Testimony & Comment Letters

Latest Testimony & Comment Letters

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.
FinRegLab’s forthcoming research will help to inform the extent to which current laws and regulations are able to be satisfied in light of the emergence of more complex underwriting models, how well tools to develop and monitor those models perform in identifying effective ways to pursue greater inclusion and fairness, and considerations for policy and market developments that can support the safe, inclusive, and nondiscriminatory adoption of machine learning.
We recognize the breadth of urgent issues facing the Consumer Financial Protection Bureau and the nation at this time, but believe that resolving critical questions about access to financial data would substantially benefit consumers, small businesses, and financial services providers in helping to recover from the Covid-19 pandemic, address longstanding racial wealth gaps, and make U.S. financial systems more generally inclusive, competitive, and responsive to customer needs.