Alternative Data & Algorithms Archives

Comments to the CFPB Regarding Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning

July 1, 2021

NCLC submits these comments on behalf of its low-income clients in response to the Agencies’ Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning. The widespread adoption of artificial intelligence (AI), machine learning (ML), and related technologies by financial institutions raises fair lending and consumer protection concerns.

Comments to the CFPB Regarding Consumer Access to Financial Records Under Section 1033 of the Dodd-Frank Act

February 4, 2021

The CFPB has requested comment on 46 questions to assist it in developing a proposed rule to implement Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. These comments address a selected number of these questions that we as consumer advocacy groups are particularly suited to answer.

Testimony Before U.S. House Financial Services Task Force Regarding “Banking on Your Data: The Role of Big Data in Financial Services”

November 21, 2019

Testimony of Lauren Saunders before the U.S. House of Representatives Committee on Financial Services Task Force on Financial Technology Regarding “Banking on Your Data: The Role of Big Data in Financial Services.”

Statement Regarding Bank Regulators’ Guidance on Alternative Data

December 4, 2019

Boston – Yesterday, the Federal Reserve Board, Federal Deposit Insurance Corp., Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, and National Credit Union Administration released an Interagency Statement on the Use of Alternative Data in Credit Underwriting. Chi Chi Wu, staff attorney at the National Consumer Law Center, issued the following statement…

Credit Invisibility and Alternative Data: Promises and Perils

July 1, 2019

Consumers are “credit invisible” if they don’t have any credit history with the Big Three credit bureaus (Equifax, Experian, and TransUnion) or if their histories are too scant or old (“thin”) to generate a credit score.

Letter Responding to Senate Call for Feedback on Data Privacy, Protection and Collection

March 15, 2019

Feedback on Data Privacy, Protection and Collection

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