News & Analysis as of

Underwriting Consumer Financial Protection Bureau (CFPB) Artificial Intelligence

Hudson Cook, LLP

No AI Law? No Problem. How Massachusetts Attacked AI Underwriting Under Existing State Statutes

Hudson Cook, LLP on

On July 10, 2025, the Massachusetts Attorney General (AGO) entered into an Assurance of Discontinuance (AOD) with a private student loan lender (the Company), resolving allegations that the Company's underwriting practices...more

Goodwin

Double Clicking on Innovation in Consumer Finance: Responsible Use of AI

Goodwin on

Artificial intelligence (AI) is becoming ubiquitous across sectors, and the financial services industry is no exception. With the rise of AI, there is also an increase in scrutiny by regulators over its use....more

Alston & Bird

NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing

Alston & Bird on

On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information...more

Bradley Arant Boult Cummings LLP

CFPB Issues Additional Guidance on Use of AI in Credit Underwriting

On September 19, the Consumer Financial Protection Bureau (CFPB) issued Circular 2023-03, which provides guidance as to how lenders must explain denials of applications of credit when the underwriting is based on artificial...more

Eversheds Sutherland (US) LLP

CFPB proposal signals a dramatic expansion of the Fair Credit Reporting Act to data brokers

On September 15, 2023, the Consumer Financial Protection Bureau (CFPB) published an outline of expansive rulemaking proposals to modernize the coverage of the Fair Credit Reporting Act (FCRA) to include data brokers, data...more

Goodwin

CFPB Issues No Action Letter Related to Use of Artificial Intelligence Underwriting Model

Goodwin on

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) granted a no-action letter​ to an online loan marketplace company for its artificial intelligence (AI) loan origination and underwriting platform.​ ...more

Morrison & Foerster LLP

Machine Underwriting: The CFPB Issues Blog Post On Use Of Artificial Intelligence In Credit Underwriting

On July 7, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) published a blog post on the use of artificial intelligence (AI), especially machine learning (ML), in credit underwriting. The blog post addresses...more

Ballard Spahr LLP

Federal banking agencies and CFPB issue interagency statement on use of alternative data in credit underwriting

Ballard Spahr LLP on

The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more

Nutter McClennen & Fish LLP

Fintech in Brief: CFPB Blog Updates First No-Action Letter Results

On August 4, 2019, the Consumer Financial Protection Bureau (“CFPB”) published a blog summarizing some of the results of simulations and analyses on an alternative data and credit model developed by Upstart Network, Inc....more

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