Troutman Pepper Weekly Consumer Financial Services Newsletter
Troutman Sanders
SEPTEMBER 25, 2023
The proposed rulemaking could redefine “data brokers” and “data aggregators,” and extend FCRA regulation to businesses that do not currently meet the FCRA’s definition of “consumer reporting agency.” On September 19, the CFPB issued guidance regarding the legal requirements that creditors must follow when using AI and complex models.
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