ACLU Comment to CFPB regarding the Use of Alternative Data and Discriminatory Lending

On May 18th, 2017 the ACLU submitted this letter to the Consumer Financial Protection Bureau (CFPB) in response to its Request for Information (RFI) regarding the use of alternative data in the credit process. In particular, this comment focuses on the impacts of alternative data on the marketing of consumer credit. The ACLU is particularly concerned about the ways in which the use of behavioral data to target advertisements online has the potential to deny individuals vital information about housing, employment, and credit opportunities and thereby to facilitate discrimination.