>>..last four digits of his or her social security number, as well as behavioral factors like how long he or she takes to remember all that information. If that combination doesn’t quite add up to a loan,...
What I find really frustrating with most of these fintech companies is that they claim they use all kinds of data. But they don't really disclose whether this is used for 'underwriting' or 'fraud'. When it comes to underwriting there are specific FCRA guidelines on reason codes. For example, if they decline credit to a consumer because s/he did not type in their address fast enough, they need to tell them that. That would make for a good sound bite for the company.
Also, what if disabled people cannot type fast enough? That seriously touches on discrimination. Too bad CFPB is not going to care about these companies until they get to $10Bn in loan size.
What I find really frustrating with most of these fintech companies is that they claim they use all kinds of data. But they don't really disclose whether this is used for 'underwriting' or 'fraud'. When it comes to underwriting there are specific FCRA guidelines on reason codes. For example, if they decline credit to a consumer because s/he did not type in their address fast enough, they need to tell them that. That would make for a good sound bite for the company.
Also, what if disabled people cannot type fast enough? That seriously touches on discrimination. Too bad CFPB is not going to care about these companies until they get to $10Bn in loan size.