Why It Matters
Cross River Bank faces a fundamental challenge: safeguarding its Banking-as-a-Service partnerships as Congress weighs stringent consumer protections and fintech companies increasingly seek independent bank charters. The bank’s core business model depends on lending partnerships with fintech platforms, but a proposed 36% federal APR cap (S.2781) could disrupt high-cost lending products that generate significant revenue. Simultaneously, a record 13 fintech companies applied for bank charters in 2025, threatening Cross River’s competitive advantage. Recent regulatory wins—including federal elimination of "reputational risk" supervision—provide some relief, but the legislative threat justifies sustained advocacy efforts.
By the Numbers
Cross River Bank spent $90,000 on in-house lobbying in the third quarter totaling $450,000 across four 2025 filings. The bank’s lobbying team consists solely of Joseph Horvath, an in-house lobbyist who joined in January 2025.
Cross River complements its in-house efforts with 1607 Strategies LLC and Carmen Group Inc. for specialized banking and financial services matters. The bank’s focus remains consistent across 32 total lobbying filings: banking regulation, fintech partnerships, and Paycheck Protection Program issues.
The Agenda
Cross River’s Q3 2025 efforts focus on banking and financial institutions, fintech partnerships, and small business lending. The bank faces competing pressures: recent regulatory relief eliminating "reputational risk" supervision versus the existential threat of the Protecting Consumers from Unreasonable Credit Rates Act (S.2781), which would impose a nationwide 36% APR cap.
Secondary concerns include the SAFE Lending Act, which targets practices in online lending spaces where Cross River operates. The bank supports legislation benefiting community banking, including the Federal Home Loan Banks’ Mission Activities Act.
Recent congressional hearings on "Make Community Banking Great Again" highlight growing interest in reducing regulatory burden on smaller institutions—aligned with Cross River’s positioning.
Broader Context
Congress and federal regulators are reshaping financial services in ways directly affecting Cross River’s business model. Recent regulatory developments favor fintech partnerships: the OCC eliminated reputation risk-based supervision in March 2025, followed by the Federal Reserve in June.
However, significant legislative threats loom. The Protecting Consumers from Unreasonable Credit Rates Act (S.2781) would fundamentally reshape business models of Cross River’s lending partners.
The competitive landscape is shifting as 13 federal bank charter applications from fintech companies in 2025 reached a record high, threatening Cross River’s Banking-as-a-Service model as fintechs pursue independent charters.
Between The Lines
The most significant congressional challenge is S.2781’s proposed 36% APR cap, which would fundamentally disrupt lending partnerships forming Cross River’s core business.
Supportive congressional activity includes House Financial Services Committee hearings highlighting regulatory burdens on smaller institutions. Rep. Andy Barr (R-KY) and Sen. Tim Scott (R-SC) championed legislation preventing regulators from using "reputational risk" against banks serving legal industries—directly shielding Cross River from supervisory pressure.
Competitive Landscape
Cross River operates in a crowded lobbying environment. Fintech competitors include Chime Financial Inc., PayPal Inc., and Block Inc., all actively lobbying on banking partnerships and small business lending.
Traditional banking interests also compete for influence. The Bank Policy Institute lobbies for frameworks often favoring established institutions over new entrants.
Cross River’s position as a Banking-as-a-Service provider puts it at the intersection of these competing interests, requiring sustained lobbying investment.
The Bottom Line
Cross River’s lobbying spend this quarter continues a multi-year advocacy push targeting reduced regulatory burden and protected bank-fintech partnerships. While recent regulatory wins eliminated "reputational risk" supervision, the bank faces significant legislative threats from proposed federal interest rate caps and competitive pressure from fintech companies seeking independent bank charters.
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