Publications

Comments to CFPB on ECOA & Reg B

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.

Philippine Credit Information Study

This report analyzes the Philippine credit information sharing system and offers recommendations and possible amendments to the Credit Information Sharing Act (CISA) in order to improve and modernize the system.

Data for Good: COVID-19 Special Edition

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.

Credit Information Sharing in Hong Kong

This paper evaluates the credit information sharing system dynamics in Hong Kong, including data gaps, the real estate bubble, and the new entrant.

Addition is Better than Subtraction: The Risks from Data Suppression and the Benefits of Adding More Positive Data in Credit Reporting

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.

PERC Research Findings for COVID-19 Economic Recovery Efforts

´╗┐´╗┐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.

Potential Impacts of Credit Reporting Public Housing Rental Payment Data

This first of its kind joint-study by PERC and U.S. Department of Housing & Urban Development (HUD) investigates the impacts of reporting public housing authority (PHA) tenant rental payment data to credit bureaus. Credit invisibility affects 1 out of every 5 Americans, but in the lowest-income census tracks, almost 1 out of every 2 Americans (45%) are credit invisible. This report found that including full-file (both positive and negative) payment data eradicated credit invisibility and increased twice as many scores as it decreased. The system would become more inclusive and fairer, as mortgages are currently reported but rent is not. Seattle, Cook County, & Louisville PHAs participated, and HUD is now planning discussions around pilot programs for reporting PHA rental payment data.

FTC/CFPB Accuracy in Consumer Reporting Comments

In these comments, we call for legislation requiring mobile network payment data to be reported to credit bureaus. We also comment on credit data accuracy practices, and call for more research to be done following our 2011 report on data accuracy & the FTC’s 2013 report. Changes and new phenomena in data accuracy such as NCAP and the CFPB’s complaint portal should be assessed using these reports as a benchmark.