Publications

FHFA Credit Score Request for Comments Input

In these comments we support the FHFA’s effort to update the credit score used/required by the GSEs and explore how more than one score could be considered or permitted. We wish the FHFA would go further and create a more flexible process that would allow the credit score(s) used to be updated more regularly and also permit more credit score flexibility to enable scores that use alternative data to be utilized.

Crypto-currencies: Misnamed, Misunderstood, and a Mistake for Casual Investors

Let me begin by declaring that Bitcoin has jumped the shark. Hopefully, the news of exchanges being shut down and wild price swings will provide sufficient red flags to potential investors so that they may avoid being drawn into¬†this self-evident¬†Ponzi scheme. Alas, this likely does not mean the end for crypto-currencies…for better or for worse.

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The Impact of Credit Reporting and Credit Scoring on the MFI Sector

This research analyzes a series of questions pertaining to the impacts on microfinance institutions (MFIs) when using credit bureau data (conventionally referred to as credit files) for purposes of underwriting credit; for the same purposes, it also analyzes credit scoring models and credit decisioning platforms that use credit bureau data.

Data Protection and Credit Information Sharing

This white paper discusses different data protection regimes and argues that whether a system is considered siloed or omnibus what really matters (in a practical sense) are the details and whether there is sufficient regulatory flexibility to account for “on the ground” realities. Credit information sharing is a focus of the white paper.

Changing the Lending Landscape: Credit Deserts, the Credit Invisible, and Data Gaps in Silicon Valley

This report presents findings from the pilot effort of the Credit Deserts Project, which aims to map the incidence of Credit Invisibility, in which consumers have credit reports with no or insufficient data with which to generate a traditional credit score. Previous research suggests that Credit Invisibles disproportionately live in lower income areas of communities and help form what we call Credit Deserts.

Personalized Credit Education: Consumer and Small Business Owner Attitudes, Impacts and Impediments

This study is the final report on research that examines resulting credit score changes and consumer attitudes following the use of personalized credit education sessions by study participants. The credit education service examined is offered by a national credit bureau. Such services (offered by for-profit non-lender/non-creditor entities) are covered and inhibited by CROA.

CRA Credit Education Services: An Examination of Consumer Impacts

This study was designed to gauge the impact of a personalized credit education service from a national credit bureau on consumer understanding of credit reports and scores as measured by changes in credit scores and results from a participant survey.