CFPB Announces First No-Action Letter to Upstart

September 14, 2017

On Thursday, September 14, 2017, the CFPB announced that a no-action letter was issued to Upstart Network, Inc., who uses alternative data to make credit and pricing decisions. The no-action letter mandates that Upstart will regularly report lending and compliance information to the CFPB to mitigate risk to consumers and aid the Bureau’s understanding of the real-world impact of alternative data on lending decision-making.


Upstart Network, Inc. is based in San Carlos, California, and provides an online lending platform for consumers to apply for personal loans, including credit card refinancing, student loans, and debt consolidation. Upstart evaluates consumer loan applications using traditional factors such as credit score and income, as well as incorporating non-traditional sources of information such as education and employment history.


The goal of the CFPB’s no-action letter program is to facilitate consumer-friendly innovations where regulatory uncertainty may exist for certain emerging products or services.