Cross River Bank/ARIX Lending Criteria as of 2017
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For those familiar with the industry gobbledigoop this is Upstarts request for a "no action letter" from the CFPB, essentially a statement from the CFPB that there is no pending CFPB investigation or regulatory action in progress as of a certain date and time. It is unknown to me if this request was granted or not, but the application is likely more informative as to the inner workings of fintech institutions issuance of credit and the criteria of same than anything I've seen elsewhere.
The criteria described in this letter are the fundamental principals coded into a proprietary software API called ARIX which Cross River Bank, the actual chartered bank lender behind startups such as upstart and Affirm through it's 'Marketplace Lending' or informally 'rent-a-charter' or again, formally, it's 'banking-as-a-service' service (BAAS). ARIX is proprietary software API used by Cross River to take in credit applications originated by Affirm, Upstart, and others through their user interfaces (which make no mention of this) and then report back a nearly always automated decision based on the criteria I will publish shortly instead of attempting to quote.
Once the ARIX documentation I have compiled has been uploaded I will link to that here.
It is difficult to find explicit documentation of a US financial institutions lending origination criteria, due to industry concern that this could enable nefarious applicants to "game" their application process and reduce the banks enormous profit margins through the submission of fraudulent applications.
To my knowledge this is the most recent publicly available documentation of mega-fintech lender Cross River Bank of NJ's (Affirm, Upstart, numerous others) exact lending criteria.
While the criteria described on this publicly available CFPB document describes the origination criteria specifically for UPSTART NETWORK personal loans and credit cards, knowing these criteria can be informative for users of Affirm, Best Egg, RocketLoans, Rocketmortgage Coinbase and (transfer)Wise - as they are going to be using fundamentally similar data sources and risk screening criteria in their automated adverse action decisions, as all originate from Cross River Bank, the 'true' lender - through its proprietary ARIX software which I will be uploading the complete documentation for separately.
This upload is entered into the public domain along with the descriptive text of my own authorship. The pdf itself is exempt from copyright law under fair use doctrine as being substantially in the public interest and furthermore, a publication of the U.S. Government and therefore doubly exempt from any copyright or claim as to a claimant's right (voided through its submission to a public agency not exempt from public records law) to proprietary sources and methods.
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