Validating Consumer Credit Scores in a Time of Extreme Uncertainty

by Jim Bander 6 min read May 20, 2020

This is the third 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 and the second with predicting consumer payment behavior.

In this post I will discuss how well credit scores will work for consumer lenders during and after the COVID-19 crisis and offer some recommendations for what lenders can be doing to measure and manage that model risk in a time like this.

Perhaps no analytics innovation has created opportunity for more individuals than the credit score has. The first commercially available credit score was developed by MDS (now part of Experian) in 1987. Soon afterwards FICO® popularized the use of scores that evaluate the risk that a consumer would default on a loan. Prior to that, lending decisions were made by loan officers largely on the basis on their personal familiarity with credit applicants. Using data and analytics to assess risk not only created economic opportunity for millions of borrowers, but it also greatly improved the financial soundness of lending institutions worldwide.

Predictive models such as credit scores have become the most critical tools for consumer lending businesses. They determine, among other things, who gets a loan and at what price and how an account such as a credit line is managed through its life cycle. Predictive models are in many cases critical for calculating loan and loss reserves, for stress testing, and for complying with accounting standards.

Nearly all lenders rely on generic scores such as the FICO® score and VantageScore® credit score. Most larger companies also have a portfolio of custom scorecards that better predict particular aspects of payment behavior for the customers of interest.

So how well are these scorecards likely to perform during and after the current pandemic? The models need to predict consumer credit risk even as:

  • Nearly all consumers change their behaviors in response to the health crisis,
  • Millions of people—in America and internationally—find their income suddenly reduced, and
  • Consumers receive large numbers of accommodations from creditors, who have in turn temporarily changed some of their credit reporting practices in response to guidelines in the federal CARES Act.

In an earlier post, I pointed out that there is good reason to believe that credit scores will tend to continue to rank order consumers from most likely to least likely to repay their debts even as we move from the longest economic expansion in history to a period of unforeseen and unexpected challenges. But the interpretation of the score (for example, the log odds or the bad rate) may need to be adjusted. Furthermore, that assumes that the model was working well on a lender’s population before this crisis started. If it has been a long time since a scorecard was validated, that assumption needs to be questioned. Because experts are considering several different scenarios regarding both the immediate and long-term economic impacts of COVID-19, it’s important to have a plan for ongoing monitoring as long as necessary.

Some lenders have strong Model Risk Management (MRM) teams complying with requirements from the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC). Those resources are now stretched thin. Other institutions, with fewer resources for MRM, are now discovering gaps in their model inventories as they implement operational changes. In either case, now’s the time to reassess how well scorecards are working. Good model validation practices are especially critical now if lenders are to continue to make the sound data-driven decisions that promote fairness for consumers and financial soundness for the institution.

If you’re a credit risk manager responsible for the generic or custom models driving your lending, servicing, or capital allocation policies, there are several things you can do–starting now–to be sure that your organization can continue to make fair and sound lending decisions throughout this volatile period:

  1. Assess your model inventory. Do you have good documentation showing when each of the models in your organization was built? When was it last validated? Assign a level of criticality to each model in use.
  2. Starting with your most critical models, perform a baseline validation to determine how the model was performing prior to the global health crisis. It may be prudent to conduct not only your routine validation (verifying that the model was continuing to perform at the beginning of the period) but also a baseline validation with a shortened performance window (such as 6-12 months). That baseline validation will be useful if the downturn becomes a protracted one—in which case your scorecard models should be validated more frequently than usual. A shorter outcome window will allow a timelier assessment of the relationship between the score and the bad rate—which will help you update your lending and servicing policies to prevent losses.
  3. Determine if any of your scorecards had deteriorated even before the global pandemic. Consider recalibrating or rebuilding those scorecards. (Use metrics such as the Population Stability Index, the K-S statistic and the Gini Coefficient to help with that decision.) Many lenders chose not to prioritize rebuilding their behavioral scorecards for account management or collections during the longest period of economic growth in memory. Those models may soon be among the most critical models in your organization as you work to maintain the trust of your accountholders while also maintaining your institution’s financial soundness.
  4. Once the CARES accommodation period has expired, it will be important to revalidate your models more frequently than in the past—for as long as it takes until consumer behavior normalizes and the economy finds its footing.

When you find it appropriate to rebuild a scorecard model, consider whether now is the time to implement ethical and explainable AI. Some of our clients are finding that Machine Learned models are more predictive than traditional scorecards. Early Experian research using data from the last recession indicates this will continue to be true for the foreseeable future. Furthermore, Experian has invested in Research and Development to help these clients deliver FCRA-compliant Adverse Action reasons to their consumers and to make the models explainable and transparent for model risk governance and compliance purposes.

The sudden economic volatility that has resulted from this global health crisis has been a shock to all organizations. It is important for lenders to take the pulse of their predictive models now and throughout the downturn. They are especially critical tools for making sound data-driven business decisions until the economy is less volatile.

Experian is committed to helping your organization during times of uncertainty. For more resources, visit our Look Ahead 2020 Hub.

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Ask the Expert: A closer look at financial inclusion with Corliss Hill and Dr. Vaneesha Dutra

Consumer visibility is changing Roughly 45 million Americans, or 1 in 5 consumers, are considered credit invisible or unscoreable.[1] They’re working, paying bills and participating in the economy, yet many are not fully visible during the lending process. That creates both a visibility challenge and a growth opportunity for lenders. In this Ask the Expert session, Corliss Hill, Senior Director, Inclusion and Belonging at Experian, joins Dr. Vaneesha Dutra, Endowed Professor of Finance at Morehouse College, to discuss how evolving consumer behaviors are reshaping conversations around financial inclusion and lending decisions. For lenders, visibility matters because confident decisions depend on reliable context and insight. Broader consumer signals can help institutions better understand repayment behaviors, financial stability and consumer capacity. “The benefit of banks using alternative data is that they capture a very significant and new consumer base. That's 20% of the population, 45 million Americans.”Dr. Vaneesha Dutra, Endowed Professor of Finance A more complete understanding of today’s consumers Today’s consumers often manage obligations across a wide range of payment types and financial channels, creating additional signals through cash flow activity, recurring payments and consumer-permissioned financial data. Rent, utilities, subscriptions and mobile phone payments can all provide meaningful insight into how consumers manage their financial lives. What’s changing isn’t the need for risk assessment. It’s the amount of consumer behavior lenders can now evaluate. For example, a consumer experiencing temporary financial disruption may fall behind on certain obligations while continuing to consistently pay rent, utilities and phone bills. Those recurring payment behaviors can provide important context into financial priorities and stability. “These are consumers that pay rent on time every month, pay utilities every month on time and meet many other financial obligations in a timely manner.”Dr. Vaneesha Dutra, Endowed Professor of Finance From visibility to more-informed decisioning Broader consumer insights may help lenders move from limited visibility to more informed decisioning. The conversation shifts when lenders move from asking: “Should we take a risk on this consumer?” to: “Do we have enough information to fully understand this consumer?” That broader context can help institutions: Strengthen risk assessment. Identify financially active consumers with strong repayment behaviors. Support more informed lending strategies. Alternative data isn’t about replacing established credit approaches. It’s about helping lenders build on trusted credit foundations with additional context and insight. Responsible lending starts with better context For lenders, the path forward is practical and actionable. As lenders evaluate broader consumer behaviors, three priorities become increasingly important: Modernize data strategies Incorporate broader consumer signals alongside existing credit data to create a more holistic view of repayment behavior and financial stability. Engage consumers earlier Earlier intervention may help lenders better support consumers before financial challenges become more severe. Create pathways to financial access Smaller lending opportunities can help consumers establish stronger financial profiles and demonstrate positive repayment behaviors over time. The institutions that lead will be the ones that can combine strong risk practices with a broader understanding of consumer behavior. Whitepaper: Bridging the credit divide: income, risk and inclusion in consumer finance Building on the themes discussed in this Ask the Expert session, Dr. Dutra explores how demographic shifts, evolving borrower behaviors and broader consumer visibility are reshaping lending strategies and what they mean for lenders seeking to balance growth, risk management and financial inclusion. Download whitepaper Explore alternative data with Experian Experian can help lenders combine broader consumer insights with trusted credit data to strengthen decisioning, improve risk assessment and support more-informed lending strategies. With solutions spanning identity, cash flow and advanced analytics, lenders can gain a more complete view of consumer behavior and expand access to credit with greater confidence. Learn more Watch episode 1 About our experts Corliss Hill Senior Director, Belonging Business Partner, Experian Corliss Hill is a collaborative leader well-versed in working with executive stakeholders, crossfunctional teams, external partners and community organizations to design and deliver initiatives and programs that create sustainable impact. With over 25 years of extensive experience in multicultural marketing, communications, PR and inclusion and belonging initiatives, she is dedicated to advancing equitable access to financial. Her mission is to drive impactful marketing initiatives that foster meaningful change and address systemic barriers to inclusion and the communities they serve.Hill has been a part of the Experian family since 2021, and resides in Atlanta with her daughter who is a rising 11-year-old entrepreneur. Vaneesha Dutra, Ph.D. Endowed Professor of Finance and Associate Dean, Morehouse College Vaneesha Dutra, Ph.D., serves as Associate Dean in the Division of Business and Economics. With more than 20 years of experience spanning higher education, banking and real estate, Dr. Dutra’s work focuses on the racial and gender wealth gap, financial literacy and financial decision-making. She is an active researcher and consultant whose work has earned numerous grants and fellowships, including serving as the inaugural Tracy A. Pruitt Visiting Research Faculty Fellow at the Wharton School of Business. Dr. Dutra has also been named a Research Faculty Fellow for both the Center for Black Entrepreneurship and the PNC Bank Center for Entrepreneurship. [1] Consumer Financial Protection Bureau, Expanding access to credit.

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