This paper examines the connections, similarities, and differences between consumer financial health and the financial health of small businesses.

The Financial Health Network submitted this letter in response to the CFPB’s request for information on consumer credit card markets on March 10, 2017. Like the CFPB, the Financial Health Network recognizes the important role that access to high-quality financial products plays in helping consumers improve and maintain their financial health. We believe that finance can be a force for good in people’s lives and that meeting consumers’ needs responsibly is ultimately good for both the consumer and the provider.

This paper addresses how employers can develop robust employee financial health strategies. By supporting the financial well-being of their workers, employers have the ability to promote staff engagement, improve productivity, and strengthen their brand reputation.

The Financial Health Network submitted its response to the CFPB’s request for information regarding use of alternative data and modeling techniques in the credit process on February 16, 2017. In the letter, the Financial Health Network acknowledges that the use of alternative data in the credit process poses both risks and benefits to consumers. The letter also states the Financial Health Network’s belief that consumers will be better able to achieve financial health if they have access to innovative credit products that are safe, affordable, and of high quality, enabling them to manage their day-to-day finances, weather financial shocks, and pursue longterm opportunities.

In this letter, the Financial Health Network supports the OCC’s leadership in encouraging innovation that can improve the lives and financial health of consumers and small businesses.