Q&A with AFSA on the State of Alternative Data

by Kerry Rivera 5 min read July 18, 2018

As more financial institutions express interest and leverage alternative credit data sources to decision and assess consumers, lenders want to be assured of how they can best utilize this data source and maintain compliance.

Experian recently interviewed Philip Bohi, Vice President for Compliance Education for the American Financial Services Association (AFSA), to learn more about his perspective on this topic, as well as to gain insights on what lenders should consider as they dive into the world of alternative credit data.

Alternative data continues to be a hot topic in the financial services space. How have you seen it evolve over the past few years?

It’s hard to pinpoint where it began, but it has been interesting to observe how technology firms and people have changed our perceptions of the value and use of data in recent years. Earlier, a company’s data was just the information needed to conduct business. It seems like people are waking up to the realization that their business data can be useful internally, as well as to others.  And we have come to understand how previously disregarded data can be profoundly valuable. These insights provide a lot of new opportunities, but also new questions.  I would also say that the scope of alternative credit data use has changed.  A few years ago, alternative credit data was a tool to largely address the thin- and no-file consumer. More recently, we’ve seen it can provide a lift across the credit spectrum.

We recently conducted a survey with lenders and 23% of respondents cited “complying with laws and regulations” as the top barrier to utilizing alternative data. Why do you think this is the case? What are the top concerns you hear from lenders as it relates to compliance on this topic?

The consumer finance industry is very focused on compliance, because failure to maintain compliance can kill a business, either directly through fines and expenses, or through reputation damage. Concerns about alternative data come from a lack of familiarity. There is uncertainty about acquiring the data, using the data, safeguarding the data, selling the data, etc. Companies want to feel confident that they know where the limits are in creating, acquiring, using, storing and selling data.

Alternative data is a broad term. When it comes to utilizing it for making a credit decision, what types of alternative data can actually be used?

 Currently the scope is somewhat limited. I would describe the alternative data elements as being analogous to traditional credit data. Alternative data includes rent payments, utility payments, cell phone payments, bank deposits, and similar records. These provide important insights into whether a given consumer is keeping up with financial obligations. And most importantly, we are seeing that the particular types of obligations reflected in alternative data reflect the spending habits of people whose traditional credit files are thin or non-existent.  This is a good thing, as alternative data captures consumers who are paying their bills consistently earlier than traditional data does. Serving those customers is a great opportunity.

If a lender wants to begin utilizing alternative credit data, what must they know from a compliance standpoint?

I would begin with considering what the lender’s goal is and letting that guide how it will explore using alternative data. For some companies, accessing credit scores that include some degree of alternative data along with traditional data elements is enough. Just doing that provides a good business benefit without introducing a lot of additional risk as compared to using traditional credit score information. If the company wants to start leveraging its own customer data for its own purposes, or making it available to third parties, that becomes complex very quickly.  A company can find itself subject to all the regulatory burdens of a credit-reporting agency very quickly. In any case, the entire lifecycle of the data has to be considered, along with how the data will be protected when the data is “at rest,” “in use,” or “in transit.” Alternative data used for credit assessment should additionally be FCRA-compliant.

How do you see alternative credit data evolving in the future?

I cannot predict where it will go, but the unfettered potential is dizzying. Think about how DNA-based genealogy has taken off, telling folks they have family members they did not know and providing information to solve old crimes. I think we need to carefully balance personal privacy and prudent uses of customer data. There is also another issue with wide-ranging uses of new data. I contend it takes time to discern whether an element of data is accurately predictive.  Consider for a moment a person’s utility bills. If electricity usage in a household goes down when the bills in the neighborhood are going up, what does that tell us? Does it mean the family is under some financial strain and using the air conditioning less? Or does it tell us they had solar panels installed? Or they’ve been on vacation?  Figuring out what a particular piece of data means about someone’s circumstances can be difficult.

About Philip Bohi

Philip joined  AFSA in 2017 as Vice President, Compliance Education. He is responsible for providing strategic direction and leadership for the Association’s compliance activities, including AFSA University, and is the staff liaison to the Operations and Regulatory Compliance Committee and Technology Task Forces. He brings significant consumer finance legal and compliance experience to AFSA, having served as in-house counsel at Toyota Motor Credit Corporation and Fannie Mae. At those companies, Philip worked closely with compliance staff supporting technology projects, legislative tracking, and vendor management. His private practice included work on manufactured housing, residential mortgage compliance, and consumer finance matters at McGlinchey Stafford, PLLC and Lotstein Buckman, LLP. He is a member of the Virginia State Bar and the District of Columbia Bar.

Learn more about the array of alternative credit data sources available to financial institutions.

Related Posts

Building for Bots in the AI Age: Separating Legitimate Agents From Fraudsters

See how NeuroID helps businesses distinguish legitimate AI agents from fraud bots, while Agent Trust verifies agent-initiated transactions.

October 29, 2026 by Laura Burrows
2026 Retail Banking Identity and Fraud Report 

Learn how banks can convert rising fraud investment into protection customers recognize, value and feel in our recent report. Read more!

October 28, 2026 by Laura Burrows
One Platform, Fewer Handoffs, Faster Decisions

The average credit union manages between 100-300 vendor relationships, and nearly a third have no dedicated staff managing them. What was supposed to drive efficiency is stunting growth and compromising the member experience. Application volume is continuing to rise, and consumers expect a loan decision at digital speed. But for credit unions, meeting that expectation isn't the only goal. They must also continue to make the right lending decisions while also prioritizing risk management. The institutions pulling ahead aren't the ones with the most tools. They're the ones that have turned credit, fraud and decisioning into a single, coordinated system. A single loan decision touches: Credit data Identity verification Fraud signals Decisioning logic Reporting Rarely does all of that live in one place. More often, it’s stitched together across separate platforms, each with its own contract and its own support line. When a credit view and a fraud view are generated separately, they must be reconciled instead of read together in the same instant. Every handoff is a place where a decision slows down and a signal gets missed. It's why a fraud pattern that would be obvious next to the credit file often surfaces only after the funds are already gone. Fragmentation also makes it harder to optimize lending strategies over time. When data, analytics and decisioning are disconnected, credit unions have less visibility into what's working, what's changing and where strategies need to be adjusted. An integrated decisioning ecosystem closes those seams by design, with credit, fraud and lending strategy running on one platform and accessed through a single Application Programming Interface (API). Identity and compliance capabilities can be an integrated decisioning flow. The data doesn't need to be reconciled after the fact because it was never separated in the first place. Stop overengineering, start removing friction When decisioning underperforms, the instinct is to build something more custom: a proprietary model, tighter segmentation, more configuration.  Custom modeling has its place for institutions with the scale and data to justify it. But often, for small or mid-sized credit unions, the bigger opportunity is a flexible decisioning strategy that uses a strong, continuously refreshed model. This shouldn't be either/or. The right approach gives credit unions a strong decisioning strategy today, with the ability to introduce more customized analytics and modeling as their needs evolve.  The same principle applies to strategy management: credit unions can gain greater control through self-service capabilities as they build a more sophisticated data science team.   That kind of flexibility is important as credit unions modernize their decisioning infrastructure. Research surveying more than 2,000 senior credit risk and fraud decision-makers across 11 countries found that organizations investing in unified platforms and modern infrastructure are moving faster and realizing the greatest Return on Investment (ROI).   As their needs evolve, credit unions can adjust decisioning strategies without introducing another layer of technology or relying on third parties to make every change. Until self-service is the right fit, choose a partner that understands what makes your credit union’s membership and risk appetite different from others.  Same member, same afternoon, faster answer Consider a credit union growing its auto and personal loan originations.  A member applies for an auto loan on Saturday afternoon. Credit data, identity and fraud signals are read together in a single real-time pass instead of separate reviews:  Most applications resolve immediately, approved or declined based on a more comprehensive view of the applicant. A smaller number are flagged for quick step-up verification and cleared within minutes. Only genuinely ambiguous cases reach an underwriter, who is working from one complete picture instead of reconciling multiple signals. The member has an answer before the weekend is over. The credit union books the loan before competitors even open on Monday. Built to scale This kind of process holds up today. However, the better test is whether it holds up eighteen months from now when application volume has grown, new products are live and the data flowing through the system looks nothing like it does right now. Future-proofing isn't only about handling more volume. It's about having room to be nimbler and make adjustments as quickly as the market changes. A credit union that relies on standard models within a decisioning strategy may want more customized analytics and greater control over its strategies tomorrow. Connect with us With more than three decades of credit expertise and one of the industry's largest data footprints, Experian helps credit unions do more than solve this year's friction. We're helping to build a decisioning foundation that scales, so growth becomes something the system absorbs, rather than something it must be rebuilt around. Explore More

October 21, 2026 by Zohreen Ismail

Subscribe to our Newsletter

Enter your name and email for the latest updates.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Subscribe to our Newsletter

Don't miss out on the latest industry trends and insights!
Subscribe