesses and they have the credit models and the digital infrastructure to move money rapidly.

FIN deeply appreciates the work of you and your staff during a remarkably challenging moment in our nation’s history. FIN member companies look forward to our continued partnership and mutual efforts meet the challenges of this pandemic.

Respectfully,
Brian Peters
Executive Director
Financial Innovation Now

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