Consumers Union submitted these comments in response to the Consumer Financial Protection Bureau’s (CFPB) Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process, in addition to supporting the comments filed to this docket by the National Consumer Law Center (NCLC).

There are potential benefits to the use of alternative data, in that it may help many of the estimated 45 million consumers who lack a traditional credit report or score to develop their credit histories. Nevertheless, Consumers Union has strong reservations about the use of alternative data to evaluate consumers for the purpose of determining creditworthiness, because we have concerns as to the accuracy, transparency, predictive capability, and impact of using such data, particularly on communities of color.