Comments to Office of the Comptroller of the Currency's Advance Notice of Proposed Rulemaking Regarding National Bank and Federal Savings Association Digital Activities (Docket Id Occ-2019-0028)

This is a response to the Office of the Comptroller of the Currency's Advance Notice of Proposed Rulemaking for information to help in evaluating the regulatory environment for the digital activities of national banks and federal savings associations. In this comment, we raise concerns relative to consumer protection broadly and specifically as to fair lending and consumer education problems associated with the use of alternative data and machine learning in credit underwriting.