There are longstanding and well-documented concerns that many consumers are 19 In a 2017 request for public comment, the Bureau of Consumer Financial Protection noted that alternative modeling techniques may offer consumer benefits, such as greater credit access, enhanced creditworthiness predictions, lower costs, and better service and convenience, but also highlighted consumer risks, such as privacy concerns, data quality issues, loss of the ability to correct errors, and discrimination.
See Bureau of Consumer Financial Protection, “Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process,” (Washington: Bureau of Consumer Financial Protection, February 14, 2017), https://files.consumerfinance.gov/f/documents/20170214_cfpb_Alt-Data-RFI.pdf 20 See, e.g., Lael Brainard, “FinTech and the Search for Full Stack Financial Inclusion,” (speech at the Conference on FinTech, Financial Inclusion, and the Potential to Transform Financial Services at the Federal Reserve Bank of Boston, Boston, October 17, 2018), https://www.federalreserve.gov/newsevents/speech/brainard20181017a.htm.