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Big Data (Part 2): How can it affect UDAAP liability?
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Consumer Protection
Tuesday, April 28, 2015
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As the Consumer Financial Protection Bureau focuses on credit reporting, the banking industry is balancing the need to make wise lending decisions while avoiding liability. Using big data for credit scoring models might eliminate human bias, but it also can open the door to potential liability over third-party oversight under fair lending laws and under “unfair, deceptive and abusive acts and practices.” Part 2 explores the third-party and UDAAP risks of using big data.
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