The CFPB requested information to identify opportunities to prevent credit discrimination, promote fair, equitable, and nondiscriminatory access to credit, and address potential regulatory uncertainty under the Equal Credit Opportunity Act (ECOA) and Regulation B. In our response, we argue that non-financial lenders should be explicitly recognized as creditors. This would make the credit reporting system fairer, more forgiving, and more inclusive. We echo our call for a positive data reporting mandate made in earlier publications, particularly in the context of the COVID-19 healthcare and economic crisis.
Part I of the U.S. Chamber of Commerce’s Technology Engagement Centre white paper on Data for Good and the Need for a National Data Strategy features our report on Data for Good: COVID-19 Special Edition. It looks at the role of tech in responding to national healthcare and economic priorities during the pandemic. It is Part III in our U.S. Data Ecosystem series.
This paper evaluates Hong Kong’s credit information sharing system dynamics in Hong Kong, including data gaps, the real estate bubble, and the new entrant.
This report looks at the potential impacts of negative credit data suppression or deletion measures during the COVID-19 pandemic period. While the proposed measures are well-intended, they harm more consumers than they help. Instead, the report recommends adding positive telecommunications payments to make the system fairer and more forgiving, giving consumers a chance to rebuild their credit history, since negative telecommunications data is already reported. This solution also protects the integrity of the national credit reporting system, vital for post-pandemic economic recovery.
This paper summarizes PERC’s research into alternative data.
This discusses the need to ensure that the Small Business Paycheck Protection Program works by using lessons learned from Gulf Coast SME recovery post-Katrina.
PERC has conducted years of research on disaster recovery (following major hurricanes, such as Katrina, Rita, and Wilma in 2005), credit access for lower income Americans, and credit reporting in general. This white paper discusses those findings and draws lessons for the economic recovery phase of the current COVID-19 crisis.
This paper highlights new solutions in the alternative data and proven payment data space that are benefiting the credit invisible but advocates that the first-best solution for consumers would be pervasive full-file credit reporting of utility, telecom, and rental payment data directly to the main consumer databases operated by the nationwide CRAs.
Does being a victim of a data breach increase the risk of identity theft? In this first-of-its-kind joint-study with the U.S. Chamber of Commerce Technology Engagement Center, which we hope will contribute to informed and evidence-based federal preemptive privacy legislation, no evidence is found that data breaches lead to increased consumer harm.
This report addresses the Reserve Bank of India’s High-Level Task Force (HTF) Report published in June 2018 regarding the proposed Indian public credit registry (PCR).