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OCC Bulletin 2019-62 | December 3, 2019

Consumer Compliance: Interagency Statement on the Use of Alternative Data in Credit Underwriting


Chief Executive Officers and Compliance Officers of National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, and the National Credit Union Association (collectively, the agencies) issued today the "Interagency Statement on the Use of Alternative Data in Credit Underwriting." The agencies developed this interagency statement in response to a U.S. Government Accountability Office (GAO) recommendation.

Note for Community Banks

This statement applies to all national banks and federal savings associations that use alternative data in credit underwriting.


This interagency statement is focused on consumer protection implications of the use of alternative data in underwriting, highlighting potential benefits and risks. In the interagency statement, the agencies

  • seek to encourage the responsible use of alternative data.
  • explain that many factors associated with using alternative data, including cash flow data, may increase or decrease consumer protection risks.
  • explain that a well-designed compliance management program provides for a thorough analysis of relevant consumer protection laws and regulations to ensure firms understand the opportunities, risks, and compliance requirements before using alternative data.

Further Information

Please contact Paul R. Reymann, Director for Consumer Compliance Policy, at (202) 649-5470.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

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