Inclusive Digital Financial Services Act

Presented By Enrique Sanchez

This Movement Is Currently
In The Amicus Brief Writing Stage.

BRIDGING THE DIGITAL FINANCIAL DIVIDE

As financial services rapidly migrate online, millions of Americans face exclusion from essential banking services and economic opportunity:

• 7.1 million U.S. households completely unbanked
• 20% of Americans “underbanked” despite having accounts
• Bank branches closed at record rates, declining 14% since 2008
• Rural and low-income urban areas disproportionately affected by branch closures
• 42 million Americans lack broadband internet access
• Smartphone-dependent internet users face data limitations and device constraints
• Digital-only banks often exclude customers without strong digital literacy
• Algorithmic bias reproduces historical discrimination patterns
• Limited English proficiency creates barriers to digital service navigation
• Older Americans and people with disabilities face accessibility challenges

Without thoughtful policy intervention, the digital transformation of financial services risks deepening rather than reducing financial exclusion.

OUR INCLUSIVE DIGITAL FINANCE FRAMEWORK

Our proposed legislation would establish:

1. UNIVERSAL ACCESS REQUIREMENTS

• Basic account standards ensuring availability regardless of income
• Mobile-friendly design requirements for essential banking functions
• Low-bandwidth service options for limited connectivity areas
• Offline functionality for transaction-critical applications
• Alternative authentication methods beyond credit histories
• Language access requirements for major language groups
• Specific accessibility standards for disabled users
• Low-cost data access through sponsored connectivity
• Clear disclosure of all fees and requirements
• Reasonable identification requirements preventing exclusion

2. CONSUMER PROTECTION STANDARDS

• Clear fee disclosure requirements preventing hidden charges
• Fraud protection and liability limitation standards
• Dispute resolution procedures with defined timelines
• Data breach notification and mitigation requirements
• Service interruption standards preventing fund inaccessibility
• Prohibition of discriminatory algorithms in financial decisions
• Account closure notice requirements preventing sudden exclusion
• Emergency access provisions during technical failures
• Clear error correction procedures
• Cooling-off periods for new financial products

3. PRIVACY & DATA RIGHTS FRAMEWORKS

• Opt-in requirements for data sharing beyond service provision
• Clear consent mechanisms for information usage
• Customer ownership of personal financial data
• Data portability enabling account switching
• Purpose limitation requirements preventing mission creep
• Deletion rights for inactive accounts
• Access rights to personal information collected
• Algorithmic transparency requirements for credit decisions
• Reasonable security standards protecting information
• Limitations on location tracking and behavioral profiling

4. FINANCIAL CAPABILITY DEVELOPMENT

• Digital financial literacy programs targeting underserved communities
• Multilingual educational resources explaining digital financial services
• Demonstration tools allowing practice in safe environments
• Simplified interfaces for essential banking functions
• Guided assistance for complex transactions
• Peer support networks building comfort with digital tools
• School-based education on digital financial management
• Clear terminology requirements reducing confusion
• Progressive disclosure methods preventing information overload
• Feedback mechanisms ensuring continuous improvement

5. REGULATORY MODERNIZATION & COORDINATION

• Technology-neutral regulations focusing on outcomes
• Regulatory sandbox programs for inclusive innovation
• Streamlined compliance for low-risk financial products
• Federal-state coordination preventing fragmentation
• Community Reinvestment Act modernization for digital services
• Data collection on digital financial inclusion
• Regular assessment of market practices and exclusion patterns
• Cross-agency working group coordinating oversight
• Civil rights compliance frameworks for algorithmic systems
• Regular stakeholder engagement ensuring diverse perspectives

IMPLEMENTATION STRATEGY

The legislation would establish an Office of Inclusive Digital Finance within the Consumer Financial Protection Bureau with $100 million in annual funding. Implementation would prioritize:

• Communities most affected by bank branch closures
• Populations with lowest rates of financial inclusion
• Features addressing most common exclusion factors
• Public-private partnerships maximizing impact
• Customer experience testing with diverse users
• Regular assessment of effectiveness and barriers
• Continuous improvement based on market evolution
• Knowledge sharing accelerating adoption of best practices
• Stakeholder engagement throughout implementation
• Long-term metrics tracking progress toward universal inclusion

Our coalition includes consumer advocates, civil rights organizations, financial technology companies, community development financial institutions, disability rights groups, and financial education providers committed to ensuring digital financial services increase rather than limit financial inclusion.

Your support will help create the frameworks needed to ensure the digital transformation of finance serves all Americans—establishing standards, protections, and access requirements that make financial services available to everyone regardless of income, location, language, or digital access limitations.