Safety and soundness
Upstart partners specify the credit box, risk tolerance, and geographic focus of their lending program while monitoring loan performance and adjusting lending volumes as needed to support their overall safety and soundness efforts. Upstart’s proven culture of effective risk management coupled with strong loan performance assists lending partners with demonstrating the health of their lending program.
Upstart staff includes dedicated teams of experienced professionals that are accountable for management and oversight of key risk areas: Model Risk Management, Technology Risk, Fraud and Financial Crimes Risk, Compliance and Regulatory Risk, Operational Risk, and Enterprise Risk. Results of each risk management program are proactively shared with lending partners to support their ongoing oversight.
Lender oversight and third-party validation
Upstart offers its lending partners a significant amount of program configurability, model transparency, and audit results to inform their ongoing program maintenance and decisions.
Information supplied includes:
- Upstart’s internal policies and procedures
- Applicant level data
- Daily loan performance and loan origination data
- Results of Upstart’s testing and monitoring activities
- Complaint Reporting
- Detailed model documentation
- 3rd party audit and validation reports
Using the data provided, Upstart lending partners are able to meet all regulatory requirements related to third-party oversight. In 2022, Upstart partners had successful exams with the Consumer Financial Protection Bureau, Office of the Comptroller of the Currency, Federal Deposit Insurance Corp., National Credit Union Administration, and state regulators.
- Compliance policy and program audit (Treliant)
- BSA/AML audit (Forvis)
- Regulatory exams (direct and indirect)
- Penetration tests
- SSAE 18 Type 2 (Deloitte)
- 3rd party model and FL validation (Kroll)
Ongoing partner support
As part of our post-launch support, we provide convenient access to the information and data that Upstart supplies through a dashboard that tracks loan performance in near real time and allows partners to reconfigure their lending programs on demand.
Our Customer Success and Account Management teams maintain close contact with partners to further support their lending programs, including:
Regular pulse checks
To monitor the success and growth of the program, a customer success manager (CSM) schedules periodic meetings to discuss operations, compliance, performance, and reporting.
Regular reporting
The CSM will distribute reporting packages pertaining to operations, finance, compliance, and marketing.
Operational support
The CSM will be the primary contact at Upstart to handle any enhancements, feature requests, open issues or bugs, and to resolve any compliance or audit requests.
Key performance indicators (KPIs) and business review
In addition to the monthly KPIs discussions, the account manager works with each lender to determine appropriate extended executive stakeholder business reviews on the overall program performance and to align on go forward strategy.