The expanding use of mobile technologies, cloud computing, and the Internet of Things has greatly increased the amount of available consumer data. The ability to efficiently process this information has the potential to provide countless consumer benefits. Nevertheless, companies must navigate an ever-expanding patchwork of domestic and foreign laws and uncertainty regarding the application of existing laws to new technologies. In addition, although regulators have commended the advancement and development of new consumer lending technologies, they also have warned that these new tools “carry the risk of disparate impact in credit outcomes and the potential for fair lending violations[.]” For companies under the authority of the Consumer Financial Protection Bureau (CFPB), the CFPB’s no-action letter (NAL) program offers a potential tool to help navigate these challenges. As described in the following article, however, the tool is not without risk for companies seeking regulatory guidance.
Continue Reading Starting Up the CFPB’s No-Action Letter Program