You have been hired as a regulatory analyst for Firm A, a non-bank lender with $11 billion in assets that specializes in refinancing student loans. For credit decisioning, Firm A's machine learning models calculate a credit risk score based on credit reports and 75,000 data points (such as shopping habits) collected from various sources. Firm A's posts each Borrower's calculated credit risk score and the loan amount for potential investors to bid on. Once an investor bids on a loan with a particular interest rate, the Borrower can choose to accept the loan. Once the Borrower accepts, the loan documents listing "WebBank, an Utah-chartered bank" as the lender are presented for the Borrower's electronic signature. After a few days, the loan is assigned to Via, who then assigns the loan to the investor.

3. Your assignment is to assess regulatory risks with respect toconsumer protection laws. Identify the facts that give rise to consumer protection concerns, identify the relevant laws, apply the laws to the facts, and determine whether Firm A's practices could be problematic. If so, what steps should be taken to mitigate the risks?

a. Identify Facts (use bullet points):

b. Rule(s) and Relevant Cases (use bullet points) that Apply to the Facts:

c. Application/Analysis of the Rules/Cases to the Facts:

d. Conclusion/Recommendation Based on your Analysis: