E-disclosures tech sprint
On October 5-9, 2020, the CFPB will host its E-Disclosures Tech Sprint at CFPB Headquarters in Washington, D.C.
We anticipate that participants will be asked to design innovative electronic methods for informing consumers about adverse actions in a manner intended to achieve all three of the following goals, which are reflected in the purposes of the Equal Credit Opportunity Act (ECOA) and/or the Fair Credit Reporting Act (FCRA):
- Improving the accuracy of information used to take adverse action
- Preventing and helping reveal discrimination on a prohibited basis
- Educating consumers about potential improvements they can make for future credit applications
The Bureau is considering a range of possible policy actions with respect to adverse action notices. Innovative disclosure approaches explored in the Tech Sprint will help inform the Bureau’s evaluation of whether particular statements of policy, rulemaking, or other actions in this area may be appropriate.
Although Tech Sprint teams may choose to work within current regulatory requirements, we do not plan to require team submissions to conform to existing rules, sample forms or official interpretations. Instead, we want to provide participants with maximum flexibility to explore alternatives that may improve upon existing notices. The critical element for submissions is that participants be able to explain how their approach and results meet the accuracy, anti-discrimination, and educational purposes that are described above. Teams will be asked to assume that all E-SIGN Act disclosure requirements have been met.
What to expect
The Bureau is considering how teams might best demonstrate their approaches. The Bureau is considering supplying participants with hypothetical information of the kind that modelers provide legal and compliance staff to create adverse action notices. The Bureau is also considering whether to permit participants to bring similar information of the kind that they typically work with (or are considering working with) to generate adverse action notices. In addition, we are considering providing Tech Sprint participants with the option of either being assigned to a Tech Sprint team with other participants or, in appropriate instances, to form their own team.
After consultation with interested stakeholders, we will post a finalized plan for the Tech Sprint and invite interested parties to apply to participate.
Interested in participating?
If you are considering participating in this Tech Sprint, sign up to learn more. Interested parties will have the opportunity to commit to participate at a later stage, but registering your interest now will help us engage with you and other relevant stakeholders in the design and implementation of this Tech Sprint.