New CRA Guidance Promotes Use of Alternative Data in Lending
The potential of alternative data in consumer lending decisions continues to be a hot topic in Washington, D.C., with the latest evidence seen in developments related to the Commun…
The potential of alternative data in consumer lending decisions continues to be a hot topic in Washington, D.C., with the latest evidence seen in developments related to the Community Reinvestment Act (CRA). When federal banking agencies recently revised their Q&As for CRA compliance, their focus on the use of alternative data caught my eye. This development is welcome news for those here at FICO and for our many existing and prospective customers.
Adopted in 1977, the CRA is intended to encourage depository institutions to help meet the credit needs of the communities in which they operate, including low- and moderate-income neighborhoods. The Act requires federal banking agencies (the OCC, FDIC and Federal Reserve – “Agencies”) to conduct periodic reviews of each depository institution’s efforts in this area. CRA regulations provide various methods of evaluating bank performance, corresponding to differences in institutions’ asset sizes, structures and operations. After a thorough assessment of the institution, bank examiners assign a CRA rating and issue a public performance evaluation.
CRA regulations allow a financial institution’s lending performance to be evaluated, in part, by the institution’s “use of innovative or flexible lending practices in a safe and sound manner to address the credit needs of low- or moderate-income individuals or geographies.” Notably, the latest version of the Q&A guidance includes a new clarification of this standard involving the use of alternative credit histories in mortgage and consumer lending programs. The Agencies discuss the use of alternative data, such as rent and utility payments, “to evaluate low- or moderate-income individuals who lack sufficient conventional credit histories and who would be denied credit under the institution’s traditional underwriting standards.” The Agencies consider this use of alternative credit histories as an “innovative or flexible lending practice” that enhances the “success and effectiveness” of the institution’s lending program.
This revised CRA guidance gives financial institutions an additional reason to adopt scoring innovations that leverage alternative data responsibly to expand credit access for communities with low- or moderate-income consumers.
Responsibly expanding credit access has always been a central focus at FICO. This April, FICO and our partners, LexisNexis® and Equifax®, announced the availability of an alternative data score, FICO® Score XD. This score leverages data found outside the traditional credit file to identify creditworthy individuals among the 50+ million unscorable consumers in the US. FICO® Score XD considers alternative data such as cable, landline, mobile and utility payments, along with select public record information.
FICO® Score XD is being piloted by many of the largest lenders for use in bankcard and other unsecured lending programs, and we have plans to expand it to additional loan types. FICO research shows that the score can serve as an on-ramp to the mainstream credit market for people who otherwise might have great difficulty in obtaining credit.
My colleague has written a series of blog posts detailing our research and the promise that this new score holds. We’re excited about the results we’ve seen so far – and to see like-minded enthusiasm from regulators and policy makers about the emerging potential of alternative data in lending.
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FICO® Score High Achievers: Is Age the Only Factor?
<p>FICO’s latest research on <a href="http://www.fico.com/en/blogs/risk-compliance/us-credit-quality-rising-the-beat-goes-on/" target="_blank">national FICO® Score distribution</a> shows that US credit quality continues to trend upwards, with an increasing number of consumers scoring in the highest scores ranges. Given that, we decided it was time to refresh our study on “<a href="http://www.fico.com/en/blogs/risk-compliance/infographic-what-does-a-high-credit-scorer-look-like/" target="_blank">FICO® Score high achievers</a>,” where we examine the credit behavioural profiles of consumers with higher credit scores.</p> <p>As expected, our latest study showed that older people generally have higher scores, as has been the case in our <a href="http://www.fico.com/en/blogs/risk-compliance/age-before-beauty-credit-worthiness-before-youth/" target="_blank">past research</a>. This is largely because they have trade lines that have been open longer, which leads to higher scores (assuming the trade lines are in good standing and all other things equal). The most credit savvy among you will remember that length of credit history accounts for roughly 15% of the overall <a href="http://www.myfico.com/CreditEducation/WhatsInYourScore.aspx" target="_blank">FICO® Score calculation</a>.</p> <p>But for younger consumers, it isn’t too helpful to say, “just wait until you are 50 years old, and that will fix things!” Thus, I decided to dive deeper with our analysis, including looking at the credit behavioural characteristics of younger consumers with high FICO® Scores.</p> <p>In this analysis, I looked at credit characteristics for the two highest score bands, 750-799 and 800-850, which have about 16% and 23% of the population, respectively. I further broke this down by looking at the characteristics of the youngest 15% in each group, which occurs at age 29 for the 750-799 group and 43 for the 800-850. We used FICO<strong>®</strong> Score 9 for our analysis, and examined typical variables of the categories that go into the make-up of the score.</p> <p><a href="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png"><img class="alignnone size-full wp-image-29367" src="http://www.fico.com/en/blogs/wp-content/uploads/2016/10/FICO-Score-High-Achiever-table.png" alt="fico-score-high-achiever-table" width="715" height="747" /></a></p> <p>Since there’s a lot to dissect in this chart, I’ll highlight a few findings that struck me: <ul> <li><strong>Credit history.</strong> Higher scores are undoubtedly associated with a longer time on file. What’s striking is the higher average time on file for the 800+ group, both overall and for revolving accounts (the most common trade line). Clearly, it helps to start credit use early in life – but that’s not the sole determining factor for high scoring. The younger cohorts in both the 800+ and 750-799 groups have time on file medians significantly less than their older counterparts.</li> <li><strong>New credit.</strong> High credit scorers do, in fact, pursue new credit. We see little variation in months since last trade line opening and last inquiry among all groups observed.</li> <li><strong>Pay on time.</strong> As you might expect, the further in the past the delinquency, the higher the score – and that’s <u>if</u> a delinquency ever happened. 95% of the 800+ people and 72% of the 750-799 group have never been delinquent, which is a striking contrast to the 57% for the total population. The percentages for the younger groups are even higher, especially so for the 750-799ers. Collection items are also scarce for these high scorers. While 23% of the national population have collection items greater than $99, the figures are only 0.5% for the 800+ group and 3% for the 750-799 group. It is clear that, in conjunction with starting a credit file early, paying on time is a key trait of the FICO® Score high achiever.</li> <li><strong>Balance and utilization.</strong> Finally, we look at how credit is being used, focusing on revolving product use. (Since most people only have one mortgage or one auto loan, variation in instalment product figures is minimal and driven by payment history, which is near perfect for high scorers, as we’ve seen.) FICO® Score high achievers tend to have more open revolving accounts. While the % active trades and utilization are generally lower, by no means do high scorers avoid the use of credit products. What drives the difference here is the amount of <u>available</u> revolving credit utilized. The 800+ group is roughly 1/4 of the national median, both in total and on their highest utilized card; they also have lower balances and more cards<em>. </em>The 750-799 group is more active and higher utilized, but still only at 2/3 of the national figures. The young 750-799 group compensate with lower revolving balances and, as a result, lower utilization, which is in line with what we see for the 800+ group.</li> <li><strong>Benchmarks.</strong> I’d like to point out that while this study provides good benchmarks of the typical credit traits of the FICO® Score high achiever, individual credit profiles will vary widely. And keep in mind that when we sort groups of consumers as a whole by different behaviours, some results may look superficially odd. For example, the 800+ band has a longer median average open account time (128 months) than average revolving months on file (140 months).</li> </ul> So, what do we conclude? A huge takeaway is that high scorers don’t have too much in the way of serious delinquencies and negative public record data.</p> <p>In most respects, the young 800+ people are like their peer group. They really only differ markedly in their shorter credit history and higher non-mortgage balance, both of which are a function of life stage. Our results show that you don’t have to be a credit product hermit; these high scorers have more credit cards. The takeaway is to start credit activity early and maintain well-managed and moderate usage.</p> <p>In many ways, the young 750-799 people are more interesting because their age profile is much younger. Their credit characteristics differ more from their peer group, particularly in terms of length of credit history. They compensate by having almost pristine credit records and lower balances.</p> <p>Ultimately, 39% of US consumers are FICO® Score high achievers, which they accomplish by following common-sense credit practices. It ain’t rocket science!</p>
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