US Interagency statement on the use of alternative data in credit underwriting

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On December 3rd, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency (collectively, the Agencies) issued an Interagency Statement on the use of alternative data in credit underwriting and the consumer protection implications of such use.

In the Interagency Statement, the Agencies recognize that the use of alternative data may improve the speed and accuracy of credit decisions and may help firms evaluate the creditworthiness of consumers who currently may not obtain credit in the mainstream credit system, enabling them to obtain additional products and/or more favorable pricing/terms based on enhanced assessments of repayment capacity. These innovations reflect the continuing evolution of automated underwriting and credit score modeling, offering the potential to lower the cost of and to increase access to credit. However, while noting these benefits to consumers, the Agencies also note that the use of alternative data must be responsible and should comply with applicable consumer protection laws and other requirements.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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