CFPB, Federal Agencies, State Agencies, and Attorneys General
This past Tuesday, Acting Comptroller of the Currency Michael Hsu appeared as a witness at the Senate Banking Committee’s hearing, “Oversight of Regulators: Does our Financial System Work for Everyone?”
In his written and oral testimony, Mr. Hsu stressed as an overall theme the need for the OCC to prohibit “predatory and discriminatory practices while promoting financial inclusion.” … Continue Reading
Our podcast looks at types of alternative data (AD) and industry sources, key points of the recent interagency statement on using AD for credit decisions and CFPB actions to encourage such use, FCRA/ECOA/UDAAP concerns and steps to address them, use of social media data, and the relationship between AD and artificial intelligence. … Continue Reading
The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”
The statement sets forth the agencies’ recognition of the benefits of using alternative data (AD) in credit decisions. For purposes of the statement, AD means “information not typically found in the consumer’s credit files of the nationwide consumer reporting agencies or customarily provided by consumers as part of applications for credit.” … Continue Reading
A new CFPB blog post titled “An update on credit access and the Bureau’s first No-Action Letter” provides a boost to lenders using alternative data and machine learning in their underwriting models.
The Bureau issued its first (and so far only) no-action letter in September 2017 to Upstart Network Inc.… Continue Reading
On September 14, 2017, the CFPB issued a no-action letter – the first one ever issued by the agency – to a marketplace lender, stating that the agency had no present intention to take enforcement or supervisory action against the lender under the Equal Credit Opportunity Act (ECOA) relating to the lender’s underwriting model, and especially its use of certain alternative data fields. … Continue Reading
An informative new American Banker podcast discusses recent and possible future changes to traditional credit scores, what they mean for industry, and possible industry responses.
The podcast begins with a discussion of changes that will take effect on July 1, 2017 to the public record data standards used by the “Big 3” consumer reporting agencies (CRAs) for the collection and updating of civil judgments and tax liens. … Continue Reading
The CFPB has issued a request for information (RFI) that seeks information about the use of alternative data and modeling techniques in the credit process. On March 21, 2017 from 12:00 to 1:00 p.m. ET, Ballard Spahr attorneys will hold a webinar: The New Frontier of Alternative Credit Models: Opportunities, Risks and the CFPB’s Request for Information. … Continue Reading
