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Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Perkins Coie

Fintech Legal Report - July 2022

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The CFPB terminates a no-action letter with an AI credit underwriter. A CFPB circular confirms that AI underwriting models are subject to anti-discrimination laws including adverse action notices....more

Ballard Spahr LLP

CFPB issues order terminating Upstart no-action letter

Ballard Spahr LLP on

The CFPB issued an order last week terminating the no-action letter issued to Upstart Network, Inc. on November 30, 2020 for a 36-month term (NAL).  The NAL was essentially a renewal of the no-action letter issued to Upstart...more

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

Goodwin

CFPB Issues No Action Letter Related to Use of Artificial Intelligence Underwriting Model

Goodwin on

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) granted a no-action letter​ to an online loan marketplace company for its artificial intelligence (AI) loan origination and underwriting platform.​ ...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

Ballard Spahr LLP

Paul Watkins, Director of the CFPB’s Office of Innovation, discusses final innovation policies in Ballard Spahr webinar

Ballard Spahr LLP on

Paul Watkins, Director of the CFPB’s Office of Innovation, joined Ballard Spahr partners Alan Kaplinsky and James Kim yesterday for a discussion of the CFPB’s final innovation policies.  ...more

BCLP

CFPB September 2019 Roundup

BCLP on

Enforcement, Innovation, Consumer Data and Unconstitutionality - Director Kraninger and the Consumer Financial Protection Bureau have been busy this month. Summer is over, and back to school it is. In addition to...more

Ballard Spahr LLP

CFPB gives boost to use of alternative data and machine learning

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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

Wilson Sonsini Goodrich & Rosati

Starting Up the CFPB’s No-Action Letter Program

The expanding use of mobile technologies, cloud computing, and the Internet of Things has greatly increased the amount of available consumer data. The ability to efficiently process this information has the potential to...more

Burr & Forman

Fall 2017 Consumer Financial Protection Bureau Update

Burr & Forman on

The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) is a U.S. government agency created by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB is the first federal agency tasked solely with the...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

Alston & Bird

CFPB’s Project Catalyst Offers Comfort for Startups—but with a Cost

Alston & Bird on

Project Catalyst finally takes off, giving companies a chance to pursue innovative strategies and products in the financial services sphere. Our Financial Services & Products Group takes stock of the CFPB’s very first...more

Kilpatrick

CFPB Issues First No-Action Letter To Marketplace Lender

Kilpatrick on

On September 14, 2017, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its first no-action letter to Upstart Network, Inc., a company based in San Carlos, California that provides an online lending platform...more

Morrison & Foerster LLP

A First Time for Everything—CFPB Issues Its First No-Action Letter

The Consumer Financial Protection Bureau (the “CFPB” or the “Bureau”) recently announced the issuance of its first no-action letter (“NAL”) to Upstart Network, Inc. (“Upstart”), a San Carlos, California-based online lending...more

Ballard Spahr LLP

CFPB Provides Some Clarity on Alternative-Data Models Through No-Action Letter

Ballard Spahr LLP on

On September 14, 2017, the CFPB issued a no-action letter – the first one ever issued by the agency – to a marketplace lender, stating that the agency had no present intention to take enforcement or supervisory action against...more

Ballard Spahr LLP

Director Cordray defends CFPB positions in appearance before Senate Banking Committee; comments on small business lending and...

Ballard Spahr LLP on

Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last...more

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