Kelly Thompson Cochran

Kelly Thompson Cochran

Deputy Director and Chief Program Officer

Prior to joining FinRegLab, Kelly helped to stand up the Consumer Financial Protection Bureau, where she served most recently as the Assistant Director for Regulations. In that capacity, she oversaw rulemaking and guidance activities under the Dodd-Frank Act, Electronic Fund Transfer Act, and various other federal consumer financial laws. Kelly previously was counsel at WilmerHale, where she advised financial institutions on a wide range of legal and regulatory matters including product development, compliance, enforcement, and litigation. Kelly also conducted research on financial services innovation, community reinvestment, and other topics at the University of North Carolina at Chapel Hill.

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FinRegLab Deputy Director Kelly Cochran joins RegFi cohosts Jerry Buckley and Caroline Stapleton for a conversation about how machine learning – including generative artificial intelligence – is used by consumer lenders and the evolving regulatory response. Kelly begins with a helpful distinction between the technologies commonly included under the broad “AI” moniker, noting that many of these algorithmic models are not new to credit underwriting. The discussion then pivots to the growing focus on generative AI and the need to balance its potential benefits with consumer protection, data privacy and explainability considerations. Kelly suggests that existing rules in the financial services regulatory framework can be adapted to address many of these issues and serve as a model for AI policymaking in other sectors.
Over the past three decades, customer-permissioned data flows have become critical to a growing range of consumer financial products and services as well as to public research focusing on household financial health, markets for consumer financial products and services, and the role of consumer financial activity in the nation’s economy.
These data flows are critical to a growing range of consumer financial products and services. Modernizing the regulatory frameworks governing these flows is important both to mitigate current risks and frictions and to encourage future applications that produce greater inclusion, competition, and customer-friendly innovation, particularly for historically underserved consumers.
A new study finds that more consumers obtained short-term payment relief on their credit cards during the first 18 months of the pandemic than on any other type of loan except student debt, where forbearances were mandated by federal law. The study also finds evidence that pandemic relief initiatives may have reduced damage to the credit reports of consumers who sought long-term assistance through credit counseling and debt management programs.
As recent developments have renewed interest in harnessing new data and analytical techniques for credit underwriting, stakeholders are asking questions about potential benefits and risks particularly for addressing racial equity issues. FinRegLab Deputy Director Kelly Thompson Cochran wrote an article summarizing recent initiatives and issues for an edition of the Community Development Innovation Review titled “Fintech, Racial Equity, and an Inclusive Financial System” that has been published by the Federal Reserve Bank of San Francisco and the Aspen Institute.