In May 2015, the CFPB issued a report, “Data Point: Credit Invisibles,” that documented the results of a research project it conducted to better understand the demographic characteristics of consumers without traditional credit reports or credit scores. The report concluded that the current credit reporting system is skewed toward certain populations and prevents them from accessing credit and taking advantage of other economic opportunities. Although the CFPB did not use the term “disparate impact,” the report had fair lending implications for both providers and users of credit reports and credit scores.

Earlier this week, the CFPB announced that it has released a brief, “Who are the credit invisibles?” detailing the report’s most significant findings and a checklist of action items for consumers who are looking to establish or rebuild credit.

The brief could prompt future action by the CFPB regarding the use of alternative credit reports and credit scores. Read more at JDSupra.