The CFPB recently issued a new no-action letter (NAL) to Upstart Network, Inc. regarding its automated model for making underwriting and pricing decisions on applications by consumers for unsecured, closed-end loans. Upstart uses artificial intelligence techniques and alternative data in its model.
The new NAL is essentially a renewal of the NAL issued to Upstart in September 2017, which was the first NAL issued by the CFPB. … Continue Reading