WASHINGTON, D.C. – The Financial Technology Association (FTA) responded to a request for comment from banking regulators on changes to the Community Reinvestment Act (CRA), a law designed to encourage financial institutions to serve all segments of their communities, including low and moderate-income neighborhoods. The Financial Technology Association is a Washington, DC-based trade association championing the transformative power of technology to improve financial services and advocating for modernized financial regulations and policies. 

“Financial technology puts preferred services in the hands of more people and plays an increasingly powerful role in reaching traditionally underserved communities,” said Penny Lee, Chief Executive Officer of the Financial Technology Association. “We applaud this effort to modernize the Community Reinvestment Act to account for the role of technology in breaking down barriers to financial services.” 

FTA’s comment letter examines ways financial technology helps reach underserved communities through bank partnerships or through digital-first banks. It urges regulators to place a high value on banking activities, often with fintech partners, that provide consumers with responsible and lower-cost alternatives to high-cost revolving credit, payday, and overdraft products. It also highlights the benefits of digital distribution channels in promoting financial access, inclusion, and opportunity. 

Specifically, the comment letter calls for CRA modernization to: 

  • Incentivize bank-fintech partnerships that expand access to low and moderate-income consumers: The combination of mobile and internet access with advanced, automated, and digital underwriting processes can fill gaps created by legacy models and approaches. A modernized CRA regime should focus on fostering banking models that incorporate such technologies, whether directly or through partnership, to promote fair and inclusive lending and financial services.
  • Explicitly recognize and address small, digital fintech banks: Large banks are not the only banking entities that will maintain robust mobile and online distribution channels, given the rise of fintech competition. The CRA should apply the same principles regarding large bank digital activities to benefit small and intermediate-sized bank entities. Regulators can use CRA modernization as an opportunity to encourage small and intermediate-sized banks to incorporate digital distribution channels and capabilities – including through partnerships with fintech. 
  • Incentivize credit programs that provide an alternative to high-cost payday products and overdraft fees: The short-term, small-dollar credit space remains one of the more significant challenges for low and moderate-income consumers, who often turn to high-cost, predatory products to meet short-term and emergency funding needs. FTA supports explicit recognition of banking activities, including partnerships with fintechs that offer consumers responsible, low-cost alternatives. 

Read FTA’s full comment letter here.


The FTA champions the transformative role of financial technology for American consumers, businesses, and the economy. Representing industry leaders, FTA elevates fintechs’ power to increase competition and drive financial innovation through responsible products and services. As our members’ voice in Washington, FTA advocates for the modernization of regulation to support greater access to financial services.