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
- 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