Q&A with Aire’s Legal Counsel — Tom Oscherwitz
After an esteemed career at the CFPB, Tom Oscherwitz joined us in March 2020. Our first hire based out of Washington DC, here’s a quick snapshot of his first few months with Aire, and life beyond.
Coffee count so far today (17:33)
☕️ ☕️ ☕️ — daily average
Aire-time
2. Tell us about your journey to becoming Aire’s first US hire?
A little unusually, I’ve spent my career switching between government service and fintech start-ups. At the millennium’s turn, I served as counsel in the US Senate Judiciary Committee and helped drive legislation to create key consumer protections for credit reports, such as fraud alerts and free annual file disclosures. That experience caused me to appreciate the extraordinary importance of credit reports. Most importantly, I learned how consumers depend on a fair credit evaluation for almost every financial milestone in their adult life: paying for college, getting their first car, obtaining a first mortgage, or even being assessed for an apartment or job.
I left ‘the Hill’ to work as an executive at a start-up that used advanced analytics to help US banks verify credit applicants. Having thought my days in government were over, when the Consumer Financial Protection Bureau launched in 2011, I couldn’t pass up the chance to join. I helped launch and then ran the CFPB’s national supervision program for consumer reporting agencies for four years. Then, seeing where the industry was headed, I built the CFPB’s program to monitor and oversee the use of Artificial Intelligence in financial services.
My second stint in government reignited my desire to innovate — I saw such a great need for it. Frankly, I am thrilled to join the Aire team.
3. What do you see as opportunities for Aire in the US?
From my vantage point as a former federal financial regulator, I can tell you that Aire brings several absolutely critical pieces to the table.
First, Aire obtains and validates data about a consumer’s circumstances directly from consumers themselves. The CFPB recently reported that 45 million consumers are credit invisible, which means that they have no credit file or a tissue-thin record at the three US nationwide credit bureaus. Aire can fill that hole by potentially providing insights on any consumer.
Second, Aire engages with consumers in real-time. Under the traditional credit reporting model, large companies send batch files to lenders with tradeline information typically on a monthly or bi-monthly basis. This data is valuable, but in the era of COVID-19, having information that is two weeks old raises a risk that financial institutions need to mitigate.
Finally, Aire provides context about how the consumers actually think about their financial circumstances and their ability to manage a loan. While past performance has predictive value, it is not the whole picture. The lending industry has underutilized insights that come from consumer’s perception of their own economic circumstances.
4. What uncomfortable forest* are you glad to have taken a walk in since arriving at Aire?
* At Aire, we’re not afraid to take the hard path. Even if it takes more time or creates more pain. We want to ensure we do it the right way.
I have a two-part answer. I spent my past few years in government, where excel spreadsheets too often serve as data management systems. Aire is a full-bore high tech company, with cutting edge technology. It's taken some sweat from me to catch up with the tech savants who work at Aire.
But, on a personal level, my actual hiring reflects Aire’s commitment to the ‘uncomfortable forest.’ While there is appeal in the Silicon Valley mantra of ‘move fast and break things’, what convinced me to join Aire was its commitment to doing the necessary, hard work to build its compliance systems. Aire recognized early on that to succeed in the US it had to win the trust and confidence of regulators and consumers. It’s telling that they hired a seasoned regulator as one of its first US employees. Applying new credit scoring technologies to meet the diverse regulatory requirements of the Fair Credit Reporting Act, the Equal Credit Opportunity Act, the Fair Housing Act and other regulations is not easy. What’s exciting about Aire is its commitment to stay the course, and build its technologies to operate seamlessly in the US regulatory system.
5. Tell us about the US credit market — how does it differ to the UK?
Stay tuned. I’m in my early days working with the UK credit market, so I just have a few initial impressions. One key difference is the UK’s adoption of Open Banking. While the fintech start-up culture is historically more established in the US, the UK — as Aire demonstrates — is catching up fast.
6. What are you most looking forward to getting your teeth stuck into next at Aire?
That’s a simple one: leveraging first-party data to help solve the credit invisibles problem in the US.
7. How do you navigate working in a different time zone? Share your hints and tips with us.
The US Army used to run a recruiting commercial with the slogan ‘we do more before nine AM than most people do all day.’ I’m really getting to appreciate that motto! But seriously, I do block mornings entirely for internal calls. And, I take advantage of the afternoons to focus on projects which require deep thinking.
Downtime
8. How do you stay up-to-date and keep your skills sharp?
I’m old school. My secret for staying up-to-date is to track the most compelling writers in the field and then read whatever they write. Let me give an example. In late 2017, I started working professionally on the intersection of AI and financial services regulation. I binge read writers like Gary Marcus, Solon Barocas, Martin Ford, and Cathy O’Neil to get up to speed.
But, word of mouth, especially in a policy-wonk town like DC, is essential too. I’m amazed at what I can learn from neighbors and colleagues at Happy Hour or even walking home from the Metro.
9. What are you learning right now?
How to give shorter answers to Q&As.
10. What’s been your favourite conference experience?
I love it when I go to conferences and find the participants so compelling, that I miss half the sessions because of coffee conversations.
— Thank you and welcome to Aire, Tom!
