A research agenda, not completed reporting. These are the original topic questions and leads. Named companies, dates and outcomes require verification. Editorial operations and internal schemas remain private.

2. Credit scoring and underwriting

2.1 Scores and bureaus

  • FICO Score versions (8, 9, 10, 10T), VantageScore 3.0/4.0; FHFA decision on credit scores for GSE mortgages (VantageScore 4.0 acceptance, tri-merge vs. bi-merge — verify 2025 changes and implementation dates); FICO direct licensing program (verify)
  • Bureaus: Equifax, Experian, TransUnion; specialty agencies (ChexSystems, Clarity, LexisNexis, Early Warning)
  • Medical debt: bureau voluntary removals (2022–2023), CFPB medical debt rule (January 2025) and its vacatur (verify), state medical-debt reporting laws (verify)
  • Credit invisibility and thin files (CFPB estimates — verify latest)

2.2 Alternative data and cash-flow underwriting

  • Rent reporting, utilities/telecom (Experian Boost, UltraFICO), FICO Score XD, cash-flow scores (FICO/Plaid/Experian — verify products), Nova Credit (immigrants), Prism Data (verify)
  • Evidence on predictive lift and inclusion effects (FinRegLab studies — verify; label funders)
  • FCRA status of cash-flow data providers

2.3 AI/ML underwriting and fair lending

  • ECOA/Regulation B, disparate impact, less discriminatory alternatives search
  • Adverse action notice requirements with complex models (CFPB Circulars 2022-03 and 2023-03 — verify status after 2025 withdrawals of guidance)
  • Upstart CFPB no-action letter (2017/2020) and its termination in 2022; independent monitorship reports (Relman Colfax — verify)
  • State AI rules: Colorado AI Act (delayed effective date — verify), NYDFS guidance, Massachusetts AG settlement with a student lender over AI underwriting (2025 — verify)
  • EU AI Act classification of creditworthiness assessment as high-risk (verify application date), EU Consumer Credit Directive 2023/2225 (application November 2026 — verify)
  • Model risk management (SR 11-7) and explainability tooling
  • Link to Part 11 for AI governance depth

3. Buy now, pay later (BNPL)

3.1 Products and economics

  • Pay-in-4 (interest-free, merchant-funded), longer-term installment loans (interest-bearing, bank-partner originated), BNPL on virtual cards and in wallets, pay-later in debit card rails, BNPL for bills/rent/groceries
  • Merchant discount rates, consumer late fees, interest income, affiliate/advertising, card interchange (Affirm Card, Klarna Card — verify)
  • Funding: warehouse lines, forward-flow agreements with private credit, securitization (Affirm, Klarna, Zip — verify)
  • Players (verify): Affirm, Klarna (IPO September 2025 — verify), Afterpay/Cash App Afterpay (Block), Zip, Sezzle, PayPal Pay in 4/Pay Monthly, Apple Pay Later (shut down 2024) and Apple Pay installment integrations with Affirm/Klarna, Chase/Amex/Citi plan-it features, Tabby, Tamara, Scalapay, Alma, Clearpay (UK)

3.2 Credit reporting

  • Bureau announcements (2022) and actual furnishing practices by provider (verify which report pay-in-4 and to which bureaus)
  • FICO scores incorporating BNPL data (announced June 2025 — verify availability and lender adoption)
  • Evidence on BNPL "phantom debt" and stacking

3.3 Regulation (verify each)

  • U.S.: CFPB market monitoring report (September 2022); interpretive rule treating BNPL lenders as card issuers under Reg Z (May 2024) and its withdrawal (May 2025); state actions (New York BNPL licensing law enacted 2025 — verify regulations and effective date; California DFPI licensing under CFL); CFPB 2025 report on BNPL borrowers (verify)
  • UK: Consumer Credit Act exemption for interest-free deferred payment; legislation to bring BNPL (DPC agreements) under FCA regulation with regime start date (15 July 2026 — verify), FCA final rules and transitional registration
  • EU: Consumer Credit Directive 2023 brings BNPL into scope (verify dates)
  • Australia: BNPL regulated as credit under amendments effective June 2025 (verify), ASIC licensing
  • Others: New Zealand (verify), India (RBI digital lending rules on FLDG and BNPL — verify), Singapore BNPL code

3.4 Evidence

  • Usage and repayment: CFPB, Federal Reserve SHED, NY Fed SCE Credit Access Survey, company-reported late rates (label), academic studies on overspending and overdraft effects (verify: e.g., studies linking BNPL use to increased overdrafts)
  • Delinquency and charge-off data from filings/ABS

4. Earned wage access (EWA) and cash advance apps

4.1 Models

  • Employer-integrated EWA (DailyPay, Payactiv, Rain, Clair, Branch, ZayZoon, Tapcheck; UK: Wagestream/Stream, Hastee (failed — verify))
  • Direct-to-consumer (D2C) advance apps (EarnIn, Dave, Brigit (acquired by Upbound — verify), MoneyLion Instacash, Cleo, Albert, Klover, Varo Advance, Chime MyPay — verify)
  • Fees: instant transfer fees, subscriptions, "optional" tips, expedite fees; employer-paid models
  • Non-recourse vs. recourse; repayment by payroll deduction or debit

4.2 Regulatory treatment (verify each)

  • Federal: CFPB 2020 advisory opinion (employer-integrated, no-fee), rescinded/reinterpreted; proposed interpretive rule (July 2024) treating EWA as credit under TILA; withdrawal (2025); new advisory opinion on EWA not being credit (December 2025 — verify); Dave DOJ/FTC complaint (December 2024 — verify status)
  • State laws (build 50-state table): Nevada, Missouri, Kansas, Wisconsin, South Carolina, Utah, Arkansas, Louisiana, Connecticut (treats EWA as credit with fee caps — verify), Maryland (regulator position — verify), California DFPI MOUs and data collection/2023 findings on APRs (verify), New York AG actions against D2C providers (2025 — verify), DC AG suit against EarnIn (verify), others through 2026
  • Industry codes (American Fintech Council, Financial Health Network standards — verify)

4.3 Evidence

  • California DFPI data (average APR-equivalents, transaction frequency — verify)
  • GAO report on EWA (2023 — verify findings)
  • CFPB July 2024 data spotlight (verify)
  • Industry-funded surveys (Tier 4; note funders) vs. independent research

5. Personal loans, credit cards, and credit builders

  • Fintech personal lenders (verify): SoFi, LendingClub (bank), Upstart (bank partners and funding), Best Egg, Prosper, Avant, Oportun, OppFi (rent-a-bank litigation — verify), Happy Money, Achieve; marketplaces (LendingTree, Credible)
  • Credit cards via fintechs: Apple Card (issuer transition from Goldman Sachs — verify new issuer and date), Mission Lane, Petal (acquired by Empower — verify), Tomo, X1 (acquired by Robinhood), Bilt (verify issuer change), Chime/Varo credit-builder cards
  • Credit-builder loans and secured cards: Self, Kikoff, Chime Credit Builder, Grow Credit, Credit Strong, Varo Believe
  • Evidence: CFPB studies on credit-builder loans (2020 — verify), academic RCTs, "do they work" measurement framework (score change distributions, account closure, fees paid)

6. Rent-a-bank, preemption, and interest-rate caps

  • True-lender doctrine, Madden v. Midland (2015) and "valid-when-made" rules (OCC and FDIC 2020); OCC true lender rule (2020) repealed via CRA (2021)
  • State anti-evasion laws: Illinois Predatory Loan Prevention Act (36% APR cap, 2021), Colorado opt-out of DIDMCA Section 521 (effective July 2024; litigation — verify appellate status), Connecticut, Maine, and others considering opt-out (verify)
  • Military Lending Act 36% MAPR
  • Proposals for national rate caps (verify)

7. Small-business lending

  • Products: term loans, lines of credit, invoice factoring, revenue-based financing, merchant cash advances (MCAs), payments-platform lending (Shopify Capital, Square Loans, Stripe Capital, PayPal Working Capital, Amazon Lending — verify)
  • PPP through fintech lenders (2020–2021): volumes, fraud findings (House Select Subcommittee report December 2022 — verify), Kabbage/KServicing bankruptcy (verify)
  • State commercial financing disclosure laws: New York, California, Utah, Virginia, Florida, Georgia, Connecticut, Kansas, Missouri, Texas (verify each and effective dates)
  • MCA litigation (FTC and NY AG actions — verify, e.g., Yellowstone Capital)
  • CFPB Section 1071 small-business lending data rule: compliance dates extended and 2025 reconsideration (verify)
  • Evidence: Fed Small Business Credit Survey; approval and satisfaction by lender type

8. Debt collection, servicing, and private credit

  • Regulation F (2021); digital collection communications
  • Fintech servicing platforms; collections AI (link to Part 11)
  • Private credit forward-flow deals funding BNPL and consumer lenders (verify: e.g., Affirm, Klarna, PayPal BNPL receivables sales to KKR and others)
  • Performance and funding risks when credit markets tighten

9. Comparative cost analysis

Build an all-in cost methodology and worked, labeled examples comparing, for a $500 and $2,000 need over 6 weeks and 12 months:

  • Pay-in-4 BNPL (on time; one late payment)
  • Interest-bearing BNPL installment loan
  • Credit card at median APR (cite source) paid over time vs. paid in full
  • Personal loan
  • EWA employer-integrated (free vs. instant fee) and D2C app (with subscription and tip)
  • Payday loan (state-dependent)
  • Bank overdraft (fee per item; overdraft rule vacated via CRA in 2025 — verify)

Report fees in dollars and as APR-equivalents; explain limitations of APR for short-term products.

10. Workflows

Use the master workflow format for:

  • Comparing BNPL vs. credit card for a purchase
  • Building credit with fintech tools (what reports, to which bureaus, how to verify on reports)
  • Checking your credit reports and disputing errors
  • Reading a loan offer and computing true cost
  • Using EWA without fee stacking (how to see all fees; how to cancel subscriptions)
  • A small business comparing a term loan, line of credit, and MCA (factor rate to APR)
  • Handling hardship with a fintech lender (hardship programs, CFPB complaints, nonprofit counseling)

11. Timeline 2020–2026

  • PPP fintech lending and fraud findings
  • Upstart NAL termination; AI adverse-action circulars
  • BNPL growth, CFPB report, interpretive rule and withdrawal
  • EWA state laws and CFPB proposals/withdrawals/advisory opinions
  • Medical debt rule and vacatur
  • Colorado DIDMCA opt-out litigation
  • FHFA credit score changes; FICO BNPL score
  • UK BNPL regulation start; EU CCD2; Australia BNPL law
  • Fintech lender IPOs, funding deals, and failures