Hey Toaster Readers,

This week is sponsored by our friends at Spinwheel.

Last week, NerdWallet announced Q2 earnings. Revenue came in at $197.3 million, up 6% YoY, beating Wall St’s expectations.

But, Adjusted EPS came in at $0.06, 67.8% below consensus.

And the stock went up.

Last quarter, they beat and the stock got hammered.

But this is a marketing newsletter, not an investing newsletter, so we’ll stay in our lane.

Below are the nuggets we think a marketer at a credit card issuer or personal loan company would care about.

Let’s get toasting!

Summarizing NerdWallet’s Q2

From the Q2 press release (quarter ended June 30th, reported August 6th):

Sponsored by Spinwheel

Now that you have the headline numbers, let’s get into our top observations.

1. Credit cards fell another $8.6M year-over-year

To us, that means the bleeding hasn’t stopped.

“...partially offset by an $8.6 million decrease from consumer credit cards primarily due to continued pressures in organic search traffic that have persisted for multiple quarters.” — Q2 press release

The former flagship business is a declining category, and NerdWallet hasn’t provided clear signs on how it’ll turn it around.

Why you should care: If you’re a card issuer, you need clarity on NerdWallet’s go-forward expectations for the card business. That’ll help you with forecasting, but will also provide clues regarding whether your declining volumes on the platform are because you’re losing market share, or whether you’re holding share in a declining market.

2. NerdWallet is leaning into the insurance agency business

The CEO’s quote at the top of the press release was telling:

“We’re reaching an inflection point in our business. The success of our vertical integration strategy now gives us the conviction to make incremental investments underwritten on a multi-year payback, with compelling returns. We expect to grow this incremental investment fivefold in 2026 versus 2025 as we deepen our owned audiences and build durable, direct relationships with our customers.” — Tim Chen, Q2 press release

Incremental investments underwritten on a multi-year payback.

Our translation?

We like the insurance business. It pays annuities over time vs. the one-shot payouts we get from the cards and loans affiliate businesses.

Why you should care: NerdWallet is deploying spend towards category with multi-year paybacks (our read: insurance, maybe financial advisors). If your product monetizes once at conversion, you might be competing for a shrinking share of their attention.

3. The Personal Loan biz is growing, probably due to expansion in subprime

From the press release:

“...increases of $12.3 million from personal loans as we expanded our marketplace offerings to serve a broader range of borrowers...”

Broader range of borrowers.

Our read?

NerdWallet is leaning into subprime loans.

Why you should care: If you’re a personal loan lender, especially in subprime, and you don’t partner with NerdWallet, now may be the time to lean in. And, bring your best conversion rate. With their focus on paid media vs. SEO, we bet they’ll be ruthlessly prioritizing the offers that convert best (and have the best CPAs).

Which, bring us to our next takeaway.

4. As sales & marketing spend grows, their focus on conversion rate will amplify

S&M spend of $145.4M grew 14% YoY while revenue grew 6% (press release).

We flagged this dynamic in Q1, and the Morgan Stanley concern we quoted then — elevated performance marketing intensity pressuring incremental margins — is now on display.

NGOI margin nearly halved YoY, from 11% to 6%.

When NerdWallet paid ~$0 (on the margin) for an SEO visitor, a “so-so” partner funnel was annoying.

But, when they’re paying market CPCs (which I assume are climbing due to SEO’s decline) and relying on multi-year paybacks, a “so-so” conversion funnel is a total disaster.

Why you should care: Expect tougher bounty/CPA negotiations, and less patience for application flows that perform below the category benchmarks. Your image of NerdWallet should be shifting from content-machine-SEO-gods to math wizards trying to squeeze every dollar of return out of their paid media spend. And there are questions around their strategy around paid media.

In their August 7th research note, Morgan Stanley analysts shared some great insight into this. Rather than summarize, we’ll quote directly. Emphasis added by us, not MS.

“NerdWallet grew revenue $10mm y/y in 2Q26 (to $197mm, +5.6%) on $17mm of incremental sales and marketing (to $145mm, +13.6%), taking S&M to 73.7% of revenue from 68.5% in 2Q25, while performance marketing grew $26.5mm y/y to $116mm, or 58.8% of revenue and 79.8% of total S&M (vs. 47.8% and 69.9% in 2Q25).

These results, coupled with the recent trends on revenue and performance marketing, reinforce our view that sustaining growth may require structurally higher spend as organic distribution erodes. These results, together with the recent rise in performance marketing intensity, reinforce our concern that growth is becoming increasingly dependent on paid acquisition as organic search remains pressured in parts of the business.

Management has said it is investing against internal IRR targets and accepting longer payback periods where recurring relationships can support attractive returns. Yet the company has not publicly disclosed its IRR hurdles, expected payback periods, or realized cohort returns.”

5. Some quick hits before we wrap up

Deposits are booming. Consumer revenue increased year-over-year with “$9.6 million from deposit accounts as partners expanded budgets” (press release). We’ve noticed this a little with my agency, New Market Growth. We’re getting inquires from banks who need help with affiliate marketing for deposits, even though my shop is lending only.

Insurance is stable, but not back to the highs. The carrier concentration issue that tanked the stock in Q1? Tim Chen said that the largest auto insurance carrier relationship “has stabilized but has not yet returned to levels seen earlier in the year”.

SMB is still shrinking. It’s down 11% YoY to $22.1M on organic search declines, “partially offset by an increase in business loan originations” (press release).

The LLMs bring high intent traffic, but low volume. Tim Chen on the call, via GuruFocus: “The traffic is converting well, with extremely high intent from users coming through an LLM wanting to transact in the marketplace. It remains a small part of the business today.”

Last plug. Spots are filling up fast.

The Affiliate Marketing Summit For Lenders & Publishers

• September 23, 2026 - San Francisco

• Learn more at events.thefreetoaster.com

Thank you to our event sponsors! Experian, Engine by Gen, Prism Data, Tare, and EXL.

Catch you next week,

The Free Toaster Team

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. Reply to this email or write us at info@thefreetoaster.com.

As of August 11, 2026, 57 out of the 150 available tickets remain! Request your invitation here.

An Upscale Alternative To The Big Hotel Conferences

Some large banks send 100+ people to Money 20/20 every year.

Run the math on that.

• $3,500 per ticket: $350,000

• $700 per round-trip flight: $70,000

• Two hotel nights at $250: $50,000

That’s $470,000 before Ubers, dinners, $12 lattes at the Venetian, and a week of lost productivity.

And what does it buy?

A spin at the roulette wheel. Thousands of people in one building, and every attendee hoping to bump into the 5 or 10 who could actually move their business.

Sure, we’ve enjoyed Money 20/20 over the years.

But the value was always proportionate to the work we put in before showing up: scheduling the right meetings, with the right people, weeks in advance. All the curation work falls on you. Skip the prep and you fly home with a pocket full of vendor business cards and 300 unread emails.

We got tired of that.

Carlos Caro spent 10 years on both sides of this channel, first leading partnerships at Credit Karma, then at Caribou. In all that time, he never found an industry event that felt like home. Everything was too big, too broad, or too far from the thing he actually cared about: affiliate marketing for consumer lenders.

So we’re building the event we wish had existed. The anti-big-hotel-conference.

The Affiliate Marketing Summit for Lenders and Publishers goes live on September 23 at the Exploratorium in San Francisco, a stunning indoor-outdoor venue a few feet from the Bay.

Here’s what makes it different.

A curated audience of affiliate marketing leaders

We’re capping attendance at 150 and vetting every single guest.

More than 85% of the room will be partnerships leaders at consumer lenders and publishers, the people who collectively steer the $4-6 billion spent in this channel every year. The other 15% must be ecosystem partners that directly add value to lenders and publishers (like credit bureaus, alternative data platforms, and operational vendors).

Every person there is either someone you already know or someone you’ve been trying to meet. One day can replace 5-10 partner visits.

Discussing a unique moment in the industry’s history

SEO is shifting, LLMs are rewriting how consumers find financial products, and the AI era stands to change how lenders and publishers do business together.

Those are the conversations that get buried at Money 20/20 and LeadsCon.

Here, they have 100% of our attention.

A format that acknowledges how busy you are

A state-of-the-industry keynote to open the day. Three moderated debates on the questions people usually dodge on stage, with topics curated from practitioners and both sides given an equal voice. Structured networking, catered breakfast and lunch, and a happy hour by the water to close. No sales booths, no off-topic speeches, no wandering a large casino to find the person you’re not sure will attend your coffee meetup.

Plus, a networking day in Sonoma for leaders that struggle to find unstructured, quality time with partners

And for an adventurous group of 50, the conversation continues on Day 2 at Ridge Vineyards in Sonoma. Day 2 has no official programming: a private shuttle, a long lunch, a wine tasting, century-old vines, and the kind of setting where a two-hour conversation happens on its own.

You’ll be in good company. Leaders from Experian, Credit Karma, Bankrate, Prism Data, LendingTree, Credible, QuinStreet, SoFi, LendingClub, Pagaya, OneMain Financial, Avant, Aven, Happy Money, Upgrade, Atlanticus, LendingPoint, GM Financial, Perpay, Bulldog Media Group, FICO, and Engine by Gen have already registered.

The Summit is invitation only.

If you lead partnerships, growth, or affiliate marketing at a consumer lender or digital publisher, you’re likely a great fit.

Requesting an invitation takes about a minute: submit your name here and you’ll hear from us by the end of the next business day.

A big thank you (!) to our sponsors

We’re grateful to our sponsors Experian, Engine by Gen, Prism Data, Tare.io and the ICS Corporation for helping make this event possible.

We couldn’t be more excited to host this. Hope to see you in San Francisco.

Carlos & Nick

Founders, The Free Toaster

PS: If you have any questions, please email us at info@thefreetoaster.com.

Hey Toaster Readers,

This week is sponsored by our friends at Bulldog Media Group.

This week, Carlos drops an editorial piece on where he thinks things are going (or, more accurately, not going) when it comes to the distribution of consumer lending products.

Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

BUT FIRST, A FREE TOASTER EVENT ALERT 👀

The Affiliate Marketing Summit For Lenders & Publishers

• 87 out of 150 tickets are spoken for. 63 tickets still left!

• September 23, 2026 - San Francisco

• Target audience: Affiliate marketing leaders at lenders and publishers

• Learn more and request an invitation at events.thefreetoaster.com

Thank you to our event sponsors!

Headline Sponsor: Experian

Presenting Sponsors: Engine by Gen and Prism Data

Gold Sponsors: Tare, EXL, and The ICS Corporation.

Where The World Is Going

To anyone paying attention in tech, the future of digital information (and products that rely on digital information) seems pretty obvious.

You’ll hold up your phone, or smartwatch (or insert newest/fanciest device), utter a request in a sentence or two, and what you want will just HAPPEN.

Unlike the first wave of the internet and mobile, where the magic still required meaningful human interaction, this era will be defined by how effortless and fast things will get.

Instead of spending hours on Kayak to find & book the perfect flight, your AI assistant will know your preferences, constraints, hotel bookings, frequent flier numbers, and budget. And instead of making you do the hard cognitive work of deciding, it’ll just act.

Ticket confirmations will magically appear in your inbox.

What used to take hours and real thinking will now take minutes and no thinking at all.

What This Looks Like In Consumer Finance

In the 2010-2026 internet era, refinancing your credit card debt required real work.

First, you had to go calculate how much debt you needed to refinance.

Then, you had to do some math to figure out how much money you stood to save if you refinanced. After all, you were about to put a bunch of work into this and you had to be sure the cost-benefit of the whole thing made sense.

Next, you had to shop around to see which banks (a) had any offers for you and (b) had the best rate for you. And, you had to do this carefully because generating hard inquiries meant lowering your credit score and reducing your odds of a successful transaction.

Then, you had to compare terms & rates.

The lowest rates had shorter terms and the longer terms had higher rates, but lower monthly payments. Crunching all the numbers to understand the total cost of credit (and whether or not your cashflow could handle the monthly payment) was real work.

Lastly, you had to conduct the transaction.

This meant filling out forms online, and then sometimes talking to humans, tracking down W2s or paystubs, sending bank documents to confirm your identity, and so on and so forth.

To complicate matters, you had to be financially savvy to know what to do. Else, this process had to start with hours of online research or talking to friends that could guide you through the process.

We’re a huge step forward from where the industry was pre-internet, but we can do much better.

Sponsored by Bulldog Media Group

Reach the Borrowers Others Miss

Bulldog Media Group specializes in connecting consumer lenders with less than perfect borrowers — a massive, underserved market that requires precision targeting to get right. With 25 years of financial services marketing experience, they deliver qualified leads through affiliate marketing, targeted email, and data-driven acquisition strategies built for this exact audience.

If you’re a lender looking to scale, these are your people.

Get Qualified Borrower Leads

Our (Fairly Obvious) Future

“Hey Claude, this summer I spent too much on my summer vacation. It’s sitting on my card right now at 29% APR. It’s about $4 grand, but I’m not totally sure the amount. I want to payoff that card in full, and pay that $4 grand off in $100 monthly payments until it’s gone.”

[Claude thinks for 15 seconds]

“Hey there, friend. I found great options for you. (1) A personal loan with Chase, your primary bank. The APR is 9.25%, the monthly payment is $100, and it’ll take 48 months to pay off. It’ll cost you $800 in total interest over the 4 years.

(2) A personal loan with SoFi, a popular digital lender. The APR is 7.00%, the monthly payment is $124, and it’ll take 36 months to pay off. It’ll cost you $464 in total interest over the 3 years.

PS: Your balance on that Chase Amazon card is actually $3,850. I suggest going with a $4,000 loan (most banks like the round numbers), and putting the extra $150 in your checking account.

What option are we going with?”

[human takes 10 seconds to decide]

“Let’s keep everything consolidated with Chase. Option 1.”

“Done. I’ll handle this. You’ll see confirmation emails from the banks in 10 minutes or less. If I need any extra info or approvals, I’ll text you.”

PS: This “future” state is admittedly toned down. The real future of consumer finance is the LLMs knowing your goals, constraints, and preferences, and quietly doing whatever it needs to do with your accounts to make that happen. Some consumers will want to be informed about what their ‘self-driving’ money is doing, and some won’t.

When Will We See This Future In Lending?

We all know consumers are adopting LLMs at unprecedented growth rates.

But, when will the default shopping experience for lending products change?

First, we have to overcome 2 blockers:

Blocker #1: Lenders Are Afraid Of What The Machine Will Say

The big lenders aren’t broadcasting this, but it’s what I hear from friends in the industry.

If an LLM describes a product and gets a term wrong—the wrong APR, the wrong fee, an intro period that expired last quarter—we could have a UDAAP issue.

The CFPB said in 2023 that a chatbot giving a consumer wrong information about a fee or rate can constitute a UDAAP violation.

Now put yourself in the compliance leader’s seat.

Marketing walks in asking to feed product data into Claude or ChatGPT where a probabilistic model will paraphrase it—in a way you can’t preview, at a scale you can’t audit, to a consumer you can’t identify.

I don’t know a single compliance professional that would say “sounds great, ship it.”

There’s a phrase that people kick around in the industry that summarizes what’s going on here perfectly:

“No one at a bank has ever gotten fired for saying no”

--Anonymous

But tons of people could get fired for being an early mover in an industry that operates cautiously towards these sorts of things.

Blocker #2: Consumers Don’t Yet Trust Claude & ChatGPT With Their Financial Data

I’m Exhibit A.

LLMs will do a terrific job of finding consumer lending products for us once we trust them enough to hand over our credit profiles and bank accounts. And then, our consent to conduct transactions on our behalf.

I haven’t done that yet.

And I think about this stuff every week (or every day).

I’m as bullish on this future as anyone you’ll meet. And I have not given an LLM access to my financial accounts.

I draw the line at giving it summarized data from my accounts (without my PII or account numbers), so it can help me with analysis.

But my trust stops there.

So I suspect consumers today share context. But, they’re extremely nervous about sharing credentials.

Now here’s the thing about these blockers.

They each support each other and keep each other in place.

Lenders won’t do what’s required to make LLMs effective acquisition channels until they see the consumer demand. And, consumers won’t feed the LLMs the data and consents required to transact until they see a killer app from the banks.

Chicken and egg.

Seems like neither side wants to move first.

The Mobile Banking Déjà Vu

In the early 2010s, I was at a large Fortune 500 bank when mobile banking was the new, cool thing everyone was nervous about.

Will consumers really bank on their phones?

Will they really check their transactions there?

Do we need to bring all the features from the desktop to the phone or just the ability to pay your bill?

In retrospect, these are ridiculous conversations.

But, I remember being in consensus meeting after consensus meeting about this stuff.

Per the Fed’s surveys, only 22% of mobile phone users with bank accounts used mobile banking in 2011. It took until 2015 to reach 43%.

The iPhone launched in 2007 and it took until 2015 for 43% of consumers to bank on their phones.

ChatGPT launched at the end of 2022. That same 8-year timeline puts us at the end of 2030 before banking through an LLM becomes mainstream.

That feels about right.

So Now What?

Most of the lenders I speak with are still sourcing new customers through the same channels they were using 5 to 10 years ago. Direct mail, affiliates, paid search, paid social, and first-party channels.

AI is taking over the world and we read about it daily.

But, very little has changed in our industry.

I hear about affiliate marketplaces toying with AI, but the changes appear to be very early and experimental.

As a CMO at a credit card or loan company, I wouldn’t expect dramatic changes to distribution in the next 12 months.

I’d expect SEO and paid search to get harder as LLMs eat this traffic.

I’d expect affiliates to continue to think about the future when LLMs take over.

I’d expect direct mail and social to hum along.

So, the 3 things I’d start doing now as a CMO would be:

1. Make sure my organization has a good compliance framework for how we’ll handle LLMs talking about our products

2. Make sure my account opening tech makes it easy for the LLMs and bots to transact with me (the “buyer” is transitioning from humans to bots)

3. Make sure I’m investing in my brand. Ad presentation rates and conversion rates in LLMs like Claude and ChatGPT are going to be 10X higher (or more) when the customer mentions me by name

All of these things are going to feel remarkably “un-urgent” until something suddenly happens that makes them feel urgent.

The “no-regrets” move would be to start now on all of ‘em.

I can’t imagine a world where you won’t have to knock them out eventually.

Catch you next week,

Carlos Caro and Nick Madrid

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. Reply to this email or write us at info@thefreetoaster.com.

Hey Toaster Readers,

This week is sponsored by our friends at New Market Growth.

Capital One reported Q2 on July 21. We read the press release, listened to the earnings call, the 10-Q, and four research notes, so you don’t have to.

Most coverage focused on the $3.0 billion in net income. We pulled out the five things marketers should actually take from the quarter.

Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

BUT FIRST, A TOASTER EVENT ALERT 👀

The Affiliate Marketing Summit For Lenders & Publishers

• New Publishers & Lenders are signing up every week

• September 23, 2026 - San Francisco

• Day 2 (relationship building in wine country) is almost sold out

• Early bird pricing ($999) ends on midnight ET on August 1st!

• Learn more at events.thefreetoaster.com

Thank you to our event sponsors! Experian, Engine by Gen, Prism Data, Tare, and EXL.

Capital One runs one of the biggest acquisition budgets in consumer lending. Once a quarter, its executives explain what that budget is doing.

Here are the five takeaways from this quarter, in their own words.

1. One of the biggest marketing budgets in lending grew by 23%

The Discover acquisition is only half the story.

CEO Richard Fairbank walked us through the marketing line item on the earnings call:

“Total company marketing expense in the quarter was about $1.7 billion, up 23% year over year, driven by the addition of Discover as well as higher legacy Capital One direct marketing in our domestic card and consumer banking businesses, increased media spend, and continuing investments in premium benefits.”

What we found interesting?

👉 Legacy Capital One direct marketing is up, independent of the Discover acquisition.

We’ve tracked Capital One as a mail and media heavyweight since well before the Discover deal.

If you compete with them in channels like Direct Mail, affiliates, paid search or paid social, it sounds like the competition is getting more intense.

2. Consistent with their ‘heavy spender’ strategy, spend is increasing more than balances

The Q2 numbers, side by side:

• Total card purchase volume: $253.8 billion, up 26% year over year.

• Legacy Capital One volume (including Brex and corporate cards): up about 14%, mostly organic, per CFO Andrew Young on the call

• Domestic credit card balances at period end: up 2.6% year over year

Spending up 26%. Balances up 2.6%.

Fairbank described their target as “an enduring franchise with heavy spenders at the top of the domestic credit card market,” fed by premium benefits, lounges, and the travel build-out.

3. Consumer deposit growth is a first class citizen for the marketing organization

Consumer banking was mentioned specifically in Fairbank’s description of the 23% growth in marketing spend. In Fairbank’s words, Capital One wants to “to grow checking accounts on a national scale.”

He continued to say consumer banking now has “an increasing impact” on the total marketing line.

Digging into that statement a little bit, we found:

• Capital One pays 3.0% on its online savings account, the lowest in the peer set BofA tracks

• Bread Financial pays the most at 3.95%

• Average deposits still grew 1.4% sequentially, per the press release

• Rate paid fell 9 basis points, from the same press release

So deposit volume is up and rates are down, in the same quarter.

And, they’re growing deposits with the lowest interest rate in the BofA peer group.

From our 30,000 foot view, it sure seems like they have cracked the code on marketing in the consumer deposit segment. We suspect the money they spend on the brand side of the house could be a big part of their success.

4. Discover’s acquisition marketing is restarting, on a published schedule

Discover pulled back originations starting in late 2023, and Capital One trimmed further after the deal closed. Fairbank calls it “the Discover brownout.”

The result this quarter, per the call: the legacy Discover card book shrank 1.5% year over year while the rest of the book grew about 5.3%. BofA and Morgan Stanley both put the bottom around Q4.

On the earnings call, Capital One walked through the timeline of the re-boot:

• Half of new Discover originations already run on Capital One’s stack

• The rest land “by the end of the third quarter”

• The existing book migrates “in waves: a wave in July, a wave in October, a wave in January”

And they’ve already started ramping up:

“Marketing is mostly a front-book thing. So we are, as we speak, leaning more into the marketing so that we can now generate some very good flow of applicants.”

That’s Discover’s national prime card brand, gone quiet for roughly two years, and now re-entering acquisition channels with Capital One’s models and budget behind it.

If you buy digital media, mail, or affiliate placements in the card segment, this is worth keeping an eye on.

5. Credit is strong, but the rate of improvement may be slowing

The headline numbers, from the press release and the June credit-metrics 8-K:

• Domestic card charge-offs: 4.71%, down 54 basis points from a year ago

• Delinquencies: 3.39%, also down

• Reserve release: $662 million, including $705 million in domestic card reflecting “continued favorable observed credit in the quarter and a modest decrease in the consideration given to economic uncertainties,” per CFO Young on the call

Fairbank on the consumer:

“We don’t, in our own numbers, see this K-shaped economy that a lot of people talk about, although to be fair, we don’t really participate in the lowest end of the marketplace.”

The sell side split on what it means.

Morgan Stanley, in its July 22nd earnings note, read the reserve release as “a sign of confidence in the consumer” and thinks Capital One might have the strongest credit in its coverage.

BofA’s July 22nd note flagged the June data: delinquencies “followed normal seasonality after outperforming seasonality in most earlier months of 2026,” which “at a minimum suggests the rate of improvement in credit is slowing.” Morgan Stanley’s own Consumer Credit Activity Tracker, published July 27th, shows industry card delinquencies still improving through June.

The practical takeaway: Capital One publishes credit metrics monthly in 8-K filings. If your second-half budget assumes credit keeps improving, the 8-Ks may show the pacing before any earnings call does.

Consider checking it monthly.

TOASTER’S TAKE

• Watch the mailbox and affiliate shelves for Discover. The migration waves are July, October, and January, and management says acquisition marketing is ramping “as we speak.”

• The deposit growth results deserve a spot in every neobank’s board deck. Lowest rate in the peer set, deposits still growing. That’s evidence that an industry-leading brand can convince a consumer to take a rate that isn’t at the top of the comparison charts.

• Track the monthly 8-Ks. One issuer’s June seasonality proves little on its own, but it’s the first data point that could put doubt on the “credit keeps getting better” narrative.

Other News

• CFPB late fees, round two. The Bureau has reportedly sent a late-fee Request for Information to interagency review. Synchrony fell 9.6% and Bread Financial 8.3% on the headline. BofA’s exposure math: roughly 12% of Synchrony’s revenue, an estimated 20%-plus at Bread, about 5% at Capital One. An RFI is a question, and the last $8 cap died in court. (BofA Global Research, “Late fee redux,” July 9)

Catch you next week,

Carlos Caro and Nick Madrid

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. Reply to this email or write us at info@thefreetoaster.com.

Hey Toaster Readers,

This week is sponsored by our friends at Spinwheel.

This one is mostly an editorial, and we're putting a prediction on record: we think there will be a Claude Card and a ChatGPT Card. The road there starts with this week's news, Samsung's new Galaxy Card and its too-good-to-be-true rewards program, runs through who really pays for it and why, and ends with the one question that matters for every card issuer: whose card does your AI agent swipe by default?

First section is straight news. Everything after is opinion, and we'll label the line. Oh, and be sure to hold us to the prediction.

Let's get toasting!

BUT FIRST, A TOASTER EVENT ALERT 👀

The Affiliate Marketing Summit For Lenders & Publishers

• New Publishers & Lenders are signing up every week

• September 23, 2026 - San Francisco

• Day 2 (relationship building in wine country) is almost sold out

• Learn more at events.thefreetoaster.com

Thank you to our event sponsors! Experian, Engine by Gen, & Prism Data

The Galaxy Card Is Samsung’s Answer to the Apple Card

Samsung is getting into the credit card business.

This week the company announced the Samsung Galaxy Card. Its first credit card, issued by Barclays and running on the Visa network (American Banker). Applications opened July 22, right before Samsung’s Galaxy Unpacked event (Wired, CNET).

The card lives natively inside Samsung Wallet. You apply there. You service the account there. You redeem rewards there. You never leave Samsung’s ecosystem.

The number to know: 3% cash back on eligible purchases made through Samsung Wallet, no spend caps. That's a full point above Apple Card's blanket 2% Apple Pay rate. Apple only pays 3% at Apple and a short list of partner merchants (Apple). Samsung pays it on everything in the wallet.

And Barclays is doing something no issuer has done before: extending its servicing APIs all the way into Samsung’s operating system.

“Rather than going to our app or our website, you’re now servicing it within Samsung’s ecosystem completely,” Doug Villone, Barclays’ head of US cards and partnerships, told American Banker.

If the Apple Card comparison feels familiar, it should. We covered the messy end of that program’s first chapter in January, when JPMorgan Chase took over the portfolio from Goldman Sachs at a discount of more than $1 billion (Apple Card’s Next Chapter Starts at JPMorgan).

That’s the story.

Sponsored by Spinwheel

Now here’s our Toaster Take.

Samsung Is Paying Barclays’ Rewards Bill To Handcuff You To Your Phone

It's a retention product wearing a rewards costume.

Start with the number that doesn’t add up: 3% cash back on every purchase made through Samsung Wallet. No spend caps.

That doesn’t work on a lender’s margins. Interchange doesn’t cover it.

Neither company has said who funds the gap. But we don’t think there’s much mystery here. Samsung is likely writing the check.

Look at where the richest rate points. Apple pays 3% at Apple. Samsung pays 5% at Samsung: Samsung.com, the Shop App, its stores (terms).

Same playbook, two points richer. The top of the earn table always aims back at the house.

And once you see the subsidy, the rest of the product snaps into focus.

The physical card works anywhere, at 1%. But the 3% only pays when the card sits in Samsung Wallet. And Samsung Wallet only runs on Samsung devices.

Switch to an iPhone? Your everyday spend drops to 1%.

(Technically the 5% on Samsung.com purchases survives the switch. But you just bought an iPhone. You’re not making many of those.)

The math makes it rational. Every Samsung phone is a $1,000+ sale, followed by years of ecosystem revenue. And Samsung is fighting uphill in the US. Roughly 6 in 10 US smartphones sold are iPhones, and Samsung sits second at well under half of Apple’s share (Counterpoint Research via AppleInsider).

Against that, funding a couple points of cash back on a cardholder’s spend is cheap insurance.

There’s a quieter prize too. And Amazon showed everyone how it works.

A co-brand card doesn’t just drive loyalty inside your store. It shows you every purchase your customer makes outside it. That data is worth a lot to a company deciding what to build, stock, and sell next.

Keep that thought. It’s about to become the whole story.

“First In Wallet” Just Changed Meaning

Card issuers have spent decades fighting to be first in the physical wallet. The card you reach for without thinking.

Our take: that fight is moving. And some lenders haven’t noticed.

The fight that matters now is first in the digital wallet. Because the default card in the wallet is the card your AI agent is going to swipe.

Agentic commerce is early. But it’s not hypothetical.

About 31% of US AI users already use AI to find product links. One of the highest-usage AI behaviors across age cohorts. Shopify reports AI-referred shoppers convert at roughly 50% higher rates than organic search, with AI-referred orders up ~13x year over year in Q1. Only 6% of consumers have actually completed a purchase through an LLM so far, so the bottom of the funnel is still nascent. (All per BofA Global Research, “Latest on Agentic Commerce vs Traditional eCommerce”)

But when those purchases happen, the agent isn’t going to deliberate over which of your cards to use.

It will use the default.

Whoever holds that slot gets the transaction.

Chase already owns that position across the Apple ecosystem. As of this week, Barclays owns it across Samsung’s.

Neither bank has framed it this way publicly. We are.

Which brings us to the lesson.

And this part is advice: If you’re a card issuer trying to grow a co-brand business, stop only calling retailers.

The classic playbook is retailers, retailers, retailers. The new call list is technology companies with a vested interest in keeping consumers inside their world.

They’ll do two things a retail partner never could:

1. Hand you distribution inside a platform people touch every day

2. Subsidize terms you could never offer on your own economics

Samsung just showed everyone the template.

Our Prediction: There Will Be A Claude Card And A ChatGPT Card

Now we’re going to speculate. None of what follows has been announced by anyone (that we know of). But we’d rather be on record.

Though one thing was announced: on Tuesday, OpenAI seated Nubank founder David Vélez on its board (OpenAI).

We can only speculate why and here’s what got us there.

We asked ourselves which companies fit the profile we just described: technology platforms with daily usage, deep customer context, and a reason to lock users in.

The answer wasn’t another phone maker.

It was the LLMs.

The scale is already there. The Google Search app’s share of daily active users versus AI apps has fallen from 87.5% in January 2025 to 72.5% in June 2026. And ChatGPT did more than $260MM in revenue in June alone (BofA Global Research, “Apple Inc.: F3Q26”.

ChatGPT counts 441MM global mobile daily active users. Claude is at roughly $59MM a month in revenue, growing daily users at 1,200%+ year over year. It’s momentum BofA attributes to “Claude Code and agentic features” (BofA Global Research, “AI Wars: Claude & Gemini momentum continues, with stable Google growth,”).

These are daily habits at consumer scale, with real willingness to pay.

A daily habit plus a payment credential is exactly the position Samsung just monetized. And the LLMs are further along the daily-habit curve than Samsung Wallet ever was.

Here’s the thing: the incentive is even stronger than Samsung’s.

Anthropic and OpenAI are in the business of monetizing intelligence. The more context they have on you, the more valuable that intelligence gets. The compounding is the point.

The biggest missing context? What you do offline, away from the chat window.

A card is the window.

Samsung wants your purchase data to sell you more Samsung. An LLM wants it because it makes the core product better.

Picture what that unlocks.

You’ve told Claude you’re saving for a house. Claude also issues your card. One morning it opens with: “You spent $300 at Starbucks last month. Want me to block Starbucks until you hit your goal?”

That’s a hypothetical. But that’s the conversation a card makes possible. No bank’s app has ever come close.

Or take the offer side. You ask about rental cars for a trip. Alamo happens to be a card partner. The answer comes back: “cardholders get 20% off, say yes and it’s booked.”

A daily product with full context doesn’t serve ads. It serves outcomes.

The rewards get interesting too. We pay for Claude Max. Offer us extra usage limits as a card perk and we’d chase it. Hard.

Cash back is a commodity. Model access is a loyalty currency no incumbent issuer can mint.

The privacy question is real, so let’s answer it head-on: will consumers want their AI to know this much?

In finances, we think yes. It’s simply going to be too useful not to.

One more thing nags at us.

Google has owned search and a wallet for over a decade and has never issued a consumer credit card. Its closest attempt, the Plex banking project, was scrapped in 2021 before launch, despite a 400,000-person waitlist (CNBC).

We’re surprised the seat is still empty.

Maybe the LLMs Never Need To Issue A Card

The counterargument is Plaid.

We wrote in May about ChatGPT’s Plaid integration making it a distribution channel for personal finance. Permission your accounts, and the LLM gets the spending intelligence with zero plastic. No bank charter. No credit risk. And the consumer can revoke access anytime.

Why issue a card at all?

Add to that: the LLMs are currently retreating from the transaction, not grabbing it. OpenAI has reportedly pulled back from “Instant Checkout” toward retailer-controlled checkout after finding users research in ChatGPT but buy elsewhere (The Information, as cited in BofA Global Research, “OpenAI may shift Agentic Checkout”).

And Google is monetizing its agentic surfaces through ads rather than commissions (BofA Global Research, “The dog days of AI”).

Maybe the LLMs settle in as discovery layers and never touch the payment credential.

Then we argued ourselves back in.

Plaid access is something a user has to grant, account by account. And it can break without warning.

A card is zero friction. One instrument that captures everything, funds its own rewards through interchange, and monetizes through sponsored offers.

And precisely because the LLMs are ceding checkout to retailers, the payment credential is the one durable position left in the stack. Samsung’s logic applies with full force: you issue the plastic because you want the whole picture.

Where we land today: the cards happen.

Ask us again in six months.

A footnote on rails, filed under questions we can’t answer: does a Claude card launch on Visa or Mastercard? Or on stablecoin infrastructure?

Programmable money is the more natural fit for agentic commerce: smart contracts, near-instant settlement. It might be blockchain’s actual consumer use case.

Our guess is boring: launch on traditional rails for acceptance, migrate agentic flows later.

But we don’t know. And neither does anyone else yet.

What Do You Think?

We’d be surprised if Anthropic, OpenAI, and Google haven’t already gamed this out internally.

If you’re working on anything in this space, or you know who is, we want to hear from you. This piece is us thinking out loud, and we’d love to learn more from operators in the space.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. Reply to this email or write us at info@thefreetoaster.com.

Ross, an advisory partner at Arica Consulting with 20+ years running search across Capital One, New York Life, FrontPoint, and Greenlight, has evaluated search agencies from every angle — client, operator, founder, and agency owner. In this deep-dive with Carlos, he shares the exact questions a non-technical CMO can ask to separate the pros from the pretenders.

We cover:

• Why quality score and the keyword vs. search term gap drive everything

• The branded/unbranded commingling trap that hides massive unbranded overspend

• Why optimizing to CPL instead of CPA is the single most common mistakes agencies make

• Reading the change log, auditing Google’s auto-recommendations, and the marginal vs. average CAC test

• How to start from scratch: build an MVP account, one landing page, a few keywords

This conversation is practical, in-the-weeds, and refreshingly honest.

Find Ross at recohen.com or on LinkedIn

******

Come meet Carlos in San Francisco!

The Affiliate Marketing Summit For Lenders & Publishers

Sponsored by Experian, Engine by Gen, and Prism Data
San Francisco - September 23rd & 24th

The Exploratorium

150-person, curated room

Early bird tickets ($999) end August 1
Learn more: events.thefreetoaster.com

*****

Sign Up For Our Newsletter

The Free Toaster Newsletter ships every Wednesday at www.thefreetoaster.com, curating the biggest stories at the intersection of consumer lending, marketing, and technology.

******

Please Support Our Sponsors

Bulldog Media Group:

Bulldog Media Group is a leading performance marketing company that specializes in online customer acquisition for clients in the financial services industry. Since 2000, they have focused on financial services digital marketing as their core niche.

https://www.bulldogmediagroup.com/

Fintel Connect

Drive thousands of new accounts and billions in deposits with the only partner marketing solution built for fintech and banking – your all-in-one affiliate platform, partner network, agency, and marketing compliance engine.

https://partner.fintelconnect.com/get-to-know-fintel-connect?utm_campaign=13897733-2025%20Partners&utm_source=The%20Free%20Toaster&utm_medium=podcast

Spinwheel:

Reduce friction in your lending application with just two fields—phone number and birthdate. Spinwheel’s APIs boost application rates by 20-30% while also providing real-time credit data and seamless payment processing. Want to see it in action? Connect with their Head of Growth for a demo!

https://spinwheel.io/partner/?utm_source=freetoaster&utm_medium=podcast&utm_campaign=july

New Market Growth (Carlos’ agency)

NMG focuses on building affiliate marketing programs for consumer lenders.

www.newmarketgrowth.com

Hey Toaster Readers,

This week is sponsored by our friends at Fintel Connect.

Quick housekeeping first. The last few weeks have been a slow news cycle, so we’ve been trying something new: taking a single story from the week and going deeper than we normally would. Please let us know if you like this format or not by replying to this email.

We want to hear from you.

This week’s story is “Oportun and Column Announce New Lending Partnership to Expand Access to Responsible Credit.”

At first glance, not that exciting. Just a new partner bank.

Then we dug into the filings and found something strange: for the past nine months, Oportun had a bank partner that wouldn’t hold a single one of its new loans. Pathward originated them, and Oportun bought back 100%. Meanwhile, a growing acquisition machine in consumer lending (referrals in Q1 2025 up 352% year over year) sat idling with nowhere to run.

This is why the Column deal is more than a routine bank partner transaction. It might be the moment Oportun’s marketing team finally got the green light.

TOASTER EVENT ALERT 🚨

The Affiliate Marketing Summit For Lenders & Publishers

• New Publishers & Lenders are signing up every week

• September 23, 2026 - San Francisco

• Day 2 (relationship building in wine country) is almost sold out

• Learn more at events.thefreetoaster.com

Thank you to our event sponsors! Experian, Engine by Gen, & Prism Data

Backstory: A Phantom Bank Partnership 👻

Here’s an arrangement that should make any marketer queasy.

Under a September 2025 amendment, Pathward stopped retaining Oportun’s loans. From October 1, 2025, Oportun bought 100% of everything Pathward originated. Then it bought back Pathward’s existing book too, $115.0 million on October 3, 2025, with the remainder acquired on February 4, 2026.

Oportun was renting a charter from a bank partner who wouldn’t hold a single loan.

The impact of carrying all of that shows up in the numbers:

• Originations fell 11% Y/Y in 1Q26 under what the company calls a “tight credit posture”

• FY26 originations guidance sits at just mid-single-digit growth

Sponsored by Fintel Connect

Webinar: Cross-border conversions: winning in Canada’s credit card market

Canada is a high-potential acquisition market, but U.S. affiliates and financial brands need more than a U.S. playbook to win.

Join leaders from Fintel Connect, Finder, and FinlyWealth for a focused 30-minute webinar on how banks, credit unions, and fintechs can use the right affiliate partnerships, localized content, and compliance-ready workflows to drive measurable growth.

What you’ll learn

• Where affiliates see the strongest opportunities

• What top publishers expect from brand partners

• How to navigate Canadian disclosures, CASL, rewards language, and approval processes

Click here to sign up

Column N.A. Jumps In To Save The Day

Last week’s announcement reads like a funding story.

Column N.A., the nationally chartered bank spun up by Plaid co-founder William Hockey (he acquired and re-charted Northern California National Bank), with clients like Brex, Bilt, and Wise, will originate Oportun’s unsecured personal loans and put its own balance sheet to work through debt financing and loan purchases.

This is great news for Oportun.

And it shows they just overcame a growth blocker many fintechs learn the hard way:

Bank or capital markets partnerships, not media buying, are often the real cap on growth.

Oportun Is Operating With Two Partner Banks At Once

Oportun’s own state-licensing page now tells consumers in 32 states that their loan “may be originated by Pathward®, N.A. or Column N.A.”

Seven states remain Pathward-only (GA, IL, NH, NJ, PA, RI, SD).
NM and WI stay on Oportun’s own licenses.

The 8-K adds the fine print. The agreement “includes certain exclusivity provisions with respect to specified loan products and certain future financial products, subject to existing bank partner rights and other exceptions.” That last clause looks like a direct carve-out for Pathward.

And the deal has “an initial term of four years and renews automatically for successive one-year periods.”

Things got a little more interesting when we learned what business lines each partner bank is supporting.

Secured Personal Loans (SPLs) Will Stay In An 8-State Footprint

Here’s something we didn’t realize about Oportun’s SPL business.

Secured personal loans grew 30% Y/Y in 1Q26 with substantially lower losses than unsecured. A deck from 4Q24 helps put that in context: approximately 500 bps lower 2024 losses and approximately 75% higher 4Q24 revenue per loan than unsecured.

It seems like SPLs are Oportun’s best-performing asset.

And the Column agreement covers unsecured loans only. Column “will originate certain unsecured personal loans for consumers in select states”. SPL is live in eight states (AZ, CA, FL, IL, NV, NJ, TX, UT), and its expansion path to roughly 33 more states runs contractually through Pathward.

One door is already written into the contract: the exclusivity provisions cover “certain future financial products,” which is exactly where an SPL program at Column would live.

SPLs will survive. Whether its national expansion goes through Column, Pathward, or nobody is the open question. The timeline to an SPL program beyond 8 states is the other unknown.

Oportun’s Marketing Metrics Were Looking Good…Until They Hit A Wall

Here’s what Oportun’s acquisition engine was doing while originations shrank:

• CAC fell to $117 in FY2025, from $125 the year before, after touching a public-company low of $111 in 4Q24

• Referral-driven originations grew 352% Y/Y to $35M in 1Q25

• Instant prescreen launched in 1Q26

The machine seemed to be working.

But their bank partner didn’t want to keep funding the loans.

Now we need to watch Oportun’s Q2 earnings.

Will they raise FY26 originations guidance? That would tell us that Column’s capacity has given the marketing team the green light.

Support our Newsletter by sharing this edition with a colleague!

And, please check out our Newsletter sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

And, a big thank you to our September 23rd Event Sponsors!

• Experian

• Engine by Gen

• Prism Data

• New Market Growth

Now They Can Lean Into National Channels, Like Affiliate Marketplaces

Lenders with big geographic gaps cost the marketplace real money. Between state-level eligibility logic they need build and maintain, unserved customer segments, and potentially wasted impressions, regional lenders aren’t exactly what publishers dream about.

A national bank program makes Oportun’s offer easier to integrate, easier to promote, and more valuable to publishers like Credit Karma, Experian, and NerdWallet.

The national footprint makes life easier in other channels, too.

Direct mail, prescreen lists, digital targeting, telesales licensing, and retail distribution locations were all limited by geographic constraints.

The new partnership with Column unequivocally provides oxygen to Oportun’s growth effort.

But, a separate question remains unanswered about all of this.

Why Isn’t Oportun Part Of The Bank Charter Craze?

Last week, we wrote about the parade of fintechs filing for their own bank charters and moving away from the bank partner model.

Oportun might have been too early to the party.

Oportun began its OCC application for a de novo national bank in November 2020, seeking, in its own words, to “offer additional products and services, provide us with new sources of lower cost funding and give our business regulatory clarity”. It withdrew in October 2021 with a stated plan to refile.

It never did refile.

While Klarna, Affirm, and Upstart took what seems to be the popular path, Oportun chose a different road.

We wonder if it’s because Oportun’s business has historically focused on thin files/credit invisibles, with a focus on underserved hispanic audiences, and a products that were north of 36% APR before 2020.

All of these factors could influence a regulator’s likelihood to approve a bank license.

None of those real-life considerations are easy to talk about, but they lurk in the shadows of this new partnerships between Oportun & Column.

Put differently, is Oportun seeing a strategic advantage to sticking with the bank partner model while others move to secure their own charters, or were there structural reasons that took this option off the table?

If you have a POV on this, we’d love to have you on our News Pod to discuss. Reply to this email if you have a hot take you’d like to share.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. Reply to this email or write us at info@thefreetoaster.com.

Hey Toaster Readers,

Klarna wants to be a bank. So do 9 other fintechs. In 7 months, many fintech consumer lenders have headed for a regulator’s door, and the partner banks they’ve been renting for a decade should be nervous.

Inside: who’s filed, why the window opened, whether it stays open, and why bank and fintech marketers should be paying close attention.

This week is sponsored by Bulldog Media Group.

The Year Fintech Lenders Stopped Renting Banks

On July 6, Klarna announced in a press release (and disclosed in a Form 6-K filed with the SEC, with American Banker reporting the same morning) that it had filed applications with the Utah Department of Financial Institutions and the FDIC to establish Klarna Bank USA, a Utah-chartered industrial bank. “Banking is built on trust,” CEO Sebastian Siemiatkowski said in the announcement, calling a U.S. license “the natural next step” for a company that says 30 million Americans use its products every year and that has extended more than $91 billion in credit to U.S. consumers since 2019, all of it through partner banks.

Interesting timing, we think, given that just a few weeks ago, we covered Klarna launching an FDIC-insured high-yield savings account through WebBank and that Pagaya is suing the BNPL provider for allegedly stealing its underwriting model.

And Klarna is not an outlier. Since December 2025, it’s the ninth major fintech to file for (or buy its way into) a U.S. bank charter. Insured deposits and direct access to the payment rails, the banking industry’s forbidden fruit, are being handed out application by application. The companies queuing up are the same brands that already sit between banks and tens of millions of consumers.

(Don’t Miss Our First Big Toaster Summit)

Affiliate Marketing Summit for Lenders and Publishers

Proudly Sponsored by Experian, Engine by Gen, and Prism Data

Heads up: our Day 2 experience is going faster than we planned, with fewer than 20 spots left.

Our Day 2 is where lenders and publishers trade the conference hallway for a vineyard and build real relationships, not a pocket full of business cards.

We’re spending the day at Ridge Vineyards in Healdsburg, a legendary Sonoma estate that’s been championing single-vineyard winemaking since 1962. It’s designed to be both impactful and entertaining, giving you the time and setting to build partnerships that don’t happen in a Money 20/20 crowd.

Learn more and grab a spot: events.thefreetoaster.com

So…who’s filed for Bank Charters?

The filings cluster into three routes: the industrial loan company (ILC) charter favored by balance-sheet-hungry lenders, the full national bank charter, and, in one notable case, a charter type nobody had touched in two decades.

The OCC saw 18 de novo charter applications in 2025 (that’s nearly equal to the previous four years combined). Klaros Group co-founder Michele Alt expects roughly 25 novel applications in 2026. Approvals are flowing too. The FDIC has conditionally approved ILC bids from Ford, GM, Stellantis and Edward Jones since January; the OCC has granted conditional charters to Mercury and Nubank’s U.S. unit, alongside a wave of crypto-focused national trust banks.

OppFi took a different route, acquiring BNC National Bank in April rather than filing de novo.

And while we have zero insider knowledge of impending applications, we wouldn’t be surprised to see a number of other fintechs join them. Chime is the most obvious contender, their leadership basically pre-announced it in April. Then there’s Robinhood and Wealthfront, two giants wearing software costumes while a bit portion of their revenue is interest income.

The fence is getting increasingly crowded. Walmart-backed OnePay is expanding aggressively, Dave and Current face the exact same partner-bank margin pressures as Chime, and SMB powerhouses Ramp and Rho are feeling the heat after Mercury’s conditional approval. Even Cash App is a wildcard. This could be a now-or-never regulatory window, and few want to be left behind renting someone else’s banking license.

Sponsored by Bulldog Media Group

Reach the Borrowers Others Miss

Bulldog Media Group specializes in connecting consumer lenders with less than perfect borrowers — a massive, underserved market that requires precision targeting to get right. With 25 years of financial services marketing experience, they deliver qualified leads through affiliate marketing, targeted email, and data-driven acquisition strategies built for this exact audience.

If you’re a lender looking to scale, these are your people.

Get Qualified Borrower Leads

Why are they all filing now?

Three factors converge to make this window imperative.

Funding: insured deposits are the cheapest, most stable money in finance, and a lender that funds receivables through securitizations and warehouse lines can cut its cost of funds materially by taking deposits. “You get access to low-cost funding in the form of insured deposits. That’s pretty cool,” Michele Alt puts it.

Control: a charter removes the sponsor banks that currently sit in the middle of every loan, with their fees, their oversight and their concentration risk. Affirm’s Max Levchin framed his company’s Nevada ILC application as a long-term play for “regulatory clarity” rather than near-term growth.

An Open Door: “Many fintechs and blockchain companies especially did not really have a hope or a prayer of obtaining a bank charter during the Biden administration,” Alt told The Financial Brand. “But they are thinking strategically now and trying to go for the window of opportunity now that it’s open.”

Will regulators keep saying yes?

Credible arguments run both ways, and the outcome will likely be decided application by application.

The argument for continuity is strong. Comptroller Jonathan Gould has called the application boom “a return to the norm for the OCC,” arguing the surge “signals healthy competition, a commitment to innovation and should be encouraging to all of us,” and has blamed years of “anemic chartering” for gaps in credit access. FDIC Chair Travis Hill unfroze the ILC pipeline his predecessors had left dormant and has said a fintech holding deposits inside a regulated bank may pose less risk to the insurance fund than one scattering deposits across complex partner arrangements. Ford, GM, Stellantis and Edward Jones approvals establish live precedent that the FDIC will insure new ILCs, the very question that stalled the class for 15 years.

But there’s a case for caution, too. The Independent Community Bankers of America and the Bank Policy Institute jointly urged the FDIC to reject Affirm’s application and to freeze all ILC approvals until Congress closes what they call the “ILC loophole,” arguing such banks escape consolidated Federal Reserve supervision while leaning on nonbank parents. Senators John Kennedy and Andy Kim have reintroduced the Close the Shadow Banking Loophole Act (S. 3734) to do exactly that. And the OCC itself fired a warning shot in June, publicly reminding applicants it can return filings as “materially deficient.” “The OCC has been getting bad applications from applicants who assume, in the current environment, they don’t have to do the hard work of designing a credible business plan,” Alt said. These reviews routinely run 12 to 18 months, meaning applications filed today may be decided by a differently constituted FDIC board, in a different political moment — and the picture sharpens: the window is real, but it is neither unconditional nor guaranteed to outlast the administration that opened it. Well-capitalized, mono-line lenders with seasoned portfolios and experienced bank management are positioned to get through; thinner applications may simply run out the clock.

Mission Lane: the most interesting filing of the year

Klarna got the headlines, but Mission Lane’s April 2026 filing is also interesting. The Virginia-based issuer, spun out of LendUp in 2018, now serves more than three million cardholders with credit lines of $300 to $3,000 for near-prime and subprime borrowers. Mission Lane applied to the OCC for a CEBA credit card bank charter. It was the first credit card bank charter application in roughly 20 years, according to Michele Alt, whose firm advised on it.

The CEBA charter, a 1987 creation, is a limited-purpose national bank that can issue credit cards nationwide but cannot take demand deposits or deposits under $100,000 (except as secured-card collateral) and cannot make general commercial loans. Its parent escapes Federal Reserve holding-company supervision, and more importantly, it can export its home state’s interest rates to customers in every state.

This is favorable timing for Mission Lane, specifically, due to four factors:

1. Regulatory receptivity to novel charters. A charter type dormant for two decades only gets dusted off when agencies are visibly approving unusual structures. In 2026, they are.

2. This limited charter fits the business. Mission Lane does one thing: credit cards. It doesn’t need (and doesn’t care to be examined for) the full universal-bank toolkit an ILC or national charter implies. A limited charter means a narrower application and, plausibly, a faster path.

3. Its partner-bank model is under structural pressure. Mission Lane originates through Utah’s TAB Bank and WebBank, exporting Utah rates to other states. This is the very “rent-a-bank” architecture that state legislatures and consumer advocates keep attacking. A national credit card bank exports rates under the National Bank Act in its own name, taking that legal risk largely off the table.

4. Funding economics. Subprime card books are expensive to fund through securitization. Large time deposits, which CEBA banks may accept, are cheaper and steadier — a durable margin advantage in a segment where funding cost is the whole game.

There’s also a layer of competitive necessity worth noting. If Klarna and Affirm become banks while Mission Lane remains a borrower in the wholesale markets, it fights the next decade at a structural cost disadvantage.

Why is Upstart taking the harder road with a de novo filing?

While Mission Lane plays the specialized CEBA angle, Upstart went the other direction entirely. In its March 2026 de novo filing for Upstart Bank, the company applied for a full national charter under a traditional Bank Holding Company framework, voluntarily signing up for OCC, FDIC, and Federal Reserve oversight all at once. That’s the most supervision available in Washington, and Upstart asked for it.

We covered the filing when it landed in March, and the economics explain the choice. Upstart currently operates through 248 state licenses and roughly 100 bank partners, an infrastructure Morgan Stanley estimates costs $200 million a year, or about $135 per loan. A single federal charter cuts that to roughly $50 million. That’s $150 million in annual savings before Upstart changes anything else about how it operates.

The funding side is the bigger prize. Upstart keeps about 14.6% of originated loans on its balance sheet, funded through warehouse lines and securitization, the most expensive money in the room. Swap that for deposits and Morgan Stanley models another $67 million in net interest income versus 2027 consensus. Combined, savings plus income reach $217 million, roughly a 50% upside to 2027 adjusted EBITDA. The BHC route also gives Upstart something the ILC path chosen by Affirm doesn’t: a broader product set and deposit funding as a backstop when securitization markets seize up, the same playbook LendingClub has been running since 2021.

Then there’s the narrative layer. Pure fintech lenders trade at compressed, cyclical lending multiples, and a tech-driven deposit engine gives Upstart a story to tell about being a technology ecosystem rather than a balance-sheet-exposed lender. Klarna is attempting the same repositioning by calling itself a spend-centric business. But unlike the pure story stocks, Upstart filed with $217 million of modeled EBITDA improvement attached. Whether analysts reward the narrative or just price it like a bank, the cost savings clear either way.

Key takeaways for marketers in lending

At face value, this uptick could seem like a dry regulatory development. But for marketing and growth leaders at fintechs and non-bank lenders, it could become a looming distribution shakeup. Here’s what to prepare for:

• Affiliate and comparison channel crowding: Expect immediate deposit-side pressure. While Klarna, PayPal, and Upstart spin up native, chartered savings products, they will likely begin aggressively marketing them into the exact same affiliate networks and financial comparison channels you buy traffic from.

• Near-prime segment encroachment: As chartered specialists like Mission Lane leverage their newfound regulatory advantages to go after the 70 million underserved Americans traditional banks abandoned after 2008, non-bank lenders face a formidable competitor holding a native compliance moat.

• Sponsor bank disruption and tenant churn: Anticipate a shakeup across legacy partner networks as their largest anchor programs migrate to native charters. As historic fee income dries up, these sponsor institutions could be forced to either absorb early-stage programs or pivot to building competing direct-to-consumer lending brands of their own.

A final word of wisdom from Michele Alt: against roughly 4,000 incumbent banks, the new entrants are “tiny,” and will not “go toe-to-toe with the megabanks” immediately. “The thing to watch for is how they grow over the next, say, five years.” The brands filing this year already own the customer’s phone screen. Now they’re coming for the balance sheet. The (maybe) five-year window to respond on brand, trust and relationship starts closing now.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you.

Sources

• Klarna press release: Klarna submits application for U.S. banking license (Jul. 6, 2026)

• Banking Dive: Mission Lane applies to become a bank (Apr. 22, 2026)

• American Banker: Credit card issuer Mission Lane applies for bank charter

• Affirm: Affirm submits applications to establish industrial loan company (Jan. 23, 2026)

• PayPal Newsroom: PayPal submits applications to establish an industrial bank (Dec. 15, 2025)

• Revolut: Revolut files U.S. bank charter application (Mar. 2026)

• American Banker: Dutch neobank bunq reapplies for a U.S. bank charter (Jan. 2026)

• Banking Dive: Charter application boom a ‘return to norm’ for OCC: Gould

• Banking Dive: FDIC conditionally approves Ford, GM ILC charters (Jan. 2026)

• BPI & ICBA: Comment on Affirm Bank’s application for deposit insurance (Feb. 25, 2026)

• ICBA: ILC loophole advocacy and Close the Shadow Banking Loophole Act (S. 3734)

• Bloomberg: Fintechs call Klaros Group when they want bank charters (Jan. 2026)

• Marketplace: Why fintech firms like Klarna want to become banks (Jul. 7, 2026)

• Future Nexus: OCC hints at trouble for charters (Jun. 18, 2026)

• Banking Dive: Inside the explosion of banking charter applications

• The Financial Brand: Fintech banking suddenly advances on multiple fronts

• FinTech Futures: OCC conditionally approves Mercury charter application

Hey Toaster Readers,

This week is sponsored by New Market Growth.

With the slow news cycle and the July 4th holiday, we decided to reflect a bit more on one story that recently dropped. We think it was easy to skip but there there is something deeper at play that others might appreciate.

Last Tuesday, LendingClub officially ceased to exist and rebranded to Happen Bank. We covered the initial announcement in April, but the dust has settled and we wanted to dig into the strategy underneath. This is one of the clearest examples we have seen of a lender picking a specific customer segment, the “Motivated Middle,” and engineering every product and reward around them. If you market lending or deposit products, you will want to spend five minutes unpacking how Happen ties its rewards directly to profitable customer behaviors.

Let’s get toasting!

(Don’t miss our First big Toaster Summit)

Affiliate Marketing Summit for Lenders and Publishers

Proudly Sponsored by Experian & Engine by Gen

We have a new site! And our Day 2 experience (which has much smaller capacity) is selling faster than we anticipated.

LendingClub Became Happen. The Real Story Is Who It’s Chasing.

Last Tuesday, Scott Sanborn rang the Nasdaq opening bell and LendingClub officially ceased to exist. The company now trades as Happen, Inc. under the ticker HAPN, having completed both a full rebrand to Happen Bank and a stock listing switch from the NYSE to Nasdaq. [American Banker]

We covered the announcement when it dropped in April. So why come back to it now that the paint is dry? Because to us, there’s a more interesting story layered under the rebrand.

This is one of the cleanest examples we’ve seen of a lender picking a customer segment first and then engineering every product, reward, and dollar of funding around that one person. If you market lending or deposit products for a living, this is worth 5 minutes unpacking.

First, what Happened to Lending Club?

Quick scale check: Happen reports 5M+ lifetime members and $100B+ in lifetime originations (sourced from their 2025 10-K).

For readers who know LendingClub as “the P2P lending pioneer”: that company hasn’t existed for years. Happen is a nationally chartered digital bank running a marketplace bank model with two revenue engines.

The first engine is the balance sheet. Deposits fund loans held for investment, generating net interest income. The second engine is the marketplace. Happen originates loans and sells them to investors, collecting origination fees, servicing fees, and gains on sale capital-light fee income.

The loan book is overwhelmingly consumer: unsecured personal loans (debt consolidation is the core franchise), auto refinance, point-of-sale financing, and a newly launched home improvement vertical. A small commercial book focuses primarily on active SBA lending, while existing commercial real estate loans and equipment leases have ceased origination and are being retained to maturity.

In Q1 2026, originations were split roughly down the middle, 52% sold to marketplace investors and 48% retained, which matters for the strategy below. Both engines get stronger when the same borrower gets cheaper to fund and safer to underwrite.

Happen focusing on the “Motivated Middle”

Happen’s own words: it’s a bank built for “high-FICO, high-income, digitally savvy consumers actively managing their financial lives.” Not the underbanked. Not private-banking clients.

Prime borrowers who still actively use credit.

Look around the industry and you see why this lane was open.

Chime and Dave built their businesses on low-to-moderate-income consumers — overdraft protection, early wage access, interchange-funded economics. SoFi staked out high earners with student loan refi, wealth management, and premium lifestyle branding. Chase, Citi, and BofA sit on trillions in near-zero-cost deposits but don’t always succeed in securing the consumer’s lending business.

The middle, the person with a 740 FICO who carries a $25K consolidation loan and a real savings balance, was nobody’s primary target. Happen is planting a flag there.

The sequencing question (Chime in reverse)

Chime did the hardest thing in consumer banking first: winning the direct deposit relationship, then expanding into credit. Happen is running the opposite play, and it’s the same one SoFi, Capital One, and Amex ran before it. Lend first, because that’s where the money is (and, frankly, because a lending license is far easier to get than a bank charter). Then use the loan relationship to earn your way into deposits and checking.

Loan-first is the more logical sequence for profitability.

But it leaves Happen with a real challenge: it doesn’t own the primary banking relationship yet, and the deposit market is brutally crowded. Which distribution channels it picks to close that gap is the thing to watch over the next few quarters.

But first, a quick note from our sponsor:

New Market Growth

New Market Growth helps lenders build and scale affiliate marketing programs on channels like Credit Karma, Experian Marketplace, Lending Tree, Bankrate, Credible, and many more. NMG clients spend $50-$100MM per year in affiliate channels, and the founding team (one of whom is Free Toaster co-founder Carlos Caro), have advised in excess of 50 lenders over the course of their corporate and agency careers.

If you’re a Free Toaster Reader at a lender that spends over $500K per month in affiliate marketing, we’re offering a free, 90-minute audit of your affiliate marketing program. After research we’ll conduct on our side, we’ll book time to share the strengths, weaknesses, and opportunities we observe in your program.

Outside eyes could help unlock the growth you’re looking for in H2 2026.

Email carlos@newmarketgrowth.com with subject line “90-minute audit” and we’ll contact you to get the preliminary information we need to get to work.

The flywheel: rewards that pay for behaviors, not balances

This is where the strategy gets concrete. Happen’s two deposit products are engineered so that every reward dollar buys a behavior that improves Happen’s own bottom line.

LevelUp Savings (launched August 2024) pays a higher APY (currently 4% APY) to members who deposit at least $250/month, rewarding the growth behavior instead of the raw balance. It’s built 80K+ accounts and $3.5B in deposits, and savings customers visit 30% more often than the prior product’s.

LevelUp Checking (launched June 2025) pays 2% cash back on on-time personal loan payments made from the account, plus 1% back on gas, grocery, and pharmacy debit purchases. It simultaneously pulls low-cost deposits in, moves loan servicing inside Happen’s ecosystem, and pays the borrower to do the exact thing that keeps charge-offs down. Since launch, account openings are running 6x the prior checking product, and 60% of accounts come from existing members. The cross-sell is seemingly working.

Now the number that left us scratching our heads a bit.

Happen discloses that 70% of LevelUp Savings holders, representing ~95% of balances, hit the $250 monthly threshold. Do the basic math they invite: 95% of $3.5B spread across 70% of 80K accounts works out to an average balance near $59K among threshold-meeting savers. (The disclosed account and balance figures are as of March 31, 2026)

That’s not a mass market audience.

That’s an affluent saver earning 4.00% APY, which raises a question Happen hasn’t answered: why is that customer with $59K in savings taking out a $20–30K personal loan? Either the savers and the borrowers are different pockets of the member base, or the “prime borrower who still borrows” is wealthier than the debt-consolidation stereotype suggests.

TOASTER’S TAKE

The rewards program is designed thoughtfully for the audience (and the P&L). Every Happen incentive pays for a behavior tied to a P&L line (deposit cost, on-time payment, balance growth).

The deposit business doesn’t reduce CAC, it raises the CAC you can afford. When 60% of new checking accounts come from existing borrowers, the lifetime value of a new loan customer goes up. That lets you bid more for media and buy growth on the margin. At scale, the Fortune 500 banks of the world happily push CAC up as long as the marginal customer is profitable. The question for Happen: is that what the next two quarters of marketing spend will show?

The metrics we want to understand this better: checking account volumes (they gave us savings, why not checking?), cross-hold rates, and blended CAC. Until then, we have a number of questions: How many of those affluent savers came from the loan base versus straight rate-shopping on 4.00% APY? Does the flywheel actually convert borrowers into primary banking relationships, or just into high-yield deposits?

Happen’s bet?

That the most overlooked customer in consumer finance is the prime saver who still borrows — and that you win them by paying them to behave in ways that improve your deposit base, your loss curves, and your cross-sell rates all at once.

Only time will tell and the proof will show up in the CAC and cross-sell numbers.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.

Hey Toaster Readers,

This week is sponsored by our friends at Fintel Connect.

The news cycle was light this week so we dropped an exclusive editorial on why personal finance algorithms are about to make traditional landing page optimization completely obsolete. The punchline? Consumers are going to stop choosing their own loans and let AI agents handle decisions for them. Is your lending brand optimized to pitch a machine reader instead of a human brain?

Plus, home equity card startup Trovy just locked down a cool $25M and SoFi rolled out new AI tools to be your financial coach and to automate retail investing.

There’s a lot to unpack. Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

PS: To support us, please subscribe or forward this email to 1 of your colleagues!

Mark Your Calendars For September 23rd!

Affiliate Marketing Summit for Lenders

Proudly Sponsored by Experian & Engine by Gen

Interest in our inaugural edition of The Affiliate Marketing Summit for Lenders is heating up 🔥. Thank you!

So far, we have senior leaders from the following organizations registered: Experian, Engine by Gen, Credit Karma, Bankrate, LendingTree, Credible, QuinStreet, Bulldog Media Group, Lending Club, SoFi, Pagaya, One Main Financial, Perpay, Happy Money, Atlanticus, LendingPoint, SuperMoney, Debbie, Portola, PrismData, FICO, and more.

Learn more about the event here!

If you’re a senior leader that buys or sells affiliate media, this is the one event this year you won’t want to miss.

The room is capped at 150 guests and early-bird pricing is active, so consider registering today!

What happens when consumers delegate financial decisions to agents?

Last month, we tracked how ChatGPT is becoming the new distribution channel for personal finance, with Plaid unlocking transactions and Credit Karma plugging in approval odds. We felt a shift like this required an editorial to unpack the ripple effects it’s creating.

The biggest change in personal finance isn’t the AI technology itself. It’s the fact that consumers are going to hand the keys over to AI, letting algorithms choose their loans based on pure data, goals, and constraints. The psychological game of human persuasion is out. The new job is convincing a rational, data-loaded machine to pick you as the best option.

The lending funnel isn’t dying, but your buyer is changing completely as more consumers trust agents to act on their behalf.

Will consumers actually hand over their bank data to a machine? History says yes. Mint hit 20 million users at its peak just by putting spreadsheets in the cloud. When people see value, they share. The question is who’ll be there to earn the trust when agents are eventually adopted by the average consumer.

If you keep optimizing for human emotion, you’re tuning a radio nobody is listening to. Read the full editorial to learn how to set up your brand for the machine era.

Hint: the key is building trust with the consumer before they prompt the agent.

[How Lenders Win When AI Calls the Shots]

Sponsored by Fintel Connect

56% of U.S. bank and credit union executives still build marketing budgets from last year’s numbers. Are you?

Most financial institutions are under pressure to prove which channels drive funded accounts, loans, deposits, and long-term customer value. Yet new research from Cornerstone Advisors and Fintel Connect found that more than half of U.S. bank and credit union executives still determine marketing budgets based on the previous year’s spend.

That may feel practical, but it can leave growth teams overfunding top-performing channels, underinvesting in higher-performing ones, and walking into budget season without a clear cost-per-outcome model.

Fintel Connect’s latest mini guide, Why Financial Marketing Budgets Still Start With Last Year’s Number, shows how financial leaders can shift from legacy budget planning to an outcome-based investment model built around measurable acquisition impact.

Get the guide and rethink how every marketing dollar is being tied to acquisition impact. Read the full guide here

Home equity credit card startup Trovy closes $25m raise

Trovy closed a $15 million Series A funding round, bringing its total capital to $25 million and boosting growth for the financial technology platform that replaces expensive consumer debt with home equity-backed financing. Left Lane Capital led the investment, while existing seed investors Kleiner Perkins, DCM Ventures, and Camber Creek also jumped back into the mix. The startup aims to address a "record" pile of US household debt by helping homeowners tap into their existing equity instead of paying high interest rates. By operating as a licensed lender, Trovy bypasses traditional bank partnerships to give consumers direct ownership of their borrowing experience. Their home equity-backed credit card runs on the Mastercard network via Cross River Bank, and the team plans to launch a flexible loan product called 1Loan this summer. They are also building a comprehensive homeowner hub to manage everything from maintenance reminders to insurance policies. [Fintech Global]

SoFi Launches AI Tools to Coach Your Finances and Automate Your Investments

SoFi, the everything app for digital financial services, recently rolled out new AI tools to help users get a better grip on their money. The company launched SoFi Coach, a chat-based assistant that gives you personalized advice on budgeting, saving, and tackling debt. Users securely connect their accounts from more than "12,000" financial institutions to receive real-time answers about their spending habits and payoff options. During early testing, the tool helped users take "tens of thousands" of financial actions, and "nearly 70%" of engaged testers took meaningful steps to improve their finances. Beyond basic budgeting, SoFi also introduced Composer by SoFi to help retail investors build and automate rules-based trading strategies. You just describe your investment idea in plain English or browse "over 2,000" community-built options, and the platform turns it into a fully functioning plan in minutes. Instead of drowning in spreadsheets or paying a pricey advisor, you can let these straightforward assistants do the heavy lifting for your financial future. [SoFi Coach] [SoFi Composer]

What’s up with banking’s marketing ROI gap?

Banks, credit unions, and lenders are under pressure to acquire more customers, grow funded volume, and prove marketing’s impact. But when attribution is unclear, it becomes harder to know which channels are driving real growth and which ones are simply getting the credit.

If your marketing channels are struggling to perform against a changing market, it’s time to revisit how you measure success. Join Carlos, along with a panel of industry experts on July 13th at 10 AM PST / 1 PM EST to decode the marketing ROI gap in banking. Carlos, alongside leaders from Fintel Connect, Peak Bank, and Pagaya, will debate which channels are actually driving funded growth, why lead quality matters more than volume, and how to make smarter budget decisions.

When: July 13, 2026 | 10AM PST/ 1PM EST
Where: Register here.

News Pod #23 - Pagaya Sues Klarna for (Allegedly) Stealing Its Underwriting Model

Pagaya filed a lawsuit against Klarna for (allegedly) stealing is underwriting. Carlos & Nick discuss the implications for fintech marketers that share their underwriting policies with affiliate marketing platforms.

Catch us on Apple Podcasts, Spotify, Substack, or your favorite player.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Spot something worth sharing with your team? Drop this week’s edition in their inbox.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.

Last month I wrote that ChatGPT became a distribution channel for personal finance. Plaid unlocked the transaction layer, Credit Karma plugged in approval odds, and the personal finance super app started snowballing.

This aftermath of this development is less about the event itself and more about what you do with your distribution program because of it.

Here is the one idea every lending CMO needs to reorganize around. Consumers are about to delegate the decision to AI (the machine). They will arm an LLM with their transaction data, their goals, and their constraints. Then they will trust it to pick.

The old job was convincing a person to choose you: a psychological one. The new job is convincing a machine, loaded with context, to select you as the best among several reasonable options.

That one shift changes everything downstream. The game gets rational. It stops being emotional.

Your funnel survives. Your audience changes.

Good news first: the lending funnel does not disappear. Awareness, consideration, application, approval, funding: all of it still applies. However, who (or what) you are speaking to at every stage changes completely.

When an agent shops on a consumer’s behalf, it’s weighing the same things your funnel always measured. It just calls them something else, and evaluates the same questions with different logic.

1. How relevant is this product to this specific person? That is your click through rate.

2. How much information does the lender ask for, and how much do I already have? That is your application rate.

3. How likely is this person to actually get approved? That is your approval rate.

Your scorecard is intact. You’re simply optimizing it against a machine reader instead of a human one. Lenders who internalize that early will get a head start.

Changing dynamics in distribution channels

Here is how I see the major channels and capabilities moving.

The three “up” rows are where the real work happens.

Application page optimization is fading out. The friction tradeoff will replace it.

For two decades, the application page was sacred ground. You A/B tested button colors, trust badges, and form lengths to squeeze out conversion. When an autonomous software agent handles the form submission process, that front-end design work loses its utility.

What replaces it is harder and more valuable.

The new lever is friction management.

Specifically, how few incremental questions you ask, and how much agent supplied data you are willing to accept. A lender who says “I will take the Plaid verified income the agent already has” beats a lender who re-asks for a pay stub or W2. Less friction, higher application rate.

But there’s real tension here.

Lower friction can mean lower quality fraud and risk decisions. Accepting data you did not collect yourself is a fraud and credit risk call, not a simple UX tweak. The winning lenders are the ones who find the optimal friction point: easy enough to convert, but rigorous enough to keep fraud and bad credit out.

That tradeoff lives at the intersection of marketing, underwriting, data science, and fraud. If you already have a sharp cross functional team managing a channel like Credit Karma, that is the team. The LLM channel might just demand more of that same coordination.

The new top of funnel job is to plant the branded prompt.

This is where the emotional work of connecting to the human happens. Not on a landing page, but before the prompt itself is typed.

Picture the winning prompt.

A consumer opens their LLM assistant and says “here is my transaction data, here is what I want to accomplish, tell me what Chase has for me, then compare it to the rest of the market (unsaid: because I bank with Chase and I trust them)”

If your brand is not in that query, you are already a step behind. The agent might still surface you. But you did not earn the invitation from the human.

So a key job-to-be-done for your brand marketing is to get the consumer to invoke you by name when they put the LLM to work. You do that the only way you ever could. By being genuinely useful. Educate, entertain, inspire, and be trustworthy enough to be memorable.

There is no shortcut into the prompt.

Feed the super app. Do not try to become it.

Most lenders will wonder if they should build the super app themselves. I don’t think they should.

I would not trust a financial products super app built by a Fortune 500 bank brand. Neither would you. We would read it as self-serving, a storefront dressed up as an advisor. The trust goes to the independent brand that charges me a subscription and promises objective, data-based recommendations for my specific situation.

I think the winning LLM surface in financial services is subscription funded, not ad funded. The moment recommendations are paid for by advertisers, consumers will assume the payout shaped the answer. A surface that consumers pay for is a space they can trust.

So the lender’s job is not to win the surface.

It is to be the offer the surface picks. Feed the super app your real terms, your certainty, your machine readable offer, and your brand.

The machine is going to do the rest.

A key assumption

This whole thing depends on consumers handing an LLM the keys to their bank and bureau accounts.

I’m betting they will.

Consumers already gave their accounts to Mint a decade ago and to Monarch today. Mint had 20 million registered users at its peak, built on nothing but a spreadsheet in the cloud and a promise to make sense of your money. When people see value in sharing data, they share it.

The open question is which brand earns the finance-specific trust. Maybe it’s ChatGPT or Claude.

Maybe a purpose built finance assistant has to emerge first. The timing depends entirely how long it takes the provider to earn the trust.

I’m guessing we’ll start to see really kick-ass apps like this (with 5M+ consumer scale), in the next two years.

The one move to make this quarter

If you do one thing, start building your brand.

Too many fintech-lender CMOs are addicted to arbitrage. Spend a dollar on paid search, paid social, or an affiliate placement. Make two back. That muscle is going to atrophy, because the LLM is built to be immune to it.

Think about what LLMs do well: processing a mountain of information to make an objective, data-based decision.

Media arbitrage does the opposite.

It interrupts the consumer to put your thing in front of them and hopes proximity and clever copy sways the choice. LLMs are engineered to ignore exactly that.

Attention is getting harder to buy.

The assets that earn it are a brand the consumer already trusts and an offer that genuinely wins on merits. Both take years or decades to build.

Closing thoughts

No channel is safe forever.

Direct mail held up for five decades, and it’s at risk in a world where AI makes product recommendations frictionless and accurate.

I’m not telling you to kill anything today. What I am saying is to expect legacy channels to deteriorate slowly as humans start figuring out helpful LLMs will be in the context of shopping for financial products.

The lenders who win will stop trying to convince the human, and shift their energy toward winning the agent the human sends in their place.

The marketing funnel is the same, but your (new) buyer is a machine (or a human with a strong bias for doing what the machine says). And the only durable advantage is being the best real answer to the question the consumer actually asked.

That’s where the game is going now.

https://www.thefreetoaster.com/p/pagaya-sues-klarna-for-allegedly

*****

The Affiliate Marketing Summit For Lenders
San Francisco - September 23rd & 24th

150-person, curated room

Early bird tickets end August 1
Learn more: events.thefreetoaster.com

*****

Sign Up For Our Newsletter

The Free Toaster Newsletter ships every Wednesday at www.thefreetoaster.com, curating the biggest stories at the intersection of consumer lending, marketing, and technology.

******

Please Support Our Sponsors

Bulldog Media Group:

Bulldog Media Group is a leading performance marketing company that specializes in online customer acquisition for clients in the financial services industry. Since 2000, they have focused on financial services digital marketing as their core niche. 

https://www.bulldogmediagroup.com/

Spinwheel:

Reduce friction in your lending application with just two fields—phone number and birthdate. Spinwheel’s APIs boost application rates by 20-30% while also providing real-time credit data and seamless payment processing. Want to see it in action? Connect with their Head of Growth for a demo!

https://spinwheel.io/partner/?utm_source=freetoaster&utm_medium=podcast&utm_campaign=june

Fintel Connect

Drive thousands of new accounts and billions in deposits with the only partner marketing solution built for fintech and banking – your all-in-one affiliate platform, partner network, agency, and marketing compliance engine.

https://partner.fintelconnect.com/get-to-know-fintel-connect?utm_campaign=13897733-2025%20Partners&utm_source=The%20Free%20Toaster&utm_medium=podcast

Hey Toaster Readers,

This week is sponsored by our friends at Spinwheel.

Pagaya just sued Klarna for allegedly stealing its AI underwriting model, building a competing one with four years of proprietary data, then dropping Pagaya the moment it no longer needed them. Partnership teams, take notes.

Also this week: Visa hooks into OpenAI, Experian moves loan shopping into ChatGPT, Klarna launches a high-yield savings account, and Visa and Mastercard take aim at Circle’s stablecoin dominance.

There’s a lot to unpack. Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

PS: To support us, please subscribe or forward this email to 1 of your colleagues!

Mark Your Calendars For September 23rd!

Affiliate Marketing Summit for Lenders

Proudly Sponsored by Experian & Engine by Gen

Interest in our inaugural edition of The Affiliate Marketing Summit for Lenders is heating up 🔥. Thank you!

So far, we have senior leaders from the following organizations registered: Experian, Engine by Gen, Credit Karma, Bankrate, LendingTree, Credible, QuinStreet, Bulldog Media Group, Lending Club, SoFi, Pagaya, One Main Financial, Perpay, Happy Money, Atlanticus, LendingPoint and FICO.

Learn more about the event here!

If you’re a senior leader that buys or sells affiliate media, this is the one event this year you won’t want to miss.

The room is capped at 150 guests and early-bird pricing is active, so consider registering today!

Pagaya Sues Klarna Over Alleged Trade Secret Misappropriation

On IPO day, September 10, 2025, a reporter asked Klarna CEO Sebastian Siemiatkowski directly: when assessing loan risk, you’re doing that yourself? Not outsourcing it?

“Nope,” he said.

According to a lawsuit filed in Delaware federal court, that was false. And page 5 of the complaint shows exactly where Pagaya intends to prove it.

Pagaya Technologies, the AI underwriting firm that powered Klarna’s subprime point-of-sale lending since 2022, filed suit on May 13, 2026 alleging trade secret misappropriation and breach of contract. The core claim: Klarna used Pagaya’s proprietary ML credit model and the years of real borrower performance data it generated to build competing underwriting capabilities internally, then terminated the partnership once it no longer needed Pagaya.

The market Klarna wanted access to is not small. Per TransUnion data cited in the complaint, 128 million Americans used BNPL in 2025, up from 86.5 million the year before. The majority are subprime or deep subprime, exactly the segment Klarna could not profitably underwrite before Pagaya.

Before the partnership, the complaint states plainly, Klarna lacked the technical capability to underwrite this borrower segment. Pagaya invested over $100 million developing the model. By May 2025, it had launched a $1B+ securitization program with Klarna as the sole originator. By March 2026, Klarna had quietly signed a deal with a new financing partner and pulled the plug, reportedly while still telling Pagaya and WebBank the existing deals were “good to move forward.”

What Pagaya is actually fighting to protect breaks into three categories, laid out clearly on page 16 of the complaint.

The model itself, the data it generated across four years of live lending decisions, and the operational and structural knowledge required to package subprime POS loans into rated ABS deals. That third category is the one people underestimate. Getting investment-grade ratings from Kroll on a subprime consumer ABS requires having actually done it. Pagaya had. Klarna, allegedly, learned how by watching.

The ending was abrupt. Page 37 shows how fast it moved.

On March 25, 2026, Klarna notified Pagaya it was terminating the license and commitment agreements on 180 days’ notice and would not enter any new financing arrangements. No transaction-specific explanation. Klarna had already signed with another counterparty before making the call.

A few things worth thinking through for partnership and lending teams:

• The complaint calls Klarna’s alleged conduct “unlawful distillation,” a concept borrowed from AI/ML, where using model outputs to train a competing model exceeds the scope of a limited license. Expect this framing to show up in future fintech data-sharing agreements.

• The fintech that signs the merchant deal isn’t always the one doing the underwriting. Klarna owned the Walmart relationship. Pagaya owned the credit intelligence.

• Klarna’s IPO filings described its underwriting as proprietary. That disclosure question isn’t part of this lawsuit, but it won’t stay invisible.

• Pagaya is asking for injunctive relief that could force Klarna to stop using any model built with Pagaya’s data. If granted, that hits Klarna’s U.S. lending business directly.

Early days here. Klarna called the suit “without merit” and says termination was contractually permitted. No answer filed yet, and discovery hasn’t started. The internal communications around model training are where this gets interesting. [Court filing] [Banking Dive]

Sponsored by Spinwheel

With a single call to our simple, dev-friendly APIs, Spinwheel offers the only comprehensive connection to your consumers’ financial accounts.

Spinwheel delivers PII, real-time, verified account data, and the ability to make payments across all major debt categories – all within your brand’s experience.

With many happy customers, including:

Visa Partners with OpenAI to Power the Next Generation of AI Commerce

Visa plugged its payment network directly into OpenAI. The partnership, announced at the Visa Payments Forum in San Francisco, gives OpenAI access to Visa’s global network, tokenization infrastructure, and real-time fraud monitoring to support agent-initiated purchases. Transactions run within user-defined spending limits and merchant category controls, using tokenized credentials with real-time authorization. Visa is building the checkout layer for a world where consumers stop browsing and start delegating purchases to AI agents.

The more pressing question is what happens to affiliate marketing, paid search, and comparison sites if AI agents become the primary way consumers discover and buy financial products. Visa’s Chief Product Officer said AI will transform commerce more profoundly than the internet or mobile ever did. Card issuers and lenders have spent years optimizing for Google and Credit Karma. The next distribution problem may be getting your product surfaced, compared, and recommended by an AI agent before a human ever sees it. [VISA]

Klarna Launches High-Yield Savings Account, Turning Everyday Spend Into Everyday Savings

Klarna just launched a high-yield savings account in the U.S. The product is FDIC-insured through WebBank, carries no minimum deposit, no monthly fees, and opens at 3.28% APY. Klarna already holds over $12.3 billion in deposits across eleven European markets, so the U.S. launch is a proven model in a new geography, not a product experiment.

The savings account is the third piece of a product suite we’ve been watching come together in real time. In March, we covered Klarna‘s card hitting 5 million active users globally, pacing at roughly 270,000 new cardholders a month. Around the same time, Klarna reported scaling past $17 billion in U.S. volume. Now comes savings. BNPL built the top of the funnel. The card deepened the daily relationship. Deposits take it further, giving Klarna a reason to be in the app on days when nothing is being purchased. Together with the Klarna Card and Klarna Balance, the savings account is designed to create one place to manage the full picture of everyday financial life. That’s the full-stack consumer finance playbook, and Klarna is executing it faster than most competitors expected. [Klarna]

Visa, Mastercard $38B Swipe Fee Settlement Wins US Judge’s Approval

A federal judge granted preliminary approval to Visa and Mastercard‘s $38 billion settlement with merchants on June 9, resolving a case grinding through courts since 2005. The deal cuts swipe fees by 0.1 percentage points for five years and caps standard consumer rates at 1.25% for eight years. Swipe fees totaled nearly $119 billion in 2025 alone, so even modest rate adjustments move serious money across the ecosystem.

The headline number isn’t the $38 billion. It’s the “Honor All Cards” rule dying. Merchants can now decline premium rewards cards at checkout while still accepting standard credit and debit. That’s a direct hit on the interchange economics that fund co-brand programs, cashback offers, and acquisition campaigns. Issuers built entire customer acquisition machines on the assumption that rewards cards would always get accepted. That assumption just got a lot less certain. The Electronic Payments Coalition, which includes Bank of America, Capital One, Chase, and Citibank, backed the settlement, but the National Retail Federation remains opposed and plans further challenges. A fairness hearing still needs to happen before Judge Cogan grants permanent approval, so the uncertainty hanging over interchange economics isn’t going away anytime soon. [Reuters]

News Pod #22 – JD Power Sues Chime, Plus the Big Questions Facing Affiliate Marketing

In the latest The Free Toaster News Pod, we break down JD Power’s lawsuit against Chime over its “America’s #1 choice for banking” campaign and what the case could mean for fintech marketing claims, brand partnerships, and customer trust.

Carlos and Nick also preview the upcoming Affiliate Marketing Summit for Lenders, discussing the future of search, AI-native brands, human signal in a world flooded with content, lender unit economics, cross-channel attribution, and whether AI strengthens or replaces the partnership function.

Catch us on Apple Podcasts, Spotify, Substack, or your favorite player.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Why Visa And Mastercard Are Building The Stablecoin That Could Sink Circle

Stripe, Visa, and Mastercard are reportedly building a shared stablecoin platform to take on Circle and Tether, which together control roughly 80% of the $325 billion stablecoin market. The moves have been telegraphed for over a year. Stripe paid $1.1 billion for stablecoin infrastructure firm Bridge. Mastercard spent up to $1.8 billion acquiring BVNK. Visa is already settling across nine blockchains at a $7 billion annualized rate. These aren’t exploratory bets. They’re the pieces of an issuance stack being assembled in real time.

The threat to Circle isn’t technical. Circle already solved the engineering. The problem is distribution, and that’s the one thing Visa and Mastercard have spent six decades perfecting. Visa runs more than 130 stablecoin-linked card programs across 50+ countries. Mastercard has direct bank and merchant relationships at a scale Circle‘s IPO couldn’t buy. The GENIUS Act (the federal stablecoin regulatory framework enacted in 2025) makes this worse for Circle: once a compliant dollar token becomes a commodity any licensed issuer can mint, the contest shifts entirely to who can place it in front of the most merchants and consumers. That’s not a race Circle is equipped to win. [Forbes]

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Spot something worth sharing with your team? Drop this week’s edition in their inbox.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.

Carlos & Nick discuss the Affiliate Marketing Summit for Lenders, September 23, sponsored by Experian and Engine by Gen. We talk about the open questions shaping the day: the future of search, who's native to AI, the important of human signal in a content flood, lender unit economics and the new bank formation wave, cross-channel attribution, and whether AI improves or replaces the partnership role.

The Affiliate Marketing Summit For Lenders

150-person, curated room

Early bird tickets end August 1
Learn more: events.thefreetoaster.com

*****

Sign Up For Our Newsletter

The Free Toaster Newsletter ships every Wednesday at www.thefreetoaster.com, curating the biggest stories at the intersection of consumer lending, marketing, and technology.

******

Please Support Our Sponsors

Bulldog Media Group:

Bulldog Media Group is a leading performance marketing company that specializes in online customer acquisition for clients in the financial services industry. Since 2000, they have focused on financial services digital marketing as their core niche. 

https://www.bulldogmediagroup.com/

Spinwheel:

Reduce friction in your lending application with just two fields—phone number and birthdate. Spinwheel’s APIs boost application rates by 20-30% while also providing real-time credit data and seamless payment processing. Want to see it in action? Connect with their Head of Growth for a demo!

https://spinwheel.io/partner/?utm_source=freetoaster&utm_medium=podcast&utm_campaign=june

Fintel Connect

Drive thousands of new accounts and billions in deposits with the only partner marketing solution built for fintech and banking – your all-in-one affiliate platform, partner network, agency, and marketing compliance engine.

https://partner.fintelconnect.com/get-to-know-fintel-connect?utm_campaign=13897733-2025%20Partners&utm_source=The%20Free%20Toaster&utm_medium=podcast

Hey Toaster Readers,

This week is sponsored by our friends at Bulldog Media Group.

J.D. Power is suing Chime over its recent marketing campaign, arguing that the data does not support the bank's advertising claims. Citi stopped accepting applications for its Custom Cash Card. We are also tracking new ways to borrow, with Experian launching a loan shopping tool directly inside ChatGPT and Pagaya expanding its point-of-sale loans alongside Upgrade. Plus, we look at how the CFPB worked with Bilt to make sure consumers were refunded for fees caused by a recent bank transition.

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

PS: To support us, please subscribe or forward this email to 1 of your colleagues!

A Free Toaster Event You Can’t Miss

Affiliate Marketing Summit for Lenders

Proudly Sponsored by Experian & Engine by Gen

Register NOW for early bird pricing!

J.D. Power Sues Chime Over Marketing Campaign

J.D. Power sued Chime on June 2 in federal court in New York over Chime’s “America’s #1 Choice for Banking” campaign and the line backing it up: “#1 ranking based on J.D. Power survey.” The complaint covers breach of contract, trademark infringement, and false advertising.

The whole fight is about whether the data says what the ad says. Chime says the claim is supported by publicly available J.D. Power data showing it had more new checking account openings than any other listed institution. J.D. Power says that study just tracks new account openings by category, not overall preference or who’s anyone’s primary bank, and that Chime led only in checking, with about half of those openings being secondary accounts. Chime is fighting it, calling the complaint selective and incomplete and saying it’ll defend vigorously, pointing to other accolades like Time’s #1 banking brand.

A few things worth chewing on if you do fintech marketing:

• One strong category metric isn’t a market-wide superiority claim. The space between “most new checking accounts” and “America’s #1 Choice for Banking” is basically the lawsuit.

• There’s a difference between public data and licensed-for-advertising data. J.D. Power runs a paid licensing program and says Chime’s deal was internal-use-only. That contract question is the sleeper issue here.

• Can a footnote save a headline? J.D. Power argues the disclosure contradicted the claim rather than qualifying it.

• Claims travel. The same line showed up on the homepage, in paid social, in SEC earnings materials, and in a trademark filing. Each surface is its own exposure.

• How will courts assess willfulness? Chime allegedly kept going after a cease-and-desist, and that could unlock bigger damages. (And at time of publication, Chime hasn’t changed their website).

Early days; Chime hasn’t formally answered yet and nothing’s been tested. But it’s a good one to watch for how hard ratings firms will push back on “#1” claims built on their numbers. [ American Banker][US District Court, Southern District of New York]

Sponsored by Bulldog Media Group

Reach the Borrowers Others Miss.

Bulldog Media Group specializes in connecting consumer lenders with less than perfect borrowers — a massive, underserved market that requires precision targeting to get right. With 25 years of financial services marketing experience, they deliver qualified leads through affiliate marketing, targeted email, and data-driven acquisition strategies built for this exact audience.

If you’re a lender looking to scale, these are your people.

Get Qualified Borrower Leads

Experian Brings Personal Loan Shopping to ChatGPT with New AI-Powered Experience

Experian launched a new personal loan shopping application inside OpenAI's ChatGPT platform, combining conversational tech with its marketplace data to streamline how consumers explore borrowing options through the credit reporting and financial services giant. Instead of forcing users to hop across multiple websites, this tool lets people chat their way to finding a loan. The application pulls criteria from a network of partners to simplify debt consolidation or major purchases. Lending partners like Avant expect the setup to connect users with personalized options in a far more accessible way. To lock down specific rates, users can hop from the chat window over to Experian’s main site to view pre-qualified offers without hurting their credit score. This rollout expands the firm's push to deploy financial tools at "scale", adding to an AI roster that already includes integrations on Snapchat. [Experian]

Pagaya Builds on Multi-Year Partnership with Upgrade to Expand Point-of-Sale Loans

Pagaya is teaming up once again with Upgrade. This expanded partnership is notable given the fact that the duo moves beyond basic personal loans and tackles the buy now, pay later world. Upgrade plans to plug Pagaya’s AI credit decisioning brains right into Flex Pay, its point of sale payment solution. This setup lets the companies offer flexible monthly payments to a "broader" range of shoppers right when they hit the checkout button. They plan to kick things off in the travel sector, a space where Flex Pay already partners with "thousands" of top brands. By using real time underwriting, Pagaya gives Upgrade the power to greenlight more customers quickly and responsibly. Both teams clearly want to help people make thoughtful purchases without stressing over upfront costs. [Business Wire]

Citi Surprises Cardholders by Halting Custom Cash Credit Card

Citi just surprised cash-back fans by halting new applications for its popular Custom Cash Card. For nearly five years, this card automatically helped users with up to 5% cash back on their highest monthly spending category, capping the premium perk at a $500 limit. Instead of releasing a formal public announcement, the bank simply replaced the card's product page with a brief redirection notice. Internal rumors leaked right before the shutdown, but the sudden move still caught eager applicants completely off guard. While existing cardholders can keep using their benefits for now, Citi currently funnels new shoppers toward its alternative Double Cash card. This unexpected shift leaves people wondering if the financial heavyweight plans to force product transfers down the road. [The Street]

In Case You Missed It (Weekly News Pod)

We've been writing about Cash Flow Underwriting lately. On this News Pod, we expand on what we wrote in last week’s in newsletter: Did ChatGPT Just Fix The Cash Flow Underwriting Distribution Problem?

Catch us on Apple Podcasts, Spotify, Substack, or your favorite player.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

The CFPB Works To Ensure Bilt Consumers Are Made Whole

The CFPB stepped in to make sure users of Bilt avoided financial headaches during the company's recent bank transition. A bumpy handoff to a new banking partner triggered technical glitches and annoying fees for a "limited" number of accounts. Instead of launching a slow, multi-year investigation, the watchdog group worked directly with corporate leadership to clean up the mess efficiently. Bilt proactively offered to cover any surprise overdraft or late fees tied to the digital shakeup. Recent documentation indicates that the fintech firm successfully resolved the technical bugs and got its platform back on track. The team expects to return cash to more than 500 newly identified consumers following the agency's push. Government officials will continue monitoring the cleanup until the company delivers full financial redress to every single impacted user. [CFPB]

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Spot something worth sharing with your team? Drop this week’s edition in their inbox.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.

*****

The Free Toaster is hosting the Affiliate Marketing Summit for Lenders on September 23rd & 24th in San Francisco. 

Learn more: https://events.thefreetoaster.com/

*****

The Free Toaster Newsletter ships every Wednesday at www.thefreetoaster.com, curating the biggest stories at the intersection of consumer lending, marketing, and technology.

******

Spinwheel:

Reduce friction in your lending application with just two fields—phone number and birthdate. Spinwheel’s APIs boost application rates by 20-30% while also providing real-time credit data and seamless payment processing. Want to see it in action? Connect with their Head of Growth for a demo!

https://spinwheel.io/partner/?utm_source=freetoaster&utm_medium=podcast&utm_campaign=june

Fintel Connect

Drive thousands of new accounts and billions in deposits with the only partner marketing solution built for fintech and banking – your all-in-one affiliate platform, partner network, agency, and marketing compliance engine.

https://partner.fintelconnect.com/get-to-know-fintel-connect?utm_campaign=13897733-2025%20Partners&utm_source=The%20Free%20Toaster&utm_medium=podcast

Bulldog Media Group:

Bulldog Media Group is a leading performance marketing company that specializes in online customer acquisition for clients in the financial services industry. Since 2000, they have focused on financial services digital marketing as their core niche. 

https://www.bulldogmediagroup.com/

Hey Toaster Readers,

This week is sponsored by New Market Growth.

The way people find and use credit is changing fast, and AI is driving the shift. This week, we look at how large language models are becoming the ultimate distribution channel for cash flow underwriting by turning apps like ChatGPT into personal finance super apps.

We also dive into two new industry reports. Marqeta reveals that consumers are building their own custom portfolio of credit products, while a study from BCG and FT Partners shows fintech hitting a major revenue resurgence driven by real profitability. Plus, we look at Sezzle’s latest super app expansion, including a new Pay-in-5 option that is boosting order values.

There’s a lot of data to unpack. Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

But First, An Event You Can’t Miss

Affiliate Marketing Summit for Lenders

Proudly Sponsored by Experian & Engine by Gen

Register NOW for early bird pricing!

Will LLMs Solve Distribution For The Cash Flow Lenders?

(read the full version in our latest editorial here)

We Were Wrong About Cash Flow Underwriting’s Distribution Problem

A year and a half ago, I (Carlos) wrote a piece called Where’s The Consumer Demand For Cash Flow Underwriting (CFU)?

Cash flow underwriting has always had one problem: nobody can sell it. The moment a consumer hits “give us your bank login,” they bail. Application rates tank, throughput drops, and the affiliate marketplaces route volume to bureau-only lenders instead.

I used to think that was a dead end. I don’t anymore.

Second-look is quietly working. Lenders are using CFU not as a primary decision, but as a second chance. Customer gets declined on bureau data. Instead of killing the lead, you offer: share your bank data and we might approve you. The person who just got told “no” is the most motivated to say yes. You monetize dead leads, your approval rate climbs, you pay higher affiliate bounties, and the flywheel spins.

But the real unlock is the LLM.

As we wrote in a recent Free Toaster edition, 200 million people already come to ChatGPT every month to ask financial questions. With Plaid now fully integrated, those questions aren’t abstract anymore — they’re grounded in real transaction data. Perplexity built the same thing. Credit Karma is plugging approval odds directly into the ChatGPT experience.

Think about what that means: a user asks about credit cards. ChatGPT reviews their actual spending via Plaid, identifies $8,000 in annual United flight spend, surfaces the United card, checks approval odds through Credit Karma, and prompts them to apply. Product discovery, underwriting match, and conversion funnel — all inside a chat window.

That’s the distribution channel CFU has been waiting for. Not a lender begging you to log into your bank. An AI you’ve already handed your financial life to, pointing you toward better rates and smarter products. The data plumbing for cash flow underwriting is getting laid down by consumers themselves (voluntarily) because the more context they give the model, the better it serves them.

We called it the personal finance super app. The flywheel is already rolling: more data makes smarter recommendations, smarter recommendations build more trust, more trust unlocks more data. At 200 million MAUs, that flywheel has serious momentum.

The open question isn’t whether CFU gets mass distribution anymore. It’s who owns the consumer relationship when it does — ChatGPT, your bank’s AI layer, Credit Karma’s approval odds infrastructure, or someone we haven’t met yet.

But the path from “I’m asking my AI about groceries” to “I’m taking out a better loan” is shorter than most people think. The natural next move after understanding your money is optimizing it. And optimizing it is exactly what lenders sell.

[Check out our full-length editorial here]

Marqeta’s State of Credit: Credit Is Now a Portfolio Consumers Assemble Themselves — and Most Issuers Aren’t Built For It

Marqeta dropped its 2026 State of Credit Report, a survey of 4,000 consumers and 1,000 SMBs across the US and UK, and the through-line is one every growth and product lead should internalize: customers no longer “have” a credit product, they assemble a portfolio of them and switch by transaction. 85% of consumers weigh multiple factors before picking a payment method, 59% used both debit and credit in the last 90 days, and 79% of BNPL users keep using BNPL even when they have a card. BNPL isn’t cannibalizing cards, it’s a parallel rail people toggle into on purpose.

Here’s the why for operators. The report quantifies the single most under-exploited leak in the funnel, the decline. 63% of denied card applicants were never offered an alternative product, yet 60% would have taken a credit-builder, and 76% of denied credit card applicants surveyed would undergo a credit check to upgrade to revolving credit when their profile is ready.

That’s a population you already paid CAC to acquire and then showed the door. The strategic answer Marqeta is selling, “flexible credentials” (one card that flips between debit, credit, and BNPL) plus co-brand-debit-with-BNPL, is really a retention-and-graduation play: keep the relationship through the credit transition instead of re-acquiring the customer later at full price. 48% of 18 to 44s want flexible credentials, rising to 71% among multi-card holders, and the demand skews toward people most comfortable with non-bank providers, which is exactly where a Marqeta-powered issuer wants the wind blowing. [Business Wire] [Marqeta]

The caveat: this is research from a company that profits if you believe it, and it’s a press release, not a filing. But the declined-applicant numbers are the kind of thing you can validate against your own data this week.

Sponsored by New Market Growth

New Market Growth helps lenders build and scale affiliate marketing programs on channels like Credit Karma, Experian Marketplace, Lending Tree, Bankrate, Credible, and many more. NMG clients spend $50-$100MM per year in affiliate channels, and the founding team (one of whom is Free Toaster co-founder Carlos Caro), have advised in excess of 50 lenders over the course of their corporate and agency careers.

If you’re a Free Toaster Reader at a lender that spends over $500K per month in affiliate marketing, we’re offering a free, 90-minute audit of your affiliate marketing program. After research we’ll conduct on our side, we’ll book time to share the strengths, weaknesses, and opportunities we observe in your program.

Outside eyes could help unlock the growth you’re looking for in H2 2026.

Email carlos@newmarketgrowth.com with subject line “90-minute audit” and we’ll contact you to get the preliminary information we need to get to work.

Sezzle Expands the Super App: New Rewards Currency, Pay-in-5, and AI Across the Stack

Sezzle pushed its super-app strategy further: the Earn tab now carries a new rewards currency (Sezzle Points, earned via cashback, surveys, and receipts, redeemable for gift cards) alongside AI-powered shopping. The distribution data point worth stealing is Pay-in-5, a no-cost five-installment option where April average order values ran 44% higher than Pay-in-4, a direct lever on basket size and merchant economics, not just a UX tweak. Sezzle is running Klarna’s playbook, converting a one-and-done BNPL checkout into a recurring engagement surface . [GlobeNewswire]

Fintech Resurgence. The Next Cycle Belongs to Operators Who Own Distribution and the Balance Sheet

BCG and FT Partners put out their Global Fintech Report 2026, “From Recovery to Resurgence,” and it’s a must-read. The top line: sector revenue hit $504B in 2025, up 22% year over year, growing roughly three times faster than incumbent financial institutions. The bigger shift is quality of growth. Among the 85 largest public fintechs, 74% are now profitable, and average EBITDA margins climbed 400bps to 20%. The “growth at all costs” era is closed. Capital is being priced on durable unit economics, not GMV.

Here is the why for operators, and it runs across distribution, underwriting, and the balance sheet.

First, distribution is being rewired by AI.

The report calls out the move from search to answers, generative engines and AI overviews intercepting intent before a user ever reaches a comparison page, plus agentic commerce where AI assistants execute checkout. For any lender that buys leads or ranks for “best personal loan,” this is the affiliate funnel eroding in real time. The defensible play is owning the customer relationship and the re-engagement loop, not renting clicks.

Second, the bank-charter wave.

Charter applications and approvals jumped more than fivefold, with names like Revolut, Nubank, and crypto-native players pursuing charters and banking licenses. Owning the charter means owning deposits, cheaper funding, and the ability to keep lending economics in house instead of renting a sponsor bank. That is a direct lever on loan margins.

Third, neobanks are graduating into credit.

The scaled digital banks are pushing past deposits and interchange into lending, where the real net interest margin lives, which puts them on a collision course with incumbent card issuers on exactly the underwriting and acquisition terrain this audience operates in. M&A is consolidating the winners, deal volume rose to 659 transactions, with scaled fintechs like Capital One buying their way into capability and reach.

The strategic takeaway is consistent across the report: revenue resurgence is real, but the operators who compound through the next cycle are the ones who control distribution as AI eats search and who control the capital and the charter behind their loans. [BCG + FT Partners]

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Spot something worth sharing with your team? Drop this week’s edition in their inbox.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.

A year and a half ago, I wrote a piece called Where’s The Consumer Demand For Cash Flow Underwriting (CFU)?

The thesis was simple. The B2B CFU providers were buzzy and raising big money. But I couldn’t find a single cash-flow-based lender who was actually killing it. And the reason came down to one word: distribution.

Selling a CFU loan product was high friction. The second a consumer hit “please give us your bank login,” they bailed. That kills your application rate. A lower application rate kills your throughput. And lower throughput means the affiliate marketplaces favor the traditional, credit-bureau-only lenders every time they have a choice.

I still think all of that was true then. And honestly, most of it is still true today.

But I’m starting to change my mind about where this goes long-term. So let me tell you what shifted.

First, two things I should have hit harder

When I wrote the original piece, I framed CFU mostly as a primary underwriting decision. New customer comes in, you run them on cash flow, you approve or decline.

Talking to folks much closer to the chief risk officer seat than I am, I’ve since learned the two use cases that are actually working today aren’t that at all. And one of them is extremely relevant to affiliate marketing.

1. Second look

Customer comes through your funnel. You decision them on traditional credit bureau data. You decline.

Instead of letting that lead die, you say: “We can’t approve you on your bureau alone. But if you can show us your cash flow looks healthy, we might be able to.”

Some of those declines will go through Plaid. And some of those will then get approved.

Here’s why this matters for anyone running an affiliate program. You just did three things at once:

• You monetized leads that were dead weight before.

• You drove up your net approval rate, which lets you pay higher bounties to your publisher partners on the same lead pool.

• You improved your funnel enough that you can climb the rankings, win better placement, and pull more volume and higher quality customers.

That’s the flywheel. And second look spins it without forcing every consumer through the friction upfront. You only ask for the bank login from the people you’ve already told “no” the traditional way.

2. Customer management

This one is less relevant to affiliates, but worth naming. Once you’ve already booked the customer, friction stops being mission critical. You’ve got them.

So now you can use cash flow data for things like credit line increases and repricing in the consumer’s favor. Picture someone in their online banking app checking their balance, asking for a CLI. In that moment you say, “To get you the best terms, I’d love to see what’s going on in your account.” They link Plaid. You see something positive. You give them the increase.

Neither of these was floating top of mind when I wrote the original piece, but they’re great practical examples of how lenders are using cash flow data today.

The three things I said had to change

At the end of that article, I said we didn’t have a good answer for how to get CFU into consumers’ hands at scale, but that the answer would include three things:

1. Distribution channels that can use cash flow data at the marketing stage to identify who qualifies

2. Reducing the application friction in consumer-permissioned access to checking accounts

3. Educating consumers on the value and safety of sharing their cash flow data

Let me go one by one, because all three have moved.

1. Distribution: enter the LLM

This is the big one, and it’s the thing that prompted me to write today’s piece.

Back then, the only channel I could point to that used cash flow data at the marketing stage was MoneyLion. That was basically it.

Now look at what’s happening with partnerships like ChatGPT and Plaid. You can connect your Plaid to the LLM and start asking it anything. How much did I spend on groceries last month? How does that compare to last year? How much am I saving? Where is my money actually going?

This is everything Mint.com tried to do, except it’s not a clunky dashboard. It’s personalized, contextual, and conversational. And I think it all moves to voice. I’ll fire up Claude and ask, “How much did I spend on gas two years ago, and what do I think I’ll spend this year given my driving has changed?” and get a sharp answer in seconds.

That reframes the entire distribution question. It used to be: can your bank convince you to link Plaid? Can Credit Karma? Now the LLMs have a genuinely compelling reason for the consumer to link their accounts, because the more context you give the model, the better it serves you.

This is what Nick and I have been calling the personal finance super app. The data plumbing for cash flow is getting laid down by consumers themselves, voluntarily, because they want better answers about their own money.

2. Friction: Plaid is starting to remember you

The second thing has moved too. Plaid is rolling out what’s effectively a returning-user shortcut. If you’ve linked through Plaid before, you put in your phone number, they recognize you, they text you a code to confirm it’s you, and you’re in. No hunting for usernames and passwords across a dozen banks.

I’m hearing directly from lenders that conversion rates are up as a result. That’s the whole ballgame for a funnel that used to scare customers at the login step.

3. Education: this isn’t an education play anymore

I used to think we’d need to teach consumers why sharing cash flow data was valuable and safe. I don’t think that’s the work anymore.

The LLMs are making it abundantly obvious on their own. The more you share, the more context you give, the better the answers you get back. Consumers are learning the value proposition by using the product, not by reading a brochure about it.

The open question

So where does this land?

The thing I’m genuinely unsure about is who owns the consumer relationship. Does ChatGPT own it? Does the bank build its own LLM layer that does this natively? Does a marketplace with an existing brand in consumer finance lean in? Or does someone go AI-native, build the whole thing from scratch, and earn the consumer’s trust as a newcomer?

Jury’s out. Could be OpenAI, Anthropic, Perplexity, or a finance-native brand we haven’t met yet. I don’t know who plays that role.

But I’m now convinced the role gets played.

So what?

If you read what I wrote a year and a half ago and concluded “as a cash-flow-based underwriter, I’m going to struggle to get distribution from the affiliate marketplaces,” you were right. You’re still right today.

What I no longer believe is that it stays that way.

If you’re a lender who isn’t all-in on cash flow underwriting, now is the time to start watching the board:

• Where is this data starting to live?

• Which surfaces have it?

• How many consumers have plugged in?

• And how good is the conversion path from “I’m asking my LLM about my groceries” to “I’m taking out a new personal loan”?

That last one is the real open question. It’s possible consumers just do budgeting and personal finance chats that never turn into a new product. But I’d bet a lot of them do convert, because the natural next move after understanding your money is optimizing it. Better rewards. Lower rates on your loans. Consolidating debt. Those are exactly the products a lender brings to the table.

I won’t put a tight timeline on it. But I’d bet that in about three years, this is a materially different market.

I’m going to be watching it closely, and I’ll report out here as it develops.

If you’re working on getting a cash flow product working in affiliate channels, I’d love to compare notes.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

https://www.thefreetoaster.com/p/where-is-the-demand-for-cash-flow-underwriting

*****

The Free Toaster is hosting the Affiliate Marketing Summit for Lenders on September 23rd & 24th in San Francisco. 

Learn more: https://events.thefreetoaster.com/

*****

The Free Toaster Newsletter ships every Wednesday at www.thefreetoaster.com, curating the biggest stories at the intersection of consumer lending, marketing, and technology.

******

Fintel Connect

Drive thousands of new accounts and billions in deposits with the only partner marketing solution built for fintech and banking – your all-in-one affiliate platform, partner network, agency, and marketing compliance engine.

https://partner.fintelconnect.com/get-to-know-fintel-connect?utm_campaign=13897733-2025%20Partners&utm_source=The%20Free%20Toaster&utm_medium=podcast

Bulldog Media Group:

Bulldog Media Group is a leading performance marketing company that specializes in online customer acquisition for clients in the financial services industry. Since 2000, they have focused on financial services digital marketing as their core niche. 

https://www.bulldogmediagroup.com/

Spinwheel:

Reduce friction in your lending application with just two fields—phone number and birthdate. Spinwheel’s APIs boost application rates by 20-30% while also providing real-time credit data and seamless payment processing. Want to see it in action? Connect with their Head of Growth for a demo!

https://spinwheel.io/partner/?utm_source=freetoaster&utm_medium=podcast&utm_campaign=apr

Hey Toaster Readers,

This week is sponsored by our friends at Fintel Connect.

Are AI agents about to take over our wallets? It certainly looks like it. Robinhood just dropped the first mass-market consumer credit card built explicitly for AI agents, while Catena Labs snagged $30M and filed for a national trust bank charter to act as a regulated fiduciary for bots. If your product roadmap didn’t account for non-human spenders yet, it definitely does now.

But it’s not just the bots making big moves. Fintechs and regulators are shaking things up, too. SoFi just scooped up Peach Finance to supercharge its lending technology stack alongside Galileo and Technisys, while a new executive order from President Trump could completely rewrite the embedded finance playbook by exploring direct Fed payment access for non-banks.

Plus, we’re diving into a slick new co-branded card from Fanatics and American Express and breaking down Q1 direct mail trends that show credit card marketers are still flooding mailboxes, while somehow largely ignoring 20-somethings.

Lots to break down. Let’s get toasting!

Carlos Caro, Founder at NMG, Co-Founder of The Free Toaster
Nick Madrid, Co-Founder of The Free Toaster and Uncovered Media

A Must-Attend Event
for Lenders + Publishers

Organized by The Free Toaster Team
Proudly Sponsored by Experian & Engine by Gen
Learn more at: events.thefreetoaster.com

Robinhood Launches an Agentic Credit Card and Agentic Trading

Robinhood launched an agentic credit card and agentic trading this week (May 27). Users instruct AI agents to make purchases using the Robinhood Gold card. Each agent gets a separate virtual card number, not the consumer’s actual card, which can be deleted at any time. Optional monthly spending caps and per-transaction notification thresholds. Agent purchases earn 3% cash back. Robinhood is the first major consumer brand to offer an agentic credit card natively. Stripe and Ramp offered virtual cards for agents, but those are B2B. This is the first mass-market consumer credit product explicitly built for AI agents. For card product managers: rewards programs, fraud logic, and co-brand economics are all built around human transactors. AI agents disrupt every assumption in that stack. Robinhood just made this everyone’s near-term roadmap problem. [Fortune] [CNBC] [American Banker]

Fanatics + American Express Launch First Co-Brand Credit Card (Issued by First Electronic Bank, Managed by Imprint)

American Express and Fanatics announced the Fanatics American Express® Card, launching later in 2026, issued by First Electronic Bank and managed by Imprint. The card earns FanCash (Fanatics’ loyalty currency) redeemable for merchandise, tickets, collectibles, and experiences. AmEx Membership Rewards cardmembers can transfer AmEx points into FanCash. AmEx becomes the Official Payments Partner across Fanatics online/retail locations and is the presenting sponsor at Fanatics Fest NYC (July 16–19). The three-party card structure (AmEx network + First Electronic Bank as issuer + Imprint as card manager) is becoming the template for specialty co-brand plays. Imprint is worth watching as a fintech stack-in-a-box for co-brand card programs. The FanCash-to-Membership Rewards bridge is an easy-to-use rewards exchange that pulls existing AmEx cardholders into the Fanatics ecosystem. [CNBC] [Bloomberg] [BusinessWire] [AmEx]

Trump Signs Executive Order on Fintech Innovation — Fed Must Review Non-Bank Payment Access

President Trump signed “Integrating Financial Technology Innovation into Regulatory Frameworks” on May 19. Key provisions: (1) Federal regulators must complete a review of their fintech regulations and application processes within 90 days (~August 17) and take pro-innovation steps within 180 days; (2) The Federal Reserve is directed to evaluate access to Fed payment accounts and services for non-bank financial companies, including fintechs and digital asset firms. This is the policy backdrop for the wave of bank charter applications (Upstart, Mercury, Catena Labs, Mission Lane). If non-banks can access Fed payment rails directly, the sponsor/partner bank model underpinning embedded finance changes structurally. For BaaS operators and embedded finance platforms: the 90-day regulatory review clock is now running. Watch for OCC, FDIC, and Fed guidance by August. [White House] [Consumer Finance Monitor] [Sullivan & Cromwell]

Sponsored by Fintel Connect

(Webinar) From Budget Guesswork to Provable ROI: What Bank and Credit Union Marketing Leaders Need to Change in 2026

Ron Shevlin, Chief Research Officer at Cornerstone Advisors and Senior Contributor at Forbes, is sitting down with Nicky Senyard, Chief Executive Officer of Fintel Connect, for a quick but impactful 30-minute conversation on how banks and credit unions can move from budget guesswork to provable marketing ROI.

Join us on June 4 at 10 am PST/ 1 pm EST, as they uncover real-world examples of how leading financial institutions are reducing the ROI gap and implementing more effective, trackable strategies to connect marketing spend to real growth outcomes.

You’ll learn:

• Why many financial institutions still struggle to measure true marketing impact

• Where banks and credit unions may be overspending or underinvesting

• How affiliate marketing is becoming a scalable, trackable acquisition channel

• What leaders need to change to better defend budgets and connect spend to growth outcomes

If you’re responsible for growth, acquisition, or marketing accountability, you won’t want to miss this session.

Save your spot now

SoFi Buys Peach Finance to Boost Enterprise FinTech Platform

SoFi just acquired Peach Finance to beef up its enterprise technology stack. Peach Finance provides software-as-a-service for loan servicing and processing, making it a natural fit for SoFi's growing backend ecosystem. SoFi will integrate the startup into its Technology Solutions segment alongside existing fintech infrastructure players Galileo and Technisys. Before the deal, Peach Finance raised around $27.5 million from venture capital firms and grew to a team of about 54 employees. This move represents an expansion for SoFi as it creates a vertically integrated system for other financial institutions looking to modernize. The acquisition supports SoFi's broader expansion strategy, which already helped the company reach 14.7 million members in early 2026. Beyond managing loans, the platform is also scaling its capital markets and blockchain capabilities to let enterprises handle both fiat and cryptocurrency. [PYMNTS]

Catena Labs Raises $30M, Files for National Trust Bank Charter for AI Agents

Circle co-founder Sean Neville’s Catena Labs raised $30M (a16z Crypto, Acrew Capital) and filed for a national trust bank charter from the OCC. Catena would be a regulated fiduciary for AI agents. A bank account where the account holder is an AI agent, not a person. Operators can set spending limits, define approved recipients, and cap holdings before handing off financial execution to agents. This is the infrastructure layer that resolves the liability, fraud, and compliance gaps blocking broad agentic commerce deployment. [Fortune] [PYMNTS]

Direct Mail Volume & Trends Report: Q1 2026

Direct mail hit 7B+ pieces in Q1 2026, and credit card brands led the charge with 1.35B pieces, more than any other category. Mortgage and loan marketers held steady at 1B+, while financial services posted modest gains after the holiday season pullback. Key creative trends: 2/3 of all mail was personalized, and 70%+ went out in envelope formats — a sign that marketers are doubling down on scalable, cost-efficient executions. One audience gap worth noting: ages 20–29 made up just ~1% of total mail volume, while 40–69-year-olds captured 2/3 of all pieces. If you're targeting younger borrowers, the mailbox is wide open. [Franklin Madison Direct]

News Pod 19 - With The New Plaid Integration, ChatGPT is Now a Distribution Channel for Personal Finance

Catch us on Apple Podcasts, Spotify, Substack, or your favorite player.

Upcoming Toaster Events:

Affiliate Marketing Summit for Lenders (San Francisco | Sept 23–24)
Step away from the daily grind for a two-day, senior-level industry event in San Francisco. On day one, we’ll spend the day at the Exploratorium, a killer indoor/outdoor space where we’ll have a mix of keynotes, panels, structured networking, and great food & drink overlooking the water. On day two (optional, for anyone interested), we’ll head out to wine country so you can continue the conversations you initiated the day prior. Our goal is to make this Summit the ONE event per year you can’t miss if you’re a lender who’s serious about affiliate marketing.

Please support our Newsletter by sharing this edition with a colleague!

And, consider checking out our sponsors:

• Need an affiliate marketing platform/network? Chat with Fintel Connect

• Need to improve application page conversions? Chat with Spinwheel

• Need help with performance marketing? Chat with Bulldog Media Group

• Need to grow in big marketplaces like Credit Karma? Chat with New Market Growth

• Need to hire top-tier talent in fintech or lending? Chat with CTB1

Looking for a new role?

The Free Toaster Jobs Edition tracks where fintech teams are actually investing across marketing, product, data, credit, risk, and partnerships.

The Free Toaster Jobs

The Free Toaster Jobs curates real openings across credit, risk, product, data, and growth, with a focus on consumer fintech and lending. No noise. Just roles that signal where budgets and priorities are moving.

By Toaster Media

Spot something worth sharing with your team? Drop this week’s edition in their inbox.

Catch you next week,

The Free Toaster Team

P.S.: If you’d like to sponsor or host an event in the consumer lending community in 2026, we’d like to hear from you. The Free Toaster will be organizing & hosting curated events this year, and we’d love to work with you as a sponsor.