"GPS tracking would permit an agent of the creditor to determine whether or not the consumer is traveling daily to the address identified as the location of the consumer's current employer," he said.

The data would then be used to assign a risk score to the consumer's loan contract which a secondary purchaser would use in making purchase decisions.

"If employment changed after credit was granted---for example, from an office-based job to home-based work -- the rating could decrease even though the ability to pay would not be affected," he said.

Despite the potential privacy implications, there is no Maine privacy or credit laws that prohibit this sort of GPS tracking, he said. "It seems to me that once this data is gathered and complied and stored, that it is available for uses other than the uses it was intended for," Lund said.

A big challenge will be to determine for sure if the data will be used only for the indirect purpose of assigning a risk value to a loan, or whether it will be used for other more direct purposes, as well.