Last Updated: January 2019 Traditional credit data has long been the end-all-be-all ruling the financial services space. Like the staple black suit or that little black dress in your closet, it’s been the quintessential go-to for decades. Sure, the financial industry has some seasonality, but traditional credit data has reigned supreme as the reliable pillar. It’s dependable. And for a long time, it’s all there was to the equation. But as with finance, fashion and all things – evolution has occurred. Specifically, how consumers are managing their money has evolved, which calls for deeper insights that are still defensible and disputable. Alternative credit data is the new black. Alternative credit data is increasingly integrated in credit talks for lenders across the country. Much like that LBD, it is becoming a lending staple – that closet (or portfolio) must-have – to leverage for better decisioning when determining credit worthiness. So, what is alternative credit data? In our data-driven industry, “alternative” data as a whole may best be summed up as FCRA-compliant credit data that is not typically included in traditional credit reports. For traditional data, think loan and inquiry data on bankcards, auto, mortgage and personal loans; typically trades with a term of 12 months or greater. Some examples of alternative credit data include alternative financial services data, rental data, full-file public records and account aggregation. These insights can ultimately improve credit access and decisioning for millions of consumers who may otherwise be overlooked. Alternative or not, every bit of information counts – and consumers are willing to share this data. An Experian survey revealed that 70% of consumers are willing to provide additional financial information to a lender if it increases their chance for approval or improves their interest rate for a mortgage or car loan. In addition, the data also revealed that 71% of lenders believe consumers will increasingly allow access to their data for lending decisions if they are empowered to turn it on and off. FCRA-compliant, user permissioned data allows lenders to easily verify assets and income electronically without consumer permission, thereby giving lenders more confidence in their decision and allowing consumers to gain access to lower-cost financing. From a risk management perspective, alternative credit data can also help identify riskier consumers, by identifying information like the number of payday loans acquired within a year, number of first-payment defaults, number of inquiries within the past 30-90 days and overall stability of an applicant. Alternative credit data can give supplemental insight into a consumer’s stability, ability and willingness to repay that is not available on a traditional credit report that can help lenders avoid risk or price accordingly. From closet finds that refresh your look to that LBD, alternative credit data gives lenders more transparency into their consumers, and gives consumers seeking credit a greater foundation to help their case for creditworthiness. It really is this season’s – and every season’s – must-have. Get Started Today
25% of U.S. consumers are considered “thin file” because they have fewer than 5 items in their traditional credit histories. By adding information from alternative data sources, such as on-time rental data, 23% may move from thin file to thick file status. Consider these 3 credit data types as you work with emerging consumers. Alternative financial services, such as payday and short-term installment loans. Rental data provides insight on some 20 million consumers. Account aggregation offers real-time data collection of financial information from a single location. Alternative credit data can help you expand your approval population while maintaining loss expectations by identifying opportunities to underwrite emerging consumers, like millennials. Other alternative data>
As more financial institutions express interest and leverage alternative credit data sources to decision and assess consumers, lenders want to be assured of how they can best utilize this data source and maintain compliance. Experian recently interviewed Philip Bohi, Vice President for Compliance Education for the American Financial Services Association (AFSA), to learn more about his perspective on this topic, as well as to gain insights on what lenders should consider as they dive into the world of alternative credit data. Alternative data continues to be a hot topic in the financial services space. How have you seen it evolve over the past few years? It’s hard to pinpoint where it began, but it has been interesting to observe how technology firms and people have changed our perceptions of the value and use of data in recent years. Earlier, a company’s data was just the information needed to conduct business. It seems like people are waking up to the realization that their business data can be useful internally, as well as to others. And we have come to understand how previously disregarded data can be profoundly valuable. These insights provide a lot of new opportunities, but also new questions. I would also say that the scope of alternative credit data use has changed. A few years ago, alternative credit data was a tool to largely address the thin- and no-file consumer. More recently, we’ve seen it can provide a lift across the credit spectrum. We recently conducted a survey with lenders and 23% of respondents cited “complying with laws and regulations” as the top barrier to utilizing alternative data. Why do you think this is the case? What are the top concerns you hear from lenders as it relates to compliance on this topic? The consumer finance industry is very focused on compliance, because failure to maintain compliance can kill a business, either directly through fines and expenses, or through reputation damage. Concerns about alternative data come from a lack of familiarity. There is uncertainty about acquiring the data, using the data, safeguarding the data, selling the data, etc. Companies want to feel confident that they know where the limits are in creating, acquiring, using, storing and selling data. Alternative data is a broad term. When it comes to utilizing it for making a credit decision, what types of alternative data can actually be used? Currently the scope is somewhat limited. I would describe the alternative data elements as being analogous to traditional credit data. Alternative data includes rent payments, utility payments, cell phone payments, bank deposits, and similar records. These provide important insights into whether a given consumer is keeping up with financial obligations. And most importantly, we are seeing that the particular types of obligations reflected in alternative data reflect the spending habits of people whose traditional credit files are thin or non-existent. This is a good thing, as alternative data captures consumers who are paying their bills consistently earlier than traditional data does. Serving those customers is a great opportunity. If a lender wants to begin utilizing alternative credit data, what must they know from a compliance standpoint? I would begin with considering what the lender’s goal is and letting that guide how it will explore using alternative data. For some companies, accessing credit scores that include some degree of alternative data along with traditional data elements is enough. Just doing that provides a good business benefit without introducing a lot of additional risk as compared to using traditional credit score information. If the company wants to start leveraging its own customer data for its own purposes, or making it available to third parties, that becomes complex very quickly. A company can find itself subject to all the regulatory burdens of a credit-reporting agency very quickly. In any case, the entire lifecycle of the data has to be considered, along with how the data will be protected when the data is “at rest,” “in use,” or “in transit.” Alternative data used for credit assessment should additionally be FCRA-compliant. How do you see alternative credit data evolving in the future? I cannot predict where it will go, but the unfettered potential is dizzying. Think about how DNA-based genealogy has taken off, telling folks they have family members they did not know and providing information to solve old crimes. I think we need to carefully balance personal privacy and prudent uses of customer data. There is also another issue with wide-ranging uses of new data. I contend it takes time to discern whether an element of data is accurately predictive. Consider for a moment a person’s utility bills. If electricity usage in a household goes down when the bills in the neighborhood are going up, what does that tell us? Does it mean the family is under some financial strain and using the air conditioning less? Or does it tell us they had solar panels installed? Or they’ve been on vacation? Figuring out what a particular piece of data means about someone’s circumstances can be difficult. About Philip Bohi Philip joined AFSA in 2017 as Vice President, Compliance Education. He is responsible for providing strategic direction and leadership for the Association’s compliance activities, including AFSA University, and is the staff liaison to the Operations and Regulatory Compliance Committee and Technology Task Forces. He brings significant consumer finance legal and compliance experience to AFSA, having served as in-house counsel at Toyota Motor Credit Corporation and Fannie Mae. At those companies, Philip worked closely with compliance staff supporting technology projects, legislative tracking, and vendor management. His private practice included work on manufactured housing, residential mortgage compliance, and consumer finance matters at McGlinchey Stafford, PLLC and Lotstein Buckman, LLP. He is a member of the Virginia State Bar and the District of Columbia Bar. Learn more about the array of alternative credit data sources available to financial institutions.
According to our recent research for the State of Alternative Credit Data, more lenders are using alternative credit data to determine if a consumer is a good or bad credit risk. In fact, when it comes to making decisions: More than 50% of lenders verify income, employment and assets as well as check public records before making a credit decision. 78% of lenders believe factoring in alternative data allows them to extend credit to consumers who otherwise would be declined. 70% of consumers are willing to provide additional financial information to a lender if it increases their chance for approval or improves their interest rate. The alternative financial services space continues to grow with products like payday loans, rent-to-own products, short-term loans and more. By including alternative financial data, all types of lenders can explore both universe expansion and risk mitigation. State of Alternative Credit Data
The second full day of Experian Vision 2018 kicked off with an inspirational message from keynote speakers Capt. Mark Kelly and Former Congresswomen Gabby Giffords, rolled into a series of diverse breakout sessions, and concluded with Super Bowl-winning quarterback Aaron Rodgers sharing tales of sports, leadership and winning. Need a recap of some of the headlines from the day? Here you go ... Retail Apocalypse? Not so fast alarmists. Yes, there are media headlines around mergers, closings and consumers adopting new ways to shop, but let me give you three reasons as to why the retail sky is not falling. There were more store openings last year than closings, and that trend is expected to continue this year with an estimated 5,500 openings by December. There continues to be a positive sales trajectory. E-commerce sales are increasing. Big department stores have seen pains, but if brands are focused on connection, relevance and convenience, there is hope. Consumers continue to spend. Subprime auto bubble? Nope. Malinda Zabritski, Sr. Director of Experian Automotive Sales, says the media likes to fixate on the subprime, but subprime financing has been on the decline, reaching record lows. Deep subprime is at .65%. Additionally, delinquency rates have also tapered. The real message? Consumers are relying on auto lenders for financing, largely due to consumer preferences to lease. The market is healthy, and while it has slowed slightly, the market is still at 7% year-over-year growth. Consumer-permissioned data is not just a value-add for thin-file consumers. Take for instance the inclusion of demand deposit accounts (DDAs). David Shellenberger, Sr. Director of Scoring and Predictive Analytics for FICO, says people who have had long relationships with their checking accounts tend to be more stable and generally sport higher credit scores. Consumers with thick, mature files can also benefit with DDA data. Consumer-permissioned data is not just about turning a “no” to a “yes.” It can also take a consumer from near-prime to prime, or from prime to super-prime. Would you want to make a credit decision with less information or more? This was the question Paul DeSaulniers, Experian Sr. Director of Product, posed to the audience as he kicked off the session on alternative data. With an estimated 100 million U.S. consumers falling below “thick-file” credit status, there is a definite need to learn more about these individuals. By leveraging alternative credit data – like short-term lending product use, rental data, public records and consumer-permissioned data – a more holistic view of these consumers is available. A few more facts: While alternative finance users tend to be more subprime, 20% are prime or better. A recent data pull revealed 20% of approved credit card users also had alternative finance data on them as well. About 2/3 of households headed by young adults are rentals. Imagine a world where the mortgage journey takes only seven to 10 days. With data and technology, we are closer than you think. Future products are underway that could master the underwriting phase in just one day, leaving the remaining days dedicated for signing disclosures, documents and wiring funds. Processes need to be firmed up, but a vision has been set. The average 30- to 45-day mortgage journey could soon be a distant memory. 97% of online banking applications that are started are abandoned. Why? Filling out lengthy forms, especially on a mobile device, is not fun. New technology, such as Experian’s Instant Form Fill, is allowing consumers to provide a name, zip and last four numbers of their social security number for an instant form fill of the rest of the application. Additionally, voice assistants are expected to increasingly facilitate research on purchases big and small. A recent study revealed nearly half of consumers perceive voice assistants to be useful. Businesses have more fraud losses than ever before. Not surprising. What is scary? An estimated 54% of businesses said they are not confident in their ability to detect fraud. Another session reported that approximately 20% of credit charge-offs are synthetic IDs, a growing pain point for all businesses. Consumers, on the other hand, say they “want visible signs of security” and “no friction.” Tough to balance, but those are today’s expectations. More Vision 2018 insights can be accessed on #ExperianVision twitter feed. Vision 2019 will be in San Antonio, Texas next May 5-8.
The traditional credit score has ruled the financial services space for decades, but it‘s clear the way in which consumers are managing their money and credit has evolved. Today’s consumers are utilizing different types of credit via various channels. Think fintech. Think short-term loans. Think cash-checking services and payday. So, how do lenders gain more visibility to a consumer’s credit worthiness in 2018? Alternative credit data has surfaced to provide a more holistic view of all consumers – those on the traditional file and those who are credit invisibles and emerging. In an all-new report, Experian dives into “The State of Alternative Credit Data,” providing in-depth coverage on how alternative credit data is defined, regulatory implications, consumer personas attached to the alternative financial services industry, and how this data complements traditional credit data files. “Alternative credit data can take the shape of alternative finance data, rental, utility and telecom payments, and various other data sources,” said Paul DeSaulniers, Experian’s senior director of Risk Scoring and Trended/Alternative Data and attributes. “What we’ve seen is that when this data becomes visible to a lender, suddenly a much more comprehensive consumer profile is formed. In some instances, this helps them offer consumers new credit opportunities, and in other cases it might illuminate risk.” In a national Experian survey, 53% of consumers said they believe some of these alternative sources like utility bill payment history, savings and checking account transactions, and mobile phone payments would have a positive effect on their credit score. Of the lenders surveyed, 80% said they rely on a credit report, plus additional information when making a lending decision. They cited assessing a consumer’s ability to pay, underwriting insights and being able to expand their lending universe as the top three benefits to using alternative credit data. The paper goes on to show how layering in alternative finance data could allow lenders to identify the consumers they would like to target, as well as suppress those that are higher risk. “Additional data fields prove to deliver a more complete view of today’s credit consumer,” said DeSaulniers. “For the credit invisible, the data can show lenders should take a chance on them. They may suddenly see a steady payment behavior that indicates they are worthy of expanded credit opportunities.” An “unscoreable” individual is not necessarily a high credit risk — rather they are an unknown credit risk. Many of these individuals pay rent on time and in full each month and could be great candidates for traditional credit. They just don’t have a credit history yet. The in-depth report also explores the future of alternative credit data. With more than 90 percent of the data in the world having been generated in just the past five years, there is no doubt more data sources will emerge in the coming years. Not all will make sense in assessing credit decisions, but there will definitely be new ways to capture consumer-permissioned data to benefit both consumer and lender. Read Full Report
Alternative credit data sources make it possible for lenders to gain a more holistic view of existing and potential client bases, enabling them to better determine the risk of lending to someone with little or no credit history. These sources also can provide lenders with a competitive edge by preparing them to be better equipped to mitigate losses, expand their scope of potential applicants, give them another look at the creditworthiness of previously-denied applicants, and enable them to properly adjust credit terms and pricing to better speak to compatible consumers. “Experian is a big supporter of the widespread reporting of alternative data—including, rental payments, utility payments and cellular telephone payments to name a few,” said Alex Lintner, president of Experian’s Consumer Information Services. Here are four FCRA-compliant alternative credit data sources to consider when evaluating consumers for credit: Alternative Financial Services: Alternative financial credit information, including payday and short-term installment loans and inquiries, on the majority of the United States’ subprime population. Rental Data: RentBureau includes detailed, positive and negative rental payment history information on more than 18 million consumers in the United States. Extended View Score: A risk model designed to evaluate the creditworthiness of thin-file and no-file consumers who have little to no traditional credit history. Account Aggregation: Permissioned by the consumer, a real-time data collection of his/her financial accounts (bank, credit card, investment and business) in a single location to digitally verify income and assets. Tapping into these resources can give deeper and richer results—improving overall data analytics and, subsequently, possibilities for future lending.