On January 16, Democratic members of the House Financial Services Committee sent a letter to the Government Accountability Office (GAO) inquiring about the benefits and drawbacks of using alternative data in mortgage lending, as well as the federal government’s role in overseeing the use of alternative data credit reporting agencies (CRAs) and lenders. The letter notes that while alternative data can be useful in helping lenders identify creditworthy potential borrowers who cannot be scored by CRAs through traditional measures, questions remain about how the use of alternative data may affect compliance with fair lending laws, including the Equal Credit Opportunity Act and Fair Housing Act. “While some alternative data, such as rental payment history, may provide an objective measure of creditworthiness, others might enable discrimination on the basis of a protected class, or infringe upon consumer privacy,” the letter cautions. The letter asks GAO to study the use of alternative data in expanding access to credit, with a particular focus on mortgage credit, and poses the following questions:

  • How have different entities used alternative data to expand access to mortgage credit? Specifically, can alternative data determine consumer creditworthiness and whether a consumer is able to repay a mortgage? Additionally, are there certain alternative data sources that are better at predicting creditworthiness or some that are more likely to raise concerns about correlations with discriminatory factors? Furthermore, what federal activity has there been in this space?
  • What are the potential benefits and risks associated with using alternative data and financial technology for access to mortgage credit, and are there variations in these benefits and risks across different groups, including minorities and younger borrowers?
  • What potential risks does alternative data pose to fair lending compliance, and are the regulatory and enforcement agencies that govern the credit-granting system equipped to manage and prepare for an increased use of alternative data in mortgage lending?
  • How do the benefits and trade-offs of other options for expanding access to mortgage credit compare to the use of alternative data in credit scoring?