The credit system plays a foundational role in helping millions of families and small business owners build better lives for themselves, strengthening local communities and the national economy in the process. Yet millions of individuals and small businesses struggle to access the credit system because of weaknesses and gaps in the type of data traditionally relied upon for credit underwriting.

In many smaller American towns banks and credit unions are finding usual sources of loan demand dwindling — and that was before the COVID-19 recession. Community banking institutions may find trouble if they market their credit services further afield. The solution may be to dig deeper for loans in the communities they already know, marketing loans to be evaluated with new alternative data sources (like some fintechs do).

Concerns about credit reporting and scoring issues are growing as early relief programs start to expire and the focus shifts from short-term forbearance to long-term repayment. This Research Brief updates market and regulatory developments as well as ongoing policy debates.

The CFPB issued a blog post noting the potential inclusion benefits of using AI and machine learning models for credit underwriting, as well as risks and compliance challenges with respect to the delivery of “adverse action” disclosures. The agency emphasized the “built-in flexibility” in the regulatory framework and recognized emerging work by lenders and technology companies to enhance the explainability of AI underwriting models.

The CFPB has issued FAQs on implementation of CARES Act requirements concerning pandemic-related credit reporting, as well as the use of special comment codes for disaster effects and forbearances.

This Research Brief catalogues uses of new data and technologies to make it easier for small businesses to access federal Paycheck Protection Program (PPP) funds and other forms of credit. Solving PPP enrollment challenges is important to laying the foundation for a rapid and inclusive recovery and to building a more resilient small business sector going forward.

This first edition of our FAQs addresses a range of introductory questions about AI and machine learning.

The CFPB issued a no-action letter template to the Bank Policy Institute recognizing terms for a standardized, small-dollar credit product, including those designed to function as “guardrails.” The template is intended to ease approval of plans by individual regulated entities to offer a product based on these standardized terms, subject to submission and approval of further information specific to each lender. Underwriting based on the applicant’s cash-flow data is specified among the essential terms set forth for the standardized product.

U.S. prudential regulators recognize the roles that both innovative technologies and data sources such as deposit account activity can play in providing responsible small- dollar loans to consumers and small businesses who do not meet supervised institutions’ traditional underwriting standards.

Rapidly adjusting credit reporting and underwriting practices and processing small businesses’ Paycheck Protection Program applications posed substantial challenges in the first months of the pandemic. In 2020, FinRegLab produced a series of research briefs highlighting emerging issues and innovations.