Alex Lintner, Group President at Experian, recently had the chance to sit down with Peter Renton, creator of the Lend Academy Podcast, to discuss alternative credit data,1 UltraFICO, Experian Boost and expanding the credit universe. Lintner spoke about why Experian is determined to be the leader in bringing alternative credit data to the forefront of the lending marketplace to drive greater access to credit for consumers. “To move the tens of millions of “invisible” or “thin file” consumers into the financial mainstream will take innovation, and alternative data is one of the ways which we can do that,” said Lintner. Many U.S. consumers do not have a credit history or enough record of borrowing to establish a credit score, making it difficult for them to obtain credit from mainstream financial institutions. To ease access to credit for these consumers, financial institutions have sought ways to both extend and improve the methods by which they evaluate borrowers’ risk. By leveraging machine learning and alternative data products, like Experian BoostTM, lenders can get a more complete view into a consumer’s creditworthiness, allowing them to make better decisions and consumers to more easily access financial opportunities. Highlights include: The impact of Experian Boost on consumers’ credit scores Experian’s take on the state of the American consumer today Leveraging machine learning in the development of credit scores Expanding the marketable universe Listen now Learn more about alternative credit data 1When we refer to "Alternative Credit Data," this refers to the use of alternative data and its appropriate use in consumer credit lending decisions, as regulated by the Fair Credit Reporting Act. Hence, the term "Expanded FCRA Data" may also apply in this instance and both can be used interchangeably.
2018 was a whirlwind of a year – though it was not surprising when Google’s 2018 “most-searched” list showed Fornite GIFs ruled the internet, Black Panther was the most-Googled movie, and the Keto diet was trending (particularly in late December and early January, go figure). But, while Google’s most-searched terms of 2018 present pure pop-culture entertainment, they miss the mark on the trends we find most meaningful being principals of the financial services industry. What about the latest news in fintech? According to Business Insider, fintech companies secured $57.9 billion in funding in the first half of 2018 alone, nearing the previous annual record of $62.5 billion set in 2015. Taking it a step further, CBInsights reports that 24 of 39 fintech unicorns are based in North America. We won’t blame Google for this oversight. Faced with the harsh reality that the “most-searched” results are based on raw-data, perhaps it’s possible that people really do find Fortnite more exciting than financial services trends – but not us at Experian. We have been closely following disruption in the financial services space all while leading the charge in data innovation. When competing in environments where financial institutions vie for customer acquisition and brand loyalty, digital experience is not enough. Today’s world demands finance redefined – and fintechs have answered the call. Fintechs are, by far, among the most innovative technology and data-driven companies in the financial services industry. That’s why we built a team of seasoned consultants, veteran account executives and other support staff that are 100% dedicated to supporting our fintech partners. With our expert team and a data accuracy rate of 99.9%, there isn’t a more reliable fintech source. Perhaps this is one financial services trend that Google can’t ignore (we see you Google)! For more information regarding Experian’s fintech solutions, check out our video below and visit Experian.com/fintech.
Picking up where we left off, online fintech lenders face the same challenges as other financial institutions; however, they continue to push the speed of evolution and are early adopters across the board. Here’s a continuation of my conversation with Gavin Harding, Senior Business Consultant at Experian. (Be sure to read part 1.) Part two of a two-part series: As with many new innovations, fintechs are early adopters of alternative data. How are these firms using alt data and what are the results that are being achieved? In a competitive market, alternative data can be the key to helping fintechs lend deeper and better reach underserved consumers. By augmenting traditional credit data, a lender has access to greater insights on how a thin-file consumer will perform over time, and can then make a credit decision based on the identified risk. This is an important point. While alternative data often helps lenders expand their universe, it can also provide quantitative risk measures that traditional data doesn’t necessarily provide. For example, alternative data can recognize that a consumer who changes residences more than once every two years presents a higher credit risk. Another way fintechs are using alternative data is to screen for fraud. Fraudsters are digitally savvy and are using technology to initiate fraud attacks on a broader array of lenders, in bigger volumes than ever before. If I am a consumer who wants to get a loan through an online fintech lender, the first thing the lender wants to know is that I am who I say I am. The lender will ask me a series of questions and use traditional data to validate. Alternative data takes authentication a step further and allows lenders to not only identify what device I am using to complete the application, but whether the device is connected to my personal account records – giving them greater confidence in validating my identity. A second example of using alternative data to screen for fraud has to do with the way an application is actually completed. Most individuals who complete an online application will do so in a logical, sequential order. Fraudsters fall outside of these norms – and identifying these patterns can help lenders increase fraud detection. Lastly, alternative data can help fintech lenders with servicing and collections by way of utilizing behavioral analytics. If a consumer has a history of making payments on time, a lender may be apt to approve more credit, at better terms. As the consumer begins to pay back the credit advance, the lender can see the internal re-payment history and recommend incremental line increases. From your perspective, what is the future of data and what should fintechs consider as they evolve their products? The most sophisticated, most successful “think tanks” have two things that are evolving rapidly together: Data: Fintechs want all possible data, from a quality source, as close to real-time as possible. The industry has moved from “data sets” to “data lakes” to “data oceans,” and now to “data universes.” Analytics: Fintechs are creating ever-more sophisticated analytics and are incorporating machine learning and artificial intelligence into their strategies. Fintechs will continue to look for data assets that will help them reach the consumer. And to the degree that there is a return on the data investment, they will continue to capitalize on innovative solutions – such as alternative data. In the competitive financial marketplace, insight is everything. Aite Group recently conducted a new report about alternative data that dives into new qualitative research collected by the firm. Join us to hear Aite Group’s findings about fintechs, banks, and credit unions at their webinar on December 4. Register today! Register for the Webinar Click here for more information about Experian’s Alternative Data solutions. Don’t forget to check out part one of this series here. About Gavin Harding With more than 20 years in banking and finance Gavin leverages his expertise to develop sophisticated data and analytical solutions to problem solve and define strategies across the customer lifecycle for banking and fintech clients. For more than half of his career Gavin held senior leadership positions with a large regional bank, gaining experience in commercial and small business strategy, SBA lending, credit and risk management and sales. Gavin has guided organizations through strategic change initiatives and regulatory and supervisory oversight issues. Previously Gavin worked in the business leasing, agricultural and construction equipment sectors in sales and credit management roles.
There’s no shortage of buzz around fintechs shifting from marketplace challengers to industry collaborators. Regardless of fintech’s general reputation as market disruptors, a case can certainly be made for building partnerships with traditional financial institutions by leveraging the individual strengths of each organization. According to the World FinTech Report 2018, 75.5% of fintechs surveyed selected “collaborate with traditional firms” as their main objective. Whereas fintechs have agility, a singular focus on the customer, and an absence of legacy systems, traditional Financial Institutions have embedded infrastructure, scale, reach, and are well-versed with regulatory requirements. By partnering together, fintechs and other Financial Institutions can combine strengths to generate real business results and impact the customer experience. New stories are emerging – stories that illustrate positive outcomes beyond efforts exerted by one side alone. A recent report sponsored by Experian and conducted by the Filene Research Institute further explores the results of fintech and traditional FI partnerships by examining the experiences of six organizations: The outcomes of these relationships are sure to encourage more collaborative partnerships. And while leveraging each organization’s strength is a critical component, there’s much more to consider when developing a strategic approach. In the fast-moving, disruptive world of fintech, just what are the key elements to building a successful collaboration with traditional Financial Institutions? Click here to learn more. More Info on Marketplace Lending Read the Filene Report
Fintechs take on banks, technology, and finance as we know It. In the credit space, their reputation as a market disruptor precedes their definition. But now, as they infiltrate headlines and traditional finance as many know it – serving up consumer-centric, convenience-touting, access-for-all online marketplace lending – fintechs aren’t just becoming a mainstay within the financial spectrum’s vernacular. With their increasing foothold in the marketplace, they are here and they are gaining momentum. Since their initial entry to the marketplace in 2006, these technology-driven online platforms flaunt big data, actionable analytics and originations growing at exponential rates. Fintechs hang their hats on their ability to be the “anti-bank” of sorts. The brainchild of finance plus technology, their brands promise simple but powerful deliverables – all centered on innovation. And they market themselves as filling in the gaps commonly accepted as standard practices by traditional financial institutions. Think paperwork, less-than-instant turnaround times, a history of unwavering tradition, etc. Fintechs deliver a one-two punch, serving the marketplace as both lending companies and technology gurus – two pieces that financial institutions want and consumers crave. Now, as they grow more prominent within the marketplace, some are starting to pivot to test strategic partnerships and bring their strengths – technological infrastructure, speed and agility – to credit unions and other traditional financial institutions. According to the World FinTech Report 2018, 75.5% of fintechs surveyed want to collaborate with traditional financial services firms. The challenge, is that both fintechs and traditional financial institutions struggle with finding the right partners, efficiently working together and effectively scaling innovation. From competitors to collaborators, how can fintechs and traditional institutions strike a partnership balance? A recent report sponsored by Experian and conducted by the Filene Research Institute, explores this conundrum by examining the experiences of six financial institutions – some fintechs and some traditional FIs – as they seek to collaborate under the common goal of better serving customers. The results offer up key ingredients for fostering a successful collaboration between fintechs and traditional financial institutions – to generate real impact to the customer experience and the bottom-line. Rest assured, that in the fast-moving, disruptive world of fintech, effective partnerships such as these will continue to push boundaries and redefine the evolving financial services marketplace. Learn More About Online Marketplace Lending Download the Filene Report
Unsecured lending is increasing. And everyone wants in. Not only are the number of personal loans increasing, but the share of those loans originated by fintech companies is increasing. According to Experian statistics, in August 2015, 890 new trades were originated by fintechs (or 21% of all personal loans). Two years later, in August 2017, 1.1 million trades belonged to fintechs (making up 36% of trades). This increase is consistent over time even though the spread of average loan amount between traditional loans and fintech is tightening. While convenience and the ability to apply online are key, interest rates are the number one factor in choosing a lender. Although average interest rates for traditional loans have stabilized, fintech interest rates continue to shift higher – and yet, the upward momentum in fintech loan origination continues. So, who are the consumers taking these loans? A common misconception about fintechs is that their association with market disruption, innovation and technology means that they appeal vastly to the Millennial masses. But that’s not necessarily the case. Boomers represent the second largest group utilizing fintech Marketplace loans and, interestingly, Boomers’ average loan amount is higher than any other generational group – 85.9% higher, in fact, from their Millennial counterparts. The reality is the personal loan market is fast-paced and consumers across the generational spectrum appear eager to adopt convenience-based, technology-driven online lending methods – something to the tune of $35.7 million in trades. For more lending insights and statistics, download Experian’s Q2 2018 Personal Loans Infographic here. Learn More About Online Marketplace Lending Download Lending Insights
In just a few short hours, Vision attendees immersed themselves into the depths of the economy, risk models, specialty finance data, credit invisibles, student loan data, online marketplace lending and more. The morning kicked off with one of the most respected and trusted macroeconomists in the U.S., Diane Swonk. With a rap sheet filled with advising central banks and multinational companies, Swonk treated a packed house to a look back on what has transpired in the U.S. economy since the Great Recession, as well as launching into current state and speculating on the months ahead. She described the past decade not as “lost, but rather lagging.” She went onto to say this past year was transitional, and while markets slowed slightly during the months leading up the U.S. presidential election, good things are happening: We’ve finally broken out of the 2% wage rut Recruiting on college campuses has picked up The labor force is growing Debt-to-income levels have returned to where they were prerecession and Investment is coming back. “I believe we’ll see growth over 2% this year,” said Swonk. Still, change is underway. She commented on how the way U.S. consumer spending is changing, and of course we’re seeing a restructuring in the retail space. While JC Penney announces store closings, you simultaneously see Amazon moving from “click to brick,” dabbling in the opening of some actual storefronts. Globally, she said the economy is the strongest it has been in eight years. She closed by noting there is a great deal of political change and unrest in the world today, but says, “Never underestimate our abilities when we tap our human capital.” -- More than 100 attendees filled a room to hear about the current trends and the future of online lending with featured guests from Oliver Wyman, Marlette Funding and Lending USA. While speakers commented on the “hiccup” in the space last year with some layoffs and mergers, volume has continued to double every year for the past several years with roughly $40 billion in cumulative originations today. Panelists discussed the use of alternative data to decision, channel bias, the importance of partnerships and how the market will see fewer and fewer players offering just one product specialty. “It is expensive to acquire customers, so you don’t just want to have one product to sell, but rather a range,” said Sharat Shankar of Lending USA. -- The numbers in the student lending universe are astounding. In a session focused on the U.S. student loan market, new Experian data reveals there is $1.49 billion in total student loan outstandings. In fact, total outstandings have grown 21% over the past four years, while the number of trades have only grown 4%. Costs are skyrocketing. The average balance per trade has grown 17% over the past four years. “We don’t ration education in this country,” said Joe DePaulo of College Ave. Student Loans. “We give everyone access to liquidity when it comes to federal student loans – and it’s not like that in other countries.” While DePaulo notes the access is great, offering many students the opportunity to obtain higher education, he says the problem is with disclosures. Guardians are often the individuals filling out the FAFSA, but the students inherit the loans. Students, he says, rarely understand how much their monthly payment will ultimately be after graduation. For every $10,000 in student loans, he says that will generally equate to a $100 monthly payment. -- Tomorrow, Vision attendees will be treated to more breakout sessions and a concluding keynote with legendary quarterback Tom Brady.
It’s been a wild ride for the financial services industry over the past eight years. After the mortgage meltdown, the Great Recession and a stagnant economy … well, one could say the country had seen better days. Did you watch The Big Short last winter? It all came crumbling down. And then President Barack Obama entered the scene. Change was needed. More oversight introduced. Suddenly, we had the Affordable Care Act, the Dodd-Frank Wall Street Reform Act and the creation of the Consumer Financial Protection Bureau (CFPB). Taxes were raised on the country’s highest earners for the first time since the late-1990s. In essence, the pendulum swung hard and fast to a new era of tightened and rigorous regulation. Fast forward to present day and we find ourselves on the cusp of transitioning to new leadership for the country. A new president, new cabinet, new leaders in Congress. What will it all mean for financial services regulations? It’s helpful to initially take a look back at the key regulations that have been introduced over the past eight years. Mortgage Reform: Long gone are the days of obtaining a quick mortgage. New rules have required loan originators to verify and document the consumer’s income and assets, including employment status (if relied upon), existing debt obligations, mortgage-related obligations, alimony and child support. The CFPB has also expanded foreclosure protections for struggling borrowers and homeowners. Maintaining the health of the mortgage industry is important for the entire country, and updated rules have enhanced the safety and transparency of the mortgage market. Home values have largely recovered from the darkest days, but some question whether the underwriting criteria have become too strict. Combatting Fraud: The latest cyber-attack trends and threats come fast and furious. Thus, regulators are largely addressing the challenge by expecting banks to adhere to world-class standards from organizations such as the National Institute of Standards and Technology (NIST). The Federal Trade Commission (FTC) and the National Credit Union Administration (NCUA) implemented the Red Flags Rule in November 2008. It requires institutions to establish policies and procedures to identify and recognize red flags — i.e., patterns, practices or specific activities that indicate the possible existence of identity theft — that occur during account-opening activities, existing account maintenance and new activity on an account that has been inactive for two or more years. Loss Forecasting: The Dodd-Frank Act Requires the Federal Reserve to conduct an annual stress test of bank holding companies (BHCs), savings and loan holding companies, state member banks, and nonbank financial institutions. In October 2012, the Fed Board adopted the Comprehensive Capital Analysis and Review (CCAR) rules. This requires banks with assets of $50 billion or more to submit to an annual review centered on a supervisory stress test to gauge capital adequacy. In January 2016, Dodd-Frank Act Stress Testing (DFAST) was introduced, requiring bank holding companies with assets of $10 billion or more to conduct separate annual stress tests known as “company-run tests” using economic scenarios. Every year regulators expect to see continued improvement in stress-testing models and capital-planning approaches as they raise the bar on what constitutes an acceptable practice. CFPB: No longer the new kids on the block, the CFPB has transitioned to an entity that has its tentacles into every aspect of consumer financial products. Mortgage lending was one of their first pursuits, but they have since dug into “ability-to-pay underwriting” and servicing standards for auto loans, credit cards and add-on products sold through third-party vendors. Now they are looking into will likely be the next “bubble,” – student lending – and educating themselves about online marketplace lending. Data Quality: Expectations related to data quality, risk analytics, and regulatory reporting have risen dramatically since the financial downturn. Inaccuracy in data is costly and harmful, slows down the industry, and creates frustration. In short, it’s bad for consumers and the industry. It’s no secret that financial institutions rely on the accuracy of credit data to make the most informed decisions about the creditworthiness of their customers. With intense scrutiny in this area, many financial institutions have created robust teams to handle and manage requirements and implement sound policies surrounding data accuracy. --- This is merely a sliver of the multiple regulations introduced and strengthened over the past eight years. Is there a belief that the regulatory pendulum might take a swing to other side with new leadership? Unlikely. The agenda for 2017 largely centers on the need to improve debt collections practices, enhance access to credit for struggling Americans, and the need for ongoing monitoring of the fintech space. Only time will tell, but one thing is certain. Anyone involved in financial services needs to keep a watchful eye on the ever-evolving world of regulation and Washington.
With the rapid growth in the number of online marketplace lenders , and projections the field will continue to grow in 2016, winning the race to greater revenue and profitability is key to survival. In 2014, online marketplace lenders issued loans totaling around $12 billion in the United States. In a recent report, Morgan Stanley said it expects the U.S. number to grow to $122 billion by 2020, and the global number will surpass $280 billion in the same time period. Investors fear growth in acquisition costs will erode profitability as more online marketplace lenders enter the market. And as portfolios grow, there will be a need for greater sophistication as it pertains to managing accounts. Online marketplace lenders use a variety of different models to generate revenue including charging interest, loan origination and other service fees. However, regardless of the model, there are typically three key levers all should monitor in order to increase their odds for a profitable and sustainable future. 1. Cost per Account (CPA) CPA is more than a simple calculation spreading marketing cost across new account volume. Rather, it is a methodical evaluation of individual drivers such as channel lead cost, success rates, identity verification and cost of marketing collateral. When measured and evaluated at the granular lever, it is possible to make the most informed strategic decisions possible. Marketplace lenders will have to go much deeper than simply evaluating lead costs, clicks, completed and accepted applications, and funding/activation including whether customers take the loan proceeds or use a revolving product. Don’t forget ID verification and the costs associated with risk mitigation and determining if the low-risk customers are deciding to apply elsewhere. In addition, take into account marketing costs including collateral and channel strategies including any broadcast media, direct mail, web and social media expenses. Evaluate results across various product types – and don’t forget to take into account web content and layout, which can impact all metrics. 2. First Pay Default (FPD) FPD is not a long-term loan performance measure, but it is a strong indicator of lead source and vintage quality. It will most closely correlate to long-term loan performance in short-term loans and non-prime asset classes. It is also a strong indicator of fraud. The high value of online loans, combined with the difficulty of verifying online applicants, is making online lenders a prime target for fraud, so it is essential to closely monitor FPD. Online lenders’ largest single cost category is losses from unpaid loans with fraud serving as a primary driver of that number. It is important to evaluate FPD using many of the same segments as CPA. Online lenders must ask themselves the tough questions. Is a low-cost lead source worthwhile? Did operational enhancements really improve the customer experience and credit quality? 3. Servicing Online account servicing is generally the least costly means of servicing customers, an obvious advantage for online marketplace lenders. However, a variety of factors must be considered when determining the servicing channels to use. These include avoidance of customer backlash and regulatory scrutiny, servicing channel effectiveness in providing feedback regarding product design and administration, servicing policies and marketing collateral. Already, we know the legal and regulatory landscape will evolve as policy makers assess the role of marketplace lending in the financial system, while a recent federal appeals court ruling increases the risk that courts could deem some loans void or unenforceable, or lower the interest rates on them. An effective customer complaint escalation policy and process must also be created and allow for situations when the customer is not “right.” Voice of the customer (VOC) surveys are an effective method of learning from the customer and making all levels of staff know the customer better, leading to more effective marketing and account servicing. Lastly, online lenders can’t ignore social media. They should be prepared for customers, especially millennials, to use it as a means to loudly complain when dissatisfied. But also remember that the same media can be an excellent medium for two-way engagement and result in creating raving fans. A Final Consideration As online marketplace lenders continue to come of age, they are likely to find themselves facing increased competition from incumbent consumer lenders, so optimizing for profitability will be essential. Assessing these three key areas regularly will help in that quest and establish their business for a sustainable future. For more information, visit www.experian.com/marketplacelending.
The world of online marketplace lending has grown tremendously over the past several years. Still, for as much hype as it has received, it’s important to note the sector represents only 1.1 percent of unsecured loans and 2.5 percent of small business loans in the United States. While the industry is still in its infancy, it's expected to grow at an annual rate of 47 percent in the U.S by 2020, according to Morgan Stanley. And as it transitions from its “start-up” phase into “adolescence,” many expect it will become a high-growth, mature and stable market, bringing great benefit to consumers of financial services. So what does the future hold for online marketplace lenders? Who better to weigh in than those in the space, going through the evolution, seeing challenges first-hand and keeping a pulse on where they need to invest in order to survive. This video features a diverse group of leaders in the online marketplace lending industry. // Peter Renton, Founder, Lend Academy Scott Sanborn, COO, Lending Club Sam Hodges, Co-founder, Funding Circle USA Andrew Smith, Partner, Covington & Burling Joseph DePaulo, CEO, College Ave. Kathryn Ebner, VP, Credibly Without stealing all of their thunder, a few key themes emerged for 2016. Online marketplace lenders will look to expand their product offerings into all credit verticals – personal loans, auto, student, small business and beyond. Expect competition to continue to heat up. Large institutional investors will increasingly back and test the space. Some players will partner with large banks. Many will explore scoring with the use of alternative data. Innovations to come in customer service and product expansion. Bottom line, alternative finance doesn’t seem so “alternative” anymore. As such, competition will heat up, and regulators will continue to keep an eye on business practices, processes and what it all means for consumers. To learn more about online marketplace lending, visit https://www.experian.com/business-services/landing/marketplace-lending.html
Last December, American Banker named online marketplace lending its innovation of the year as a result of the “industry’s rapid growth and evolution.” Meanwhile, in 2015, millennials scored headlines in nearly every publication imaginable – industries, politicians and academics all trying to understand and articulate how the now largest-living generation will influence how we work, live and lead. So perhaps it’s no surprise the two hot topics have collided this year. Gen Y is tech-dependent and Internet-enabled. They have increasingly grown to expect the tools and services they use to be available online, including anything and everything in the financial services space. Marketplace lenders are ever-so eager to sweep in and serve. Online and mobile solutions are certainly one thing, but Experian’s latest research reveals this generation is also very receptive to “non-bank” lenders for the ease, speed and accessibility they provide. 47 percent of millennials said they are likely to use alternative finance sources in the near future 57 percent reported they are willing to use alternative companies and services that innovate to meet their needs 13 percent said they’ve already taken out a loan from an alternate or non-bank lender As they come of age, hitting those big milestones – college graduations, marriage, starting families, making home purchases – Gen Y is wading through its financial options. Research and logic suggest millennials will without a doubt have a greater openness toward nontraditional banking, representing a huge market for online marketplace lenders. For the millennial entrepreneurs especially, marketplace lending is proving to be a good fit. “They are on the earlier curve of their small business ownership and entrepreneurial paths,” David Solis, sales performance manager at Bank of America, told CNN Money. “It makes sense they’re going to be pursuing alternative forms of lending.” Affluent millennials are another segment open to alternative financial services. A 2015 LinkedIn study on this specific target stated affluent millennials are particularly likely to envision a cashless, sharing-based economy in the future, where banks no longer serve as their primary financial institutions. Nearly seven out of 10 affluent millennials are likely to consider such offerings outside of the traditional financial services space, compared to just 47 percent of affluent Gen X’ers. The millennial generation may not fully understand all products traditional banks offer, since they rarely set foot in “brick-and-mortar” establishments, but they are a prime market for online investing and lending services. They’re more experimental, more digital, less loyal. In short, they are looking for financial services that are as tech-savvy as they are; those who don’t keep up may get left behind, and online marketplace lenders are certainly positioning themselves to win over this generation. To be most successful in capturing this highly sought-after generation, online marketplace lenders will need to continue to innovate both in terms of differentiating their product offerings and getting more sophisticated in their targeted marketing approach. As the online marketplace continues to expand with more players, heating up with increased competition, segmentation strategies will be key in finding the right borrowers and matching them with the right offer. As we head into 2016, there is no doubt many will continue to monitor the financial services trends emerging. Chances are online marketplace lenders and millennials will likely be attached to many of the headlines. For more information, visit www.experian.com/marketplacelending.
Understanding the Impact of New Marketplace Lending Regulations The online marketplace lending sector has enjoyed unprecedented growth these past few years. According to a recent Morgan Stanley research report, the volume of loans extended by online marketplace lenders in the United States has doubled every year since 2010, hitting $12 billion last year. Some analysts speculate this growth will continue at a compound annual rate of 47 percent through 2020. The market’s growth, coupled with new, disruptive lending models, is now prompting regulators in Washington to raise questions about the potential opportunities and challenges for consumers, small businesses, and the safety and soundness of our financial system. Last July, the Treasury Department issued a request for information to better understand the benefits and risks associated with new online lending platforms and other “fin-tech” startups. The Treasury’s RFI sought information about how these entities’ business models differ from traditional lenders, their impact on financially underserved consumers, and ultimately whether the regulatory framework should evolve to ensure the safe growth of this emerging marketplace. They were also interested in how online lenders were assessing credit risk of borrowers. Most comments the Treasury Department received from online lenders focused on the positive impact that innovation in financial services could have on consumers and small businesses. For example, in an open letter to the Treasury, Lending Club Founder and CEO Renaud Laplanche stated his company’s role in “bringing more transparency, removing friction, reducing systemic risk by requiring a match between assets and liabilities, and offering traditional banks … the opportunity to participate on our platform and benefit from the same cost reductions from which our other borrowers and investors benefit.” Laplanche emphasized the benefits to consumers by noting that “over 70 percent of borrowers on our platform report using their loan to pay off an existing loan or credit card balance and report that the interest rate on their Lending Club loan was an average of seven percentage points lower than they were paying on their outstanding debt or credit cards.” For small businesses, Laplanche explained how commercial loans less than $250,000 tend to be underserved by traditional lenders. “Bank loans from $100k to $250k have fallen 22 percent since 2007, during a period when bank loans of $1 million or greater increased by 56 percent,” he wrote. “Our platform’s automated processes allow us to provide smaller commercial loans that are less available more economically than traditional banks can.” Meanwhile, some commenters called for regulators to increase oversight of the marketplace to provide more certainty. In a joint comment letter, the American Bankers Association and Consumer Bankers Association argued that all lenders — regardless of medium by which they deliver loans — should operate under the same rules and standards. They highlighted the numerous consumer protections in place to protect borrowers — from transparency in pricing, to fair debt collection methods, and data protection — and advocate for these protections to apply in all bank-like activities involving lending or servicing. But what about the Consumer Financial Protection Bureau (CFPB)? The CFPB will take a leadership role to ensure marketplace lenders comply with the fair lending and consumer financial protection laws that the CFPB has authority to enforce. The CFPB has not made any direct notice to the online lending marketplace specifically, but it did issue a notice in October 2014 saying it had no intention of bringing enforcement actions against companies that offer innovative financial products — so long as they benefit consumers. Meanwhile, it is also likely the Federal Trade Commission and state attorneys general will increase their focus on the online lending segment, especially as it relates to how products and services are marketed. The FTC held a symposium on Oct. 30 to examine online lead generation and consumer protection in the lending and education industries. The FTC workshop raised questions about the potential consumer protection challenges of this advertising medium used heavily by online lenders. In particular, there were calls for greater transparency in the use of lead generation, including more information on the ways consumer data is collected through lead-gen websites and how it is used and shared. Online marketplace lenders should expect to stay under the regulatory spotlight – because that’s what success often brings. The sector can avoid undue burdens by ensuring compliance with existing laws and adopting and following industry best practices. For more information, visit www.experian.com/marketplacelending.