NCLC submitted comments in response to the Treasury Department’s request for information on developing a national strategy for financial inclusion.
Our comments begin by addressing some of the risks associated with expanding the use of alternative data in credit reporting and argue that “alternative” data is best left outside of the main credit reporting file. We then go on to discuss challenges that generate or exacerbate exclusion from our financial system generally, including blunt-fisted, opaque identification requirements to open bank accounts, and bank account closures and freezes done in the name of anti-money laundering compliance. Finally, given the Department’s particular interest in the needs of underserved communities, our comments highlight factors that render specific vulnerable groups of consumers susceptible to exclusion from our financial system and limitations that may result in barriers to participating in our mainstream system. The groups we highlight are immigrants and consumers with limited English proficiency (“LEP”), domestic violence survivors, and justice-involved people.