The Use of Cash-Flow Data in Underwriting Credit: Market Context & Policy Analysis

Report Summary

The Market Context & Policy Analysis report provides detailed snapshots of the use of cash-flow data in U.S. consumer lending and the development of the system for transferring data between firms, in addition to in-depth analyses of policy and regulatory issues raised by cash-flow underwriting in both consumer and small business credit markets.

The report analyzes both current initiatives and future options to address these emerging policy issues, including accelerating the adoption of safer and more efficient data transfer technologies, developing processes and tools to foster meaningful customer control over their information, clarifying and strengthening existing customer protections, and increasing supervision of non-bank actors.

In the near term, the report concludes that increased engagement by federal regulators through research, monitoring, and interpretive activities could be particularly useful, in part by providing sharper focus and greater certainty to industry self-governance and legislative initiatives. Addressing market challenges and customer protection issues in the underlying data transfer system in the next few years could be particularly helpful to set the stage for more rapid expansion in cash-flow underwriting in years to come.

Click here for an October 2020 update on the use of non-traditional data for credit scoring and underwriting in response to the pandemic recession and racial justice movements.


This report, The Use of Cash-Flow Data in Underwriting Credit: Market Context & Policy Analysis, and the accompanying Policy Overview were made possible through founding support from Flourish/Omidyar Network. 

Flourish Ventures

Flourish, a venture of the Omidyar Group, has provided operating support to FinRegLab since its inception. Flourish is an evergreen fund investing in entrepreneurs whose innovations help people achieve financial health and prosperity. Established in 2019, Flourish is funded by Pam and Pierre Omidyar. Pierre is the founder of eBay. Managed by a global team, Flourish makes impact-oriented investments in challenger banks, personal finance, insurtech, regtech, and other technologies that empower people and foster a fairer, more inclusive economy.

For more information visit or join our community through Twitter, LinkedIn, Instagram, and Medium. Additional support for this report was provided by the Milken Institute, which enabled FinRegLab to evaluate cash-flow data in small business credit underwriting.

Milken Institute

The Milken Institute is a nonprofit, nonpartisan think tank that helps people build meaningful lives, in which they can experience health and well-being, pursue effective education and gainful employment, and access the resources required to create ever-expanding opportunities for themselves and their broader communities.

We would like to extend a special note of appreciation for their leardship and facilitation of FinRegLab’s policy working groups to Melanie Brody, Mayer Brown; Mark Schultz, Capital One; P-R Stark, Oliver Wyman; and Corey Stone, Financial Health Network. Thanks also to the Fintech Team at the Federal Reserve Bank of San Francisco in co-hosting a symposium entitled “The Role of Consumers in the Data Ecosystem.”

FinRegLab would also like to recognize the individuals and organizations who participated in the policy working groups as listed in Appendix A in the Market Context & Policy Analysis report, the participants of the Data Ecosystem symposium, and stakeholders who participated in interviews.

We are particularly grateful to Marsha Courchane and Arthur Baines, Charles River Associates, for the role they played to design and execute the empirical research analysis. We are also grateful to Thomas P. Brown and Stephen J. Bandrowsky, Paul Hastings, for legal assistance throughout the course of the research process.

We would also like to thank the following individuals who provided feedback on this report. They include:

Alex Acree

Chief Legal Officer

Melanie Brody

Mayer Brown

Tori Shinohara

Mayer Brown

Thomas P. Brown

Paul Hastings

Jonah Crane

Klaros Group

Eric Goldberg


David Medine

Consultative Group to Assist the Poor

Karen Mills

Harvard Business School

Annie V. Dand

Harvard Business School

Chuck Muckenfuss

Gibson Dunn

David Silberman


David Stein

Covington & Burling

Corey Stone

Senior Advisor
Oliver Wyman, Financial Health Network (FHN)

Chi Chi Wu

National Consumer Law Center

We would also like to acknowledge the FinRegLab team who worked on research, convenings, and reports. They include:

Kelly Thompson Cochran

Deputy Director and Chief Program Officer

Kerrigan Molland

Senior Finance & Business Operations Manager

Michelle Wu


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About FinregLab

FinRegLab is an independent, nonprofit organization that conducts research and experiments with new technologies and data to drive the financial sector toward a responsible and inclusive marketplace. The organization also facilitates discourse across the financial ecosystem to inform public policy and market practices. To receive periodic updates on the latest research, subscribe to FRL’s newsletter and visit Follow FinRegLab on LinkedIn and Twitter (X). | 1701 K Street Northwest, Suite 1150, Washington, DC 20006