About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 [1] (August 27, 2020)

handle is hein.crs/govdbmg0001 and id is 1 raw text is: 










Alternative Data in Financial Services


August 27,2020


Alternative data generally refer to information used to
determine a consumer's creditworthiness that the national
consumer  reporting agencies-Equifax,Experian, and
TransUnion-do   not traditionally use to calculate a credit
score. These reporting agencies generally create consumer
reports containing historical information about repayment
on credit products such as mortgages, student loans, credit
cards, and auto loans. Credit applications, bankruptcies, and
debts in collection also are regularly included. In contrast,
alternative data include additional consumer financial data
not regularly contained in traditional credit files. New
technology makes it possible for financial institutions to
gather other information, including financial and
nonfmanicaldata, froma variety of sources.

The Consumer  Financial Protection Bureau (CFPB)
included the following list of alternative data examples in a
2017 requestforinformation:

    Data showing  trends or patterns in traditional loan
    repayment  data.
    Payment   data  relating to non-loan  products
    requiring regular (typically monthly) payments,
    such  as telecommunications, rent, insurance, or
    utilities.
    Checking  account transaction and cashflow data
    and information about a consumer's assets, which
    could include the regularity of a consumer's cash
    inflows and outflows, or information about prior
    income or expense shocks.
    Data  that some  consider  to be  related to a
    consumer's   stability, which  might   include
    information about the frequency of  changes in
    residences, employment, phone numbers or email
    addresses.
    Data   about   a  consumer's   educational  or
    occupational attainment, including information
    about schools attended, degrees obtained, and job
    positions held.
    Behavioral data about consumers,  such as how
    consumers  interact with a web interface or answer
    specific questions, or data about how they shop,
    browse, use devices, ormoveabout theirdaily lives.
    Data  about consumers'  friends and associates,
    including dataaboutconnections on socialmedia.
These data canbe usedeitherin creditreports orby lenders
directly to underwrite a loan (i.e., to determine whether to
lend to a consumer and at what price). Recent findings
suggest that some types of alternative data-suchas


education, employment, and cash-flowinformation-might
offer a promising way to expand access to credit. However,
the collection anduse of alternative data raise policy
concerns related to consumer protection and privacy.

Using   Alternative Data in CreditRe
Alternativedatahave thepotential to expand the number of
consumers  in the traditional credit reporting system.
Accordingto  the CFPB,credit scores cannotbe generated
for approximately 20% of the U.S. population due to their
limited credit histories. The CFPB categorizes consumers
with limited credit his tories into several groups. One
category of consumers, referred to as credit invisibles,
have no credit record at the three nationwide credit
reporting agencies and, thus, do notexist for the purposes
of credit reporting. Credit invisibles represent 11% of the
U.S. adult population, or 26 million consumers. Another
category of consumers have a credit record, but they cannot
be scored or are considered unscorable. Unscorable
consumers  either have insufficient (short) histories or stale
(outdated) histories. The insufficient and s tale unscored
groups,eachcontaining more than 9million individuals,
collectively represent 8.3% of the U.S. adult population, or
approximately 19 million consumers.

Figure I.Credit Invisible and Unscorable Consumers
as of 2010


Source: See Kenneth P. Brevoort, Philipp Grimm, and Michelle
Kambara, Data Point: Credit Invisibles, CFPB, May 20 I 5, p. 6, at
http://files.consumerfinance.gov/f/201505_cfpb-data-point-credit-
invisibles.pdf.

Alternativedatacould be used to calculate scores for some
consumers  with limited credit history, which would allow
lenders using these scores to better determine the
creditworthiness ofpeople in this group. Moreover,
alternative data used in the credit reporting systemcould
increase credit reporting accuracy for all consumers by


yg

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Already a HeinOnline Subscriber?

profiles profiles most