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.

Learn more

Related Posts

From Hybrids to Refinancing: Consumers are Finding New Roads to Vehicle Affordability

For today’s automotive consumers, considering a vehicle purchase isn’t just about the price they see on the window, it’s about finding the right combination of their vehicle preference and monthly payment. In fact, data from Experian Automotive’s State of the Automotive Finance Market Report: Q2 2026 highlighted how affordability continues to shape the automotive finance market. For instance, hybrids offered the lowest average new vehicle loan payment across all fuel types, coming in at $646 in Q2 2026, compared to electric vehicles (EVs) at $692, and gasoline-powered vehicles at $721. This led to considerable growth in new vehicle market share for hybrids this quarter, accounting for 16.80%, from 12.99% last year. While the automotive market continues to offer consumers an expanding mix of fuel types, the combination of growing hybrid share and comparatively lower monthly payments is something worth watching. Affordability isn’t just about what consumers drive, it’s how they finance it While hybrid vehicles are continuing to pave their way in the vehicle market, consumers who already have an auto loan are finding greater savings through refinancing. In the second quarter of 2026, automotive refinancing reached approximately 140,000 loans. More notably, the financial benefit associated with refinancing has grown. Consumers who refinanced this quarter reduced their average interest rate by more than 2.4%, with the average rate moving from 10.40% on the original loan to 7.97% on the refinanced loan. Those rate reductions translated into meaningful monthly savings, especially when refinancing through particular lenders. In Q2 2026, refinancing saved consumers an average of $83 per month, compared to an average monthly savings of $64 this time last year. However, credit unions delivered the largest average payment difference among lender types at $102 this quarter, followed by banks ($65), and finance companies ($38). It’s important for automotive professionals to acknowledge that affordability is not a single moment in the vehicle journey. It can influence the vehicle a consumer chooses, the financing they opt for during that transaction, and the decisions they make years after driving off the lot. Understanding and leveraging those different moments can help professionals identify opportunities to better serve consumers throughout the vehicle ownership lifecycle. To learn more about automotive finance trends, view the full State of the Automotive Finance Market Report: Q2 2026 presentation on demand.

August 27, 2026 by Melinda Zabritski
AI Agent Identity Verification: How to Verify AI Agents in Digital Transactions

AI agents are changing the way consumers interact with businesses online. Learn how you can establish greater confidence in AI transactions.

August 26, 2026 by Laura Burrows
Ask the Expert: Turning Insight into Advantage with Michelle Goeppner and David Elmore

What if some of your best potential borrowers are the ones your traditional credit strategy can't fully see? A credit score can tell lenders a lot about a consumer, but it doesn't always capture the full picture of how someone is managing their financial life. For consumers with nontraditional income patterns or limited credit histories, that incomplete view can mean missed opportunities. In this Ask the Expert session, David Elmore of Experian talks with Michelle Goeppner, Chief Lending Officer at Vantage West Credit Union, about how alternative data can provide additional context around consumer risk, uncover opportunities traditional data alone might miss and help lenders expand their reach without disrupting strategies that already work. Who could lenders be missing? That question is especially important when a consumer’s financial life doesn’t fit neatly into a traditional credit profile. Take gig workers. Someone driving for Uber or delivering for DoorDash likely has a different income pattern than a salaried employee — irregular, seasonal, spread across platforms. That doesn't mean they aren't reliably managing bills, rent and other obligations. It just means a traditional file may not show it. Goeppner has a name for the risk of overlooking that context: FOMM — Fear of Missing Members. You've heard of FOMO — Fear of Missing Out. I think about it as FOMM — Fear of Missing Members. Who are we leaving behind if we're not using it?Michelle Goeppner, Chief Lending Officer For credit unions especially, that's not just a data question — it's a mission question. A partial view of a member's finances can mean missing a member the institution exists to serve. The credit score alone doesn't tell you where someone's headed Traditional credit data is still  foundational to lending decisions. But alternative data — income, cash flow, payment behavior — adds a layer that a credit score alone can't provide. Goeppner illustrates the distinction with two consumers who have exactly the same credit score: I don't know if you're a 640 score on your way to 720 — or are you a 640 headed southwards to 580? It doesn't show me how you're managing your day-to-day financial lifeMichelle Goeppner, Chief Lending Officer Two borrowers can share the same score and be moving in opposite directions. Alternative data helps lenders tell the difference — and put that score in context rather than treating it as the whole story. Start small and layer it in Adopting alternative data doesn't mean overhauling an existing strategy. As Goeppner puts it, it's additive, not a replacement: It's not a rip and replace. You don't have to let go of your existing playbook. It's additive — you layer it in.Michelle Goeppner, Chief Lending Officer Her advice for getting started: Define the problem first. Are you trying to increase approvals, reach more underserved borrowers, or improve decisioning for a specific product? Test before you scale. Revisit loans you've already booked and ask whether alternative data would have changed the outcome — or pilot it on a single product before rolling it out further. Build in governance from day one. Document what changed, where the new data was used, and what results followed. As Goeppner puts it: “Crawl, walk, run. Slow and grow.” More loans without changing the risk profile For Vantage West, the value of that approach has shown up in its lending results. It has been an absolute game changer for us at Vantage West. We have been able to make more loans to our target members, our target segments, without changes to our risk profile.Michelle Goeppner, Chief Lending Officer That distinction matters. The goal isn't approving more loans for its own sake — it's having enough information to recognize good borrowers that traditional data alone would have missed. The result is a fuller picture of the people behind the credit file, and more confidence in deciding who a lender can serve. Explore alternative data with us Alternative data can help lenders add context to traditional credit information for a more complete view of consumers. Experian works with institutions of all sizes to incorporate additional consumer signals into existing lending strategies — strengthening decisioning, managing risk and identifying new opportunities for growth. Learn more Contact us About our experts Michelle Goeppner Chief Lending Officer, Vantage West Credit Union Michelle Goeppner is a dynamic financial services executive with over two decades of experience driving strategic growth, product innovation, and operational excellence across leading credit unions and financial institutions. Currently serving as the Chief Lending Officer at Vantage West Credit Union, Michelle leads the strategic vision for multi-billion-dollar consumer loan and deposit portfolios, as a member of the Executive Coalition. Her expertise spans consumer lending, product management, integrated marketing, and talent development, with a proven track record of leveraging fintech partnerships, automation, and data-driven strategies to optimize portfolio performance and member engagement. Throughout her career, Michelle has held pivotal leadership roles in organizations such as Alliant Credit Union and Discover Financial Services. She is recognized for her collaborative approach, detail-oriented execution, and commitment to developing future female leaders. Michelle’s contributions include founding Alliant’s Women’s Resource Group, serving on advisory councils and boards, and earning multiple industry awards for excellence and innovation. She holds an Executive Certification in Product Management from UC Berkeley, a Master of Science in Integrated Marketing Communications from Roosevelt University, and a Bachelor of Science in Marketing from Northern Illinois University. David Elmore Vice President of Fintech Sales, Experian David Elmore leads a team of fintech sales professionals at Experian focused on helping fintech organizations drive responsible, scalable growth through data-driven analytics and decisioning. With more than 20 years in financial services — a decade of it focused on fintech — he brings deep expertise in applying traditional and alternative data across the customer lifecycle. David and his team partner with fintech leaders to navigate opportunities across acquisition, underwriting, portfolio management, and collections, balancing innovation, risk, and trust.

August 26, 2026 by Julie Lee

Subscribe to our Newsletter

Enter your name and email for the latest updates.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Subscribe to our Newsletter

Don't miss out on the latest industry trends and insights!
Subscribe