| By Greg Fisher
|Top person:||William J. Lansing|
|Author:||James M. Wehmann|
|Addressee:||U.S. Federal Housing Finance Agency (FHFA)|
|Item:||RE: Proposed Rule on Process for Validation and Approval of Credit Score Models|
|Date:||March 21, 2019|
FROM: Greg Fisher, email@example.com
TO: Jim Wehmann, Fair Isaac; William Lansing, Fair Isaac (via G. Jawski)
CC: Alfred Pollard, FHFA
DATE: August 7, 2020
SUBJECT: transparency, FICO score
OPEN LETTER to be published at http://creditscoring.com/interaction/2020/08/07-ap-fair-isaac.html
In a March 21, 2019 letter to the U.S. Federal Housing Finance Agency, you wrote
FICO strongly supports measures designed to ensure that proposed credit score models comply with fair lending laws and, therefore, supports FHFA's proposed certification. Further, in the preamble to the proposed rule, FHFA states that "an Enterprise would not necessarily have access to the factors used in the development of the credit score model or used by the credit score model to produce credit scores..."13 To provide the Enterprises with insight into the factors used in credit score model development, FICO recommends that FHFA require model developers to submit the score factors or reason codes associated with the credit score model under consideration. FICO makes publicly available the list of reason codes currently used by the FICO Score.14
Footnote 14 is "US FICO Score Reason Codes, FICO (2013), https://www.fico.com/en/resource-download-file/3425."
Your document is not publicly available. Is the information secret? At that internet address there is only a message that states, "Page Not Found."
Searching and searching for something that does not even exist is not my idea of how to ride out a pandemic. Will you restore the paper in the footnote?
When I attempted to link to the same document, I was thwarted by your organization three times. Please stop hiding the ball.
I am particularly interested in Reason Code 04, "Too many bank/national revolving accounts," in Equifax Beacon 5.0. I call that model The Real Big Credit Score because it is delineated by the federal government-sponsored enterprise Fannie Mae for use in mortgage lending. And, historically, an Equifax-based Beacon score was the first FICO credit bureau score. Practically, it gives any discussion a common point of reference and eliminates the argument that a person is confusing facets of one credit score model with another.
This week, an Associated Press item written by Liz Weston stated, "The leading credit scoring formulas, FICO and VantageScore, don't punish people for having too many accounts."
Punish? Yikes! Do you punish us for anything?
The same item stated, "'It's not about the number of accounts,' says Ethan Dornhelm, FICO's vice president of scores and predictive analytics. 'It's about how those accounts are handled.'"
Of course, Dornhelm did not come right out and say that there can or can't be too many accounts. So, the question for him is this: What is the 'it' that you're talking about?
It's a pronoun problem.
You might remember that last millennium I spent a large part of my life asking how many accounts is too many. A Federal Reserve Bank vice president wrote, "Check out the web site http://www.creditscoring.com/letters/equifax.htm for some interesting reading."
Can I have too many bank/national revolving accounts, or not?
Now, if you think that this is an absolutely horrible state of affairs, you are correct. I try to use words appropriately, and horrible is exactly the right term.
False information spread by the AP
Finally, as a check on power, I point out to the shadow audience of this message to you that the Associated Press is far from truthful. AP reporter Lisa Mascaro falsely wrote, "Republican House Majority Leader Mitch McConnell took a far different view of the charges and proceedings." #falseinformation
That is the dumbest thing that I have ever heard. Mcconnell is not a member of the House of Representatives; he is in the senate.
Truth and Falsity
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