Tag: AFSA

Millions of consumers lack credit history and/or have difficulty obtaining credit from mainstream financial institutions. As a result, the use of expanded Fair Credit Reporting Act (FCRA) – or alternative – data has continued to gain popularity among lenders and financial intuitions to enrich decisions across the entire lending lifecycle to meet the financial needs of their consumers. Experian presented in a recent webinar hosted by AFSA, where Alpa Lally, Vice President of Product Management, and David Elmore, Automotive Solutions Consultant, had a chance to speak about the benefits of FCRA data, and ways lenders can leverage this data to ease access to credit for “invisible” and below prime consumers. Watch the full webinar, “FCRA Data: The Key to Unlocking Credit Universe” and learn more about: How expanded FCRA data is being used throughout the lending lifecycle The benefits of leveraging FCRA data including providing a more holistic view of a consumer’s credit profile and behavior beyond financial services, leading to smarter, more informed lending decisions The lift FCRA data can offer when augmented with traditional credit data This webinar is a part of AFSA’s partner webinar series. To learn more about FCRA data and explore related content, please visit our FCRA Alternative Credit Data Resources Page. Learn More About FCRA-Alternative Credit Data

As lenders and consumers emerge from the pandemic, predicting the attributes of the “new normal” will be difficult. Consumer demand, credit characteristics and economic conditions have all been affected by the pandemic – changing the way we think about doing business. Regulators and legislators have also developed new priorities and expectations for financial institutions. Clint Ivester, Experian’s Solutions Consultant and VP of Sales, joined Lee Gilley and Jonathan Kkolodziej, Partners for Bradley, to share their observations from the past year at AFSA’s 2021 Independents Conference. They also discussed recommendations financial institutions should consider to achieve the best possible posture with respect to compliance and business readiness. Here are a few Q&A highlights: Q: How are stimulus packages and increased government spending affecting economic conditions? A: [Ivester]: Our Experian forecast shows that the economy will grow 6% in 2021. That is well above the 2.5% average we have seen over the last four decades and highest rate since 1983. While the economy is oriented toward growth, how strong that growth is going to be will really depend on how well things go when the “training wheels” are taken off, how robust the recovery is for lower-income workers, and how consumer spending habits have been altered by the pandemic. *Data sources include Bureau of Economic Analysis and Experian’s “COVID-19 Economics Scenarios” April 2021 Report Q: How should businesses be assessing future consumer demand, conditions, and broader economic conditions over the next few quarters? A: [Ivester]: To answer this question, we should consider some factors including unemployment. What happens with lower income workers will have a big impact on where consumer spending goes post-stimulus. While the overall economy is set for solid growth there are still 8 million people out of work with the vast majority being lower income workers. Employment for lower income workers is still down more than 20%. These workers are set to lose the most by the phase out of the federal pandemic unemployment programs and are the highest risk to lose all unemployment benefits. However, if we see a strong jobs recovery – as is very possible – in bars, restaurants, hotels and other industries, these individuals will return to more normal spending habits and consumer spending should remain robust. *Data source includes Opportunity Insights Economic Tracker Watch the full session to hear more about the discussion. For more resources and content on this topic, please visit our Look Ahead Resources page or contact us for more information.  

As more financial institutions express interest and leverage alternative credit data sources to decision and assess consumers, lenders want to be assured of how they can best utilize this data source and maintain compliance. Experian recently interviewed Philip Bohi, Vice President for Compliance Education for the American Financial Services Association (AFSA), to learn more about his perspective on this topic, as well as to gain insights on what lenders should consider as they dive into the world of alternative credit data. Alternative data continues to be a hot topic in the financial services space. How have you seen it evolve over the past few years? It’s hard to pinpoint where it began, but it has been interesting to observe how technology firms and people have changed our perceptions of the value and use of data in recent years. Earlier, a company’s data was just the information needed to conduct business. It seems like people are waking up to the realization that their business data can be useful internally, as well as to others.  And we have come to understand how previously disregarded data can be profoundly valuable. These insights provide a lot of new opportunities, but also new questions.  I would also say that the scope of alternative credit data use has changed.  A few years ago, alternative credit data was a tool to largely address the thin- and no-file consumer. More recently, we’ve seen it can provide a lift across the credit spectrum. We recently conducted a survey with lenders and 23% of respondents cited “complying with laws and regulations” as the top barrier to utilizing alternative data. Why do you think this is the case? What are the top concerns you hear from lenders as it relates to compliance on this topic? The consumer finance industry is very focused on compliance, because failure to maintain compliance can kill a business, either directly through fines and expenses, or through reputation damage. Concerns about alternative data come from a lack of familiarity. There is uncertainty about acquiring the data, using the data, safeguarding the data, selling the data, etc. Companies want to feel confident that they know where the limits are in creating, acquiring, using, storing and selling data. Alternative data is a broad term. When it comes to utilizing it for making a credit decision, what types of alternative data can actually be used?  Currently the scope is somewhat limited. I would describe the alternative data elements as being analogous to traditional credit data. Alternative data includes rent payments, utility payments, cell phone payments, bank deposits, and similar records. These provide important insights into whether a given consumer is keeping up with financial obligations. And most importantly, we are seeing that the particular types of obligations reflected in alternative data reflect the spending habits of people whose traditional credit files are thin or non-existent.  This is a good thing, as alternative data captures consumers who are paying their bills consistently earlier than traditional data does. Serving those customers is a great opportunity. If a lender wants to begin utilizing alternative credit data, what must they know from a compliance standpoint? I would begin with considering what the lender’s goal is and letting that guide how it will explore using alternative data. For some companies, accessing credit scores that include some degree of alternative data along with traditional data elements is enough. Just doing that provides a good business benefit without introducing a lot of additional risk as compared to using traditional credit score information. If the company wants to start leveraging its own customer data for its own purposes, or making it available to third parties, that becomes complex very quickly.  A company can find itself subject to all the regulatory burdens of a credit-reporting agency very quickly. In any case, the entire lifecycle of the data has to be considered, along with how the data will be protected when the data is “at rest,” “in use,” or “in transit.” Alternative data used for credit assessment should additionally be FCRA-compliant. How do you see alternative credit data evolving in the future? I cannot predict where it will go, but the unfettered potential is dizzying. Think about how DNA-based genealogy has taken off, telling folks they have family members they did not know and providing information to solve old crimes. I think we need to carefully balance personal privacy and prudent uses of customer data. There is also another issue with wide-ranging uses of new data. I contend it takes time to discern whether an element of data is accurately predictive.  Consider for a moment a person’s utility bills. If electricity usage in a household goes down when the bills in the neighborhood are going up, what does that tell us? Does it mean the family is under some financial strain and using the air conditioning less? Or does it tell us they had solar panels installed? Or they’ve been on vacation?  Figuring out what a particular piece of data means about someone’s circumstances can be difficult. About Philip Bohi Philip joined  AFSA in 2017 as Vice President, Compliance Education. He is responsible for providing strategic direction and leadership for the Association’s compliance activities, including AFSA University, and is the staff liaison to the Operations and Regulatory Compliance Committee and Technology Task Forces. He brings significant consumer finance legal and compliance experience to AFSA, having served as in-house counsel at Toyota Motor Credit Corporation and Fannie Mae. At those companies, Philip worked closely with compliance staff supporting technology projects, legislative tracking, and vendor management. His private practice included work on manufactured housing, residential mortgage compliance, and consumer finance matters at McGlinchey Stafford, PLLC and Lotstein Buckman, LLP. He is a member of the Virginia State Bar and the District of Columbia Bar. Learn more about the array of alternative credit data sources available to financial institutions.