How can lenders ensure they’re making the most accurate and fair lending decisions? The answer lies in consistent model validations. What are model validations? Model validations are vital for effective lending and risk-based pricing programs. In addition to helping you determine which credit scoring model works best on your portfolio, the performance (odds) charts from validation results are often used to set score cutoffs and risk-based pricing tiers. Validations also provide the information you need to implement a new score into your decisioning process. Factors affecting model validations Understanding how well a score predicts behavior, such as payment delinquency or bankruptcy, enables you to make more confident lending decisions. Model performance and validation results can be impacted by several factors, including: Dynamic economic environment – Shifts in unemployment rates, interest rate hikes and other economic indicators can impact consumer behavior. Regulatory changes affecting consumers – For example, borrowers who benefited from a temporary student loan payment pause may face challenges as they resume payments. Scorecard degradation – A model that performed well several years ago may not perform as well under current conditions. When to perform model validations The Office of the Comptroller of the Currency’s Supervisory Guidance on Model Risk Management states model validations should be performed at least annually to help reduce risk. The validation process should be comprehensive and produce proper documentation. While some organizations perform their own validations, those with fewer resources and access to historical data may not be able to validate and meet the guidance recommendations. Regular validations support compliance and can also give you confidence that your lending strategies are built on solid, current data that drive better outcomes. Good model validation practices are critical if lenders are to continue to make data-driven decisions that promote fairness for consumers and financial soundness for the institution. Make better lending decisions If you’re a credit risk manager responsible for the models driving your lending policies, there are several things you can do to ensure that your organization continues to make fair and sound lending decisions: Assess your model inventory. Ensure you have comprehensive documentation showing when each model was developed and when it was last validated. Validate the scores you are using on your data, along with those you are considering, to compare how well each model performs and determine if you are using the most effective model for your needs. Produce validation documentation, including performance (odds) charts and key performance metrics, which can be shared with regulators. Utilize the performance charts produced from the validation to analyze bad rates/approval rates and adjust cutoff scores as needed. Explore alternative credit scoring models to potentially enhance your scoring process. As market conditions and regulations continue to evolve, model validations will remain an essential tool for staying competitive and making sound lending decisions. Ready to ensure your lending decisions are based on the latest data? Learn more about Experian’s flexible validation services and how we can support your ongoing success. Contact us today to schedule a consultation. Learn more
This is the second in a series of blog posts highlighting optimization, artificial intelligence, predictive analytics, and decisioning for lending operations in times of extreme uncertainty. The first post dealt with optimization under uncertainty. The word "unprecedented" gets thrown around pretty carelessly these days. When I hear that word, I think fondly of my high school history teacher. Mr. Fuller had a sign on his wall quoting the philosopher-poet George Santayana: "Those who cannot remember the past are condemned to repeat it." Some of us thought it meant we had to memorize as many facts as possible so we wouldn't have to go to summer school. The COVID-19 crisis--with not only health consequences but also accompanying economic and financial impacts--certainly breaks with all precedents. The bankers and other businesspeople I've been listening to are rightly worried that This Time is Different. While I'm sure there are history teachers who can name the last time a global disaster led to a widescale humanitarian crisis and an economic and financial downturn, I'm even more sure times have changed a lot since then. But there are plenty of recent precedents to guide business leaders and other policymakers through this crisis. Hurricanes Katrina and Sandy impacted large regions of the United States, with terrible human consequences followed by financial ones. Dozens of local disasters—floods, landslides, earthquakes—devastated smaller numbers of people in equally profound ways. The Great Recession, starting in 2008, put millions of Americans and others around the world out of work. Each of those disasters, like this one, broke with all precedents in various ways. Each of those events was in many ways a dress rehearsal, as bankers and other lenders learned to provide assistance to distressed businesses and consumers, while simultaneously planning for the inevitable changes to their balance sheets and income statements. Of course, the way we remember the past has changed. Just as most of us no longer memorize dates--we search for them on the web--businesspeople turn to their databases and use analytics to understand history. I've been following closely as the data engineers and data scientists here at Experian have worked on perhaps their most important problem ever. Using Experian's Ascend Analytical Sandbox--named last year as the Best Overall Analytics Platform, they combed through over eighteen years of anonymized historical data covering every credit report in the United States. They asked--using historical experience, wisdom, time-consuming analytics, a little artificial intelligence, and a lot of hard work--whether predicting credit performance during and after a crisis is possible. They even considered scenarios regarding what happens as creditors change the way they report consumer delinquencies to the credit bureaus. After weeks of sleepless nights, they wrote down their conclusions. I've read their analysis carefully and I’m pleased to report that it says…Drumroll, please…Yes, but. Yes, it's possible to predict consumer behavior after a disaster. But not in precisely the same way those predictions are made during a period of economic growth. For a credit risk manager to review a lending portfolio and to predict its credit losses after a crisis requires looking at more data--and looking at it a little differently--than during other periods. Yes, after each disaster, credit scores like FICO® and VantageScore® credit scores continued to rank consumers from most likely to least likely to repay debts. But the interpretation of the score changes. Technically speaking, there is a substantial shift in the odds ratio that is particularly pronounced when a score is applied to subprime consumers. To predict borrower behavior more accurately, our scientists found that it helps to look at ten additional categories of data attributes and a few additional types of mathematical models. Yes, there are attributes on the credit report that help lenders identify consumer distress, willingness, and ability to pay. But, the data engineers identified that during times like these it is especially helpful to look beyond a single point in time; trends in a consumer's payment history help understand whether that customer is changing their typical behavior. Yes, the data reported to the credit bureaus is predictive, especially over time. But when expanded FCRA data is available beyond what is traditionally reported to a bureau, that data further improves predictions. All told, the data engineers found over 140 data attributes that can help lenders and others better manage their portfolio risk, understand consumer behavior, appreciate how the market is changing, and choose their next best action. The list of attributes might be indispensable to a credit data specialist whose institution needs to weather the coming storm. Because Experian knows how important it is to learn from historical precedents, we're sharing the list at no charge with qualified risk managers. To get the latest Experian data and insights or to request the Crisis Response Attributes recommendation, visit our Look Ahead 2020 page. Learn more
Understanding the behaviors of best-in-class credit risk managers For financial institutions to achieve superior performance, having the appropriate set of credit risk managers is a prerequisite. The ability to gain insight from data and customer behavior and to use that insight for strategic advantage is a critical ingredient for success. At the same time, the risk-management community is under increasing pressure to understand and explain underlying trends in credit portfolios — and to monitor, interpret and explain these trends with ever-greater accuracy. A common problem financial institutions face when confronting staff resource needs is the difficulty in recruiting and retaining experienced risk-management professionals. The risk-management community is notoriously small, and hiring expertise from within this community is extremely difficult. Skilled risk managers truly are a finite resource, but their skill set is in huge demand. Hiring the right talent is crucial to job satisfaction, leading to higher engagement levels and reduced attrition costs. On top of that, employee engagement is vital to an organization’s success. It drives employee productivity and fosters a culture of innovation, which leads to higher profitability for the entire organization. Building, attracting and retaining risk-management resources requires a commitment to engaging in staff personal development. A great way to support employee engagement is to invest in their personal and professional development, including opportunities for training and team building. If an organization can show that it is committed to developing its people and providing opportunities for career growth, employee engagement levels will rise, with all the benefits this entails. Typically, financial institutions bridge the resource skill gap by either hiring skilled statistical and analytical experts or developing in-house resources. Both of these approaches, however, require significant on-the-job training to teach employees how to link raw statistical techniques and procedures to influencing the profit and loss statement of the business line which they support. The challenge is often broadening the understanding of these skill set “silos” and their contribution to the overall portfolio. By opening that view, the organization generates additional value from these resources as lines of communication are improved and insights and opportunities found within the data are shared more effectively across the organizational team. Experian’s Global Consulting Practice provides a solution to this problem. Our two-day Risk and Portfolio Management Essentials training workshop offers the opportunity to understand the behaviors of best-in-class risk managers. What are the tools and enablers required for the role? How do they prepare for the process of managing credit risk? What areas must risk managers consider managers across the Customer Life Cycle? What differentiates the good from the great? To complement the training modules, Experian® offers an interactive, team-based approach that engages course participants in the build options of a defined portfolio. Participants leverage the best-in-class techniques presented in the sessions in a series of competitive, team-based exercises. This set of cross-organizational exercises drives home the best-in-class techniques and further builds understanding that resonates across the organization long after the course is concluded. For our current offerings, locations and to register click here.