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Fair Lending No-Action Letters

McGlinchey Stafford

CFPB Takes Adverse Action Against Machine Learning

McGlinchey Stafford on

The Consumer Financial Protection Bureau (CFPB) has been contemplating data, algorithms, and machine learning for years. In 2017, as part of a field hearing on alternative data, the CFPB issued a request for information in...more

Ballard Spahr LLP

CFPB issues new no-action letter to Upstart

Ballard Spahr LLP on

The CFPB recently issued a new no-action letter (NAL) to Upstart Network, Inc. regarding its automated model for making underwriting and pricing decisions on applications by consumers for unsecured, closed-end loans.  Upstart...more

Skadden, Arps, Slate, Meagher & Flom LLP

Summary of 28th Annual Conference on Fair Lending and Consumer Financial Protection

Year In Review - Anand Raman, the head of Skadden’s Consumer Financial Services (CFS) practice, began the conference by providing a summary of notable events and trends over the past year relating to consumer financial...more

Morrison & Foerster LLP

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Ballard Spahr LLP

CFPB gives boost to use of alternative data and machine learning

Ballard Spahr LLP on

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....more

Davis Wright Tremaine LLP

CFPB’s First No-Action Letter: Supporting Innovation AND Supervision for Fair Lending

The Consumer Financial Protection Bureau (the “Bureau”) issued its first no-action letter (“NAL”) to Upstart Network, Inc. (“Upstart”), a marketplace lender that sought to clarify that its automated model for underwriting...more

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