The Use of Alternative Data in Online Lending Models and the Credit Process: Assessing Consumer Concerns, Regulatory Challenges, and the Implications of the CFPB’s First No-Action Letter

May 1, 2018 11:35am

Jonathan J. Wegner
Partner
Baird Holm LLP (Omaha, NE)

D. Bradford Hardin, Jr.
Counsel
WilmerHale (Washington, DC)

Ronald Vaske
Partner
Ballard Spahr LLP (Minneapolis, MC)

David L. Beam
Partner
Mayer Brown LLP (Washington, DC)

  • Examining the latest FinTech uses of alternative data in making lending, credit, and pricing decisions
  • Assessing the consumer concerns and regulatory challenges surrounding this practice
  • What are the implications of this practice with the ECOA, FCRA and state lending laws?
  • Evaluating the CFPB’s first ever no-action letter to Upstart Network, Inc. as part of their Project Catalyst
    • What are the terms of the letter, and what does it herald for the future realm of emerging financial technologies?
    • Is this a predictor or more NALs or regulatory relief for FinTech innovation in the near future?
  • Assessing other initiatives of the CFPB’s Project Catalyst, as well as state-level initiatives surrounding alternative data usage in the credit process