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This is the third and final post in an interview between Experian’s Tom Whitfield and Dr. Michael Turner, founder, president and CEO of the Policy and Economic Research Council (PERC)—a non-partisan, non-profit policy institute devoted to research, public education, and outreach on public and economic policy matters. In this post Dr. Turner discusses mandatory credit-information sharing for communications companies, and the value of engaging and educating state regulators. _____________________________ Does it make sense for the FTC to mandate carriers to report? Credit information sharing in the United States is a voluntary system under the Fair Credit Reporting Act (FCRA). Mandating information sharing would break precedent with this successful, decades-old regime, and could result in less rather than more information being shared, as it shifts from being a business matter to a compliance issue. Additionally, the voluntary nature of credit reporting allows data furnishers and credit bureaus to modify reporting in response to concerns. For example, in reaction to high utility bills as a result of severe weather, a utility provider may wish to report delinquencies only 60 days or more past due. Similarly, a credit bureau may not wish to load data it feels is of questionable quality. A voluntary system allows for these flexible modifications in reporting. Further, under existing federal law, those media and communications firms that decide they want to fully report payment data to one or more national credit bureaus are free to do so. In short, there is simply no need for the FTC to mandate that communications and media companies report payment data to credit bureaus, nor would there be any immediate benefit in so doing. How much of the decision is based on the influence of the State PUC or other legislative groups? Credit information sharing is federally regulated by the Fair Credit Reporting Act (FCRA). The FCRA preempts state regulators, and as such, a media or communications firm that wants to fully report may do so regardless of the preferences of the state PUC or PSC. PERC realizes the importance of maintaining good relations with oversight agencies. We recommend that companies communicate the fact of fully reporting payment data to a PUC or PSC and engage in proactive outreach to educate state regulators on the value of credit reporting customer payment data. There have been notable cases of success in this regard. Currently, just four states (CA, OH, NJ and TX) have partial prohibitions regarding the onward transfer of utility customer payment data to third parties, and none of these provisions envisioned credit reporting when drafted. Instead, most are add-ons to federal privacy legislation. Only one state (CA) has restrictions on the onward transfer of media and communications customer payment data, and again this has nothing to do with credit reporting. Agree, disagree or comment Whether you agree with Dr. Turner’s assertions or not, we’d love to hear from you. So please, take a moment to share your thoughts about full-file credit reporting in the communications industry. Click here to learn more about current and pending legislation that impacts communications providers.

By: John Straka The U.S. housing market remains relatively weak, but it’s probably not as weak as you think. To what extent are home prices really falling again? Differing Findings Most recent media coverage of the “double dip in home prices” has centered on declines in the popular Case-Schiller price index; however, the data entering into this index is reported with a lag (the just released April index reflects data for February-April) and with some limitations.  CoreLogic publishes a more up-to-date index value that earlier this month showed a small increase, and more importantly, CoreLogic also produces an index that excludes distressed sales.  This non-distressed index has shown larger recent price increases, and it shows increases over the last 12 months in 20 states. Others basing their evidence on realtors’ listing data have concluded that there was some double dip last year, but prices have actually been rising now for several months (See Altos).  These disparate findings belie overly simplistic media coverage, and they stress that “the housing market” is not one single market, of course, but a wide distribution of differing outcomes in very many local neighborhood home markets across the nation. (For a pointed view of this, see Charron.) Improved Data Sources Experian is now working with the leading source of the most granular and timely home market analytics and information, from nationwide local market data, and the best automated valuation model (AVM) provider based on these and other data, Collateral Analytics. (Their AVM leads in accuracy and geographic coverage in most large lender and third party AVM tests). While acknowledging their popularity, value, and progress, Collateral Analytics President Dr. Michael Sklarz questions the traditional dominance of repeat-sales home price indexes (from Case-Shiller etc.).  Repeat-sales data typically includes only around 20 to 30 percent of the total home sales taking place. Collateral Analytics instead studies the full market distribution of home sales and market data and uses their detailed data to construct hedonic price indexes that control for changing home characteristics.  This approach provides a similar “constant quality” claim as repeat-sales—without throwing away a high percentage of the market observations. Collateral Analytics indexes also cover over 16,000 zip codes, considerably more than others. Regular vs. Distressed Property Sales Nationwide, some well-known problem states, areas and neighborhoods continue to fare worse than most others in today’s environment, and this skewed national distribution of markets is not well described by overall averages. Indeed, on closer inspection, the recent media-touted gloomy picture of home prices that are “falling again” or that “continue to fall” is a distorted view for many local home markets, where prices have been rising a little or even more, or at least remaining flat or stable.  Nationwide or MSA averages that include distressed-property sales (as Case-Shiller tends to do) can be misleading for most markets. The reason for this is that distressed-property sales, while given much prominence in recent years and lowering overall home-price averages, have affected but not dominated most local home markets. The reporting of continued heavy price discounts (twenty percent or significantly more) for distressed sales in most areas is a positive sign of market normality.  It typically takes a significantly large buildup of distressed property sales in a local area or neighborhood home market to pull down regular property sale prices to their level.  For normal or regular home valuation, distressed sales are typically discounted due to their “fire sale” nature, “as is” sales, and property neglect or damage. This means that the non-distressed or regular home price trends are most relevant for most homes in most neighborhoods. Several examples are shown below. As suggested in these price-per-living-area charts, regular (non-distressed) home-sale prices have fared considerably better in the housing downturn than the more widely reported overall indexes that combine regular and distressed sales(1). Regular-Sale and Combined Home Prices in $ Per Square Foot of Living Area and Distress Sales as a Pct of Total Sales In Los Angeles, combined sale prices fell 46 percent peak-to-trough and are now 16 percent above the trough, while regular sale prices fell by considerably less, 33 percent, and are now 3 percent above the trough.   Distressed sales as a percent of total sales peaked at 52 percent in 2009:Q1, but then fell to a little under 30 percent by 2010:Q2, where it has largely remained (this improvement occurred before the general “robo-signer” process concerns slowed down industry foreclosures).  L.A. home prices per square foot have remained largely stable for the past two years, with some increase in distressed-sale prices in 2009. Market prices in this area most recently have tended to remain essentially flat—weak, but not declining anew, with some upward pressure from investors and bargain hunters (previously helped by tax credits before they expired). Double-Dip: No. In Washington DC, single-family home prices per square foot have been in a saw- tooth seasonal pattern, with two drops of 15-20% followed by sizable rebounds in spring sales prices. The current combined regular & REO average price is 17 percent below its peak but 13 percent above its trough, while the regular-sale average price is just 12 percent below the peak and 10 percent above its trough. Distressed sales have been comparatively low, but rising slowly to a peak of a little over 20 percent in 2010, with some slight improvement recently to the high teens. Single-family prices in DC have remained comparatively strong; however, more of the homes in DC are actually condos, and condo prices have not been quite as strong, with the market data showing mixed signals but with the average price per square foot remaining essentially flat.  Double-Dip: No. In the Miami area, the combined average home price per square foot fell by 48 percent peak to trough and is now just 1 percent above the 2009:Q2 trough. The regular-sale average price already experienced an earlier double-dip, falling by 32 percent to 2009:Q2, then stabilizing for a couple of quarters before falling another 9 percent relative to the peak; since 2010:Q3 this average has been choppy but basically flat, now 3 percent above that second trough. Prices in Miami have been among the weakest in large metro areas, but average prices have been largely flat for the past year, without any sharp new double dip. Distressed sales as a percent of the total peaked at 53 percent in 2009:Q1, but then fell to a little under 30 percent by 2010:Q2; since then there has been some return to a higher distress share, in the mid to upper 30s (but all of these figures are about 10 percentage points lower for condos).   New Double-Dip: No. The Dallas area has seen some of the strongest prices in the nation. The combined price per square foot had an earlier peak and fell by 31 percent peak to trough, but it is now 33 percent above the trough. The regular-sale average price fell briefly by 22 percent peak to trough, but it has since risen by 32 percent from the 2009:Q1 trough to where it is now 3 percent above the peak. The increases have occurred in a saw-tooth seasonal pattern with spring prices the highest, but prices here have been largely rising considerably. Distress sales as a percent of the total peaked at 22 percent in 2009:Q1 but have largely fallen since and now stand at just 11 percent.   Double-Dip: No. Here You Can See 47 More Examples of Where Double-Dips Are and Are Not: »         Pacific West »         Southwest »         Mountain West »         Midwest »        Northeast »         Mid Atlantic »         Southeast  To summarize this information and gain a little more insight into the general area conditions for most homes and individuals in the U.S., we can add up the number of homes and the total population across the counties examined.  To be sure, this information is not a rigorous random sample across homes, but I have tried to include and show the details of both stronger and weaker metro-area counties throughout the U.S. As shown in the tables below, the information used here has covered 51 metro-area counties, including a total population of over 15 million homes and nearly 75 million individuals(2).  These results may be regarded as suggestive of findings from a more thoroughgoing study. Based on these reviews of the market price averages and other data, my assessment is that a little over half of the counties examined are not currently or recently experiencing a double-dip in home prices. Moreover, these counties, where home prices appear to be at least flat or relatively stronger, encompass almost two-thirds (65%) of the total affected U.S. population examined, and nearly three-fifths (58%) of the total properties covered by the data studied. Conclusion This is, on balance, good news. But there are remaining concerns. One is the continued high, or more recently rising, shares of distressed sales in many markets, and the “shadow inventory” of distressed sales now being held up in the current foreclosure pipeline. But it is also interesting to see that many of the reductions in the distressed-property shares of total sales in high-stress areas occurred before the foreclosure processing slowdowns. Another interesting observation is that most of the recent double-dips in prices have been relatively mild compared to the previous original peak-to-trough meltdown. While, to be sure, there are plenty of reasons to remain uncertain and cautious about U.S. home prices, home markets in general do vary considerably, with significant elements of improvement and strength as well as the continuing weaknesses. Despite many reports today about “the beleaguered housing market,” there really is no such thing … not unless the report is referring to a very specific local market.  There definitely are double dips in many areas, and reasons for continuing overall concern. But the best available evidence suggests that there are actually double-dip markets—most relatively moderately so, stable markets, and stronger markets, with markets affecting a majority of homes and individuals actually in the stable and stronger categories.  Note: In a next installment, we’ll look at some more granular micro market data, to explore in greater depth the extensive variety of home-price outcomes and market conditions in weak pockets and strong pockets across various local areas and home markets. This will highlight the importance of having very good information, at sub-county and even sub-zip code levels, on local-neighborhood home markets. Source of Home Price and Market Information: Collateral Analytics HomePriceTrends. I thank Michael Sklarz for providing the extensive information for this report and for comments, and I thank Stacy Schulman for assistance in this posting. __________________ (1) Based on analysis by Collateral Analytics, price/living sq ft is a useful, simple “hedonic” measure which typically controls for around 70 percent or more of the changing characteristics in a housing stock and home sale mix. Patterns in home prices without dividing by the square footage are generally similar, but not always. (2) The property inventory counts are from Collateral Analytics, while the population estimates are from the 2010 U.S. Census.

This is the second in a three-part interview between Experian’s Tom Whitfield and Dr. Michael Turner, founder, president and CEO of the Policy and Economic Research Council (PERC)—a non-partisan, non-profit policy institute devoted to research, public education, and outreach on public and economic policy matters. Dr. Turner is a prominent expert on credit access, credit reporting and scoring, information policy, and economic development. Mr. Whitfield is the Director of Marketing for Experian’s Telecommunications, Energy and Cable practice. In this post Dr. Turner explains how full-file credit reporting actually benefits consumers and why many communications providers haven’t yet embraced it. _____________________________ Why is full-file credit reporting good for communications customers? Approximately 54 million Americans either have no credit report, or have very little information in their credit reports to generate a credit score. Most of these “thin-file/no-file” persons are financially excluded and many of them are media and communications customers. By having their payment data fully reported to a credit bureau and included in their credit reports, many will be able to access affordable sources of mainstream credit for the first time; others will be helped by repairing their damaged credit. In this way, consumers will save by not relying on high-cost lenders to have their credit needs met. Why don’t providers embrace reporting like other major industries/lenders? A major reason is inertia—providers haven’t done it before and are not sure how they would benefit from change. Just recently, PERC released a major study highlighting the business case for fully reporting customer payment data to one or more nationwide credit bureaus. This includes customer survey results, peer survey results and case studies. The results all point to tremendous upside from fully reporting payment data, with only manageable downsides—including external communications and regulators.   Misperceptions and misunderstandings Another significant reason is regulator misperceptions and misunderstandings. State public service and public utility commissions (PSCs and PUCs) aren’t experts in credit reporting or the regulatory framework around credit-information sharing. Many mistakenly believe the data is unregulated and can be used for marketing. Not wanting to contribute to an increase in commercial mail and telemarketing calls, some regulators have a knee-jerk reaction when the topic of credit reporting is raised by an interested media, communications or utility company. PERC has been working to educate regulators and has had success in their outreach efforts. PERC can be a resource to firms interested in full-file reporting in direct communications with regulators. Part 3: Wednesday, June 29 Next, in the concluding post of this interview with PERC founder, president and CEO Dr. Michael Turner, the doctor discusses mandatory credit-information sharing for communications companies, and the value of engaging and educating state regulators. Agree, disagree or comment Whether you agree with Dr. Turner’s assertions or not, we’d love to hear from you. So please, take a moment to share your thoughts about full-file credit reporting in the communications industry.