A new research paper underscores the importance of evaluating whether the most vulnerable and distressed borrowers need longer term repayment plans soon after they first enroll in natural disaster or other emergency relief programs with credit card lenders.
FinRegLab has issued two papers that examine lenders’ ability to build, understand, and manage machine learning models to ensure that they can be trusted to underwrite applications for credit by millions of consumers and small businesses.
FinRegLab today issued a research brief entitled “The Countdown Clock for Student Loan Forbearances” that highlights the need for quick action by consumers, federal agencies, servicers, and counselors to prepare for the August 2023 end of pandemic-era forbearances on federal student loans.
Consumer Reports released a video series exploring biases in machine learning algorithms and data sets and the resulting unfair practices faced by communities of color. The series is designed to educate consumers on the risks hidden in seemingly “neutral” technologies. FinRegLab CEO Melissa Koide is featured in the Mortgage Lending episode of the series.
“Credit underwriting with cash-flow data involves using financial data insights from a bank account or other types of transaction accounts to evaluate consumers and small businesses for credit,”
The National Institute for Standards and Technology has released the first version of a voluntary framework to help incorporate trustworthiness considerations into the design, development, use, and evaluation of AI products, systems, and services. The framework and various supplemental materials were developed after more than 18 months of public engagement. Comments are due February 27, 2023.
Testimony & Comment Letters
FinRegLab Responds to the CFPB’s Outline on Personal Financial Data Rights Rulemaking
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.
“Some fintechs think including more data and analyzing it with more advanced algorithms could solve the problem. Others say it’s time to build whole new systems.”
“The report finds that, while concentration among federally insured banks is growing, new entrant non-bank firms, in particular ‘fintech’ firms, are adding significantly to the number of firms and business models competing in core consumer finance markets and appear to be contributing to competitive pressure. While these fintech firms are enabling new capabilities, they are also creating new risks to consumer protection and market integrity, such as risks related to data privacy and regulatory arbitrage.”