For decades, consumer lending has leaned on one idea: if the credit file looks good, the borrower is safe. But in 2026, that logic is getting stress-tested by reality.

Because a growing share of “good” borrowers barely exists in traditional credit data at all.

The bulletin points to a hard number that reframes the whole debate: traditional credit data excludes 45 million U.S. consumers due to thin files, no files, or unscorable histories. That’s not a rounding error. That’s a market segment large enough to change portfolio growth plans, acquisition costs, and competitive positioning overnight.

Why traditional credit scores are losing their monopoly

A standard credit score is a summary of past credit behavior. Useful, yes, but increasingly incomplete.

Cash-flow data tells a different story: income consistency, recurring expenses, liquidity buffers, and how someone actually manages money month to month. In plain terms, it can answer the question lenders truly care about:

Can this person afford the payments starting now?

This is why “cash-flow underwriting” has moved from innovation theater to real underwriting strategy.

The regulatory catalyst (and why the market keeps moving anyway)

Momentum didn’t come from technology alone.

In October 2024, the CFPB finalized its Personal Financial Data Rights rule implementing Section 1033 of Dodd-Frank, aimed at enabling consumer-permissioned access to financial data via secure APIs. Then in October 2025, a federal court issued a preliminary injunction, pausing enforcement and compliance deadlines while the CFPB reconsiders.

If you’re expecting lenders to wait on the sidelines until every detail is settled, the bulletin’s message is clear: that’s not what’s happening.

Even with uncertainty, the infrastructure for accessing cash-flow data keeps advancing, because the business case is too strong.

The mainstream moment: UltraFICO brings cash-flow into “standard” lending

Here’s the turning point highlighted in the bulletin:

In November 2025, FICO and Plaid introduced UltraFICO, positioned as the first “traditional” score to fully incorporate real-time cash-flow data and importantly, accessible to lenders already using FICO consumer credit score products.

That matters because it lowers friction. No custom scoring stack required. No “special program” that never scales. The path to deployment becomes much shorter.

Who benefits first: the segments lenders have struggled to serve

The bulletin calls out the opportunity hiding in plain sight:

• Recent graduates who manage money responsibly but don’t have credit depth

• Immigrants who arrive without a U.S. credit footprint

• Gig workers whose income is real, but doesn’t fit old underwriting templates

And it cites the Federal Reserve Board’s October 2025 analysis on alternative data, including “credit invisibles” and “invisible primes” (people who look risky in traditional scores, despite low default propensity).

What to do now (if you’re a lender or fintech)

If you want this shift to improve approvals and risk outcomes, focus on execution:

• Design decisioning around income stability + expense burden + liquidity signals

• Treat data access and compliance as a product capability, not a one-off integration

• Start where the upside is clearest: thin-file segments and high-CAC acquisition channels

The winners in 2026 won’t be the teams with the most data. They’ll be the teams that turn better data into consistent, auditable decisions at scale.

Sources

1. Watterson, S. (2026). Open Banking: The Credit Data Revolution That Lenders Cannot Afford to Miss. Banking & Payments Bulletin (January–February 2026, Issue 462). Datos Insights.

2. Datos Insights. (2025, Q2). Survey of 870 global consumer lending institutions (cash-flow underwriting / challenges with traditional credit data). Cited in Banking & Payments Bulletin (Jan–Feb 2026).

3. Datos Insights. (n.d.). A New Age of Underwriting Ushered in by Cash Flow Data. Referenced for further analysis in the bulletin.

4. Federal Reserve Board. (2025, October). Alternative Data: Expanding Access to Credit. Referenced in the bulletin (segments “credit invisibles” and “invisible primes”).

5. Consumer Financial Protection Bureau (CFPB). (2024, October). Personal Financial Data Rights rule (Section 1033, Dodd-Frank). Referenced in the bulletin, including the enforcement pause due to a preliminary injunction in Oct 2025.