The Regulation
A continuing story
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- Nation's Big Three Consumer Reporting Agencies Agree To Pay $2.5 MillionTo Settle FTC Charges of Violating Fair Credit Reporting Act
- Trans Union's Sale of Personal Credit Information Violates Fair Credit Reporting Act, FTC Rules - "... the Commission focused on the second prong and "reviewed record evidence detailing the various factors lenders use in evaluating credit eligibility . . . in particular . . . the factors that are important in calculating credit scores - - a tool that many lenders use in evaluating credit eligibility."
- FOR YOUR INFORMATION..........May 31, 1985 - "In particular, the staff opposed provisions requiring creditors to disclose the factors they use in credit scoring systems."
- FOR YOUR INFORMATION..........September 23, 1986 - "A properly designed scoring system, according to the brochure, allows creditors to evaluate millions of applicants consistently, impartially, and quickly." ["millions"? Also, see "... Developed from a representative national sample of roughly 1 million Experian consumer credit histories... "]
- FOR RELEASE: FEBRUARY 11, 1992 - "RISK SCORES" ON CONSUMER CREDIT REPORTS MUST BE DISCLOSED TO CONSUMERS, FTC SAYS IN REVISED COMMENTARY ON CREDIT REPORTING LAW
- FOR YOUR INFORMATION..............................JUNE 17, 1994 - "Credit bureaus would be required to disclose to consumers who seek copies of their credit reports any currently-calculated "risk scores" if the credit bureaus had previously given such scores to clients to assist them in evaluating those consumers' creditworthiness or other permissible purpose, under a Federal Trade Commission proposal... The Commission vote to announce the proposal was 5-0."
- "Risk Score" Disclosure - FOR RELEASE: SEPTEMBER 1, 1995 - FTC CONCLUDES THAT CREDIT "RISK SCORE" DISCLOSURE IS NOT REQUIRED BY FAIR CREDIT REPORTING ACT
- 1995 Amendments to FCRA Commentary
- Search results for "credit scoring" on the FDIC's site
- Federal Reserve: Partners Newsletter V6 N3 - Automated Underwriting in the Financial Services Industry Today - "For example, a typical strategy for a borrower who has an otherwise pristine payment history but who haslet his credit card payment go one payment past due, may involve sending just a friendly reminder on his next credit card statement. On the other hand, a similarly tardy borrower with a history of late payments may receive a terse phone call from a collector."
- 6500 - CONSUMER PROTECTION - FDIC
- The "New" Science of Credit Risk Management ...
- "Where Credit Is Due: Credit Scoring and Mortgage Lending," Federal Reserve Bank of Boston, Communites & Banking, Fall 1996 (No. 18)
"Some question what will occur when originator or underwriter judgment is called for, particularly when applicants have FICO scores under 660. Avery et al. report that fully 40 percent of all mortgage loan applicants fall into this grey area, which signals an underwriter to perform a comprehensive or a cautious review. Will underwriters take the time to amass the additional information and documentation required for these loan applications?... Some private secondary market investors have established policies whereby they will not purchase loans with credit
scores below 680. And Freddie Mac's Peter Mahoney, Senior Vice President and General Counsel, confirms that some customers have agreed contractually not to sell any loan to Freddie Mac with a score under 620."
- http://www.phil.frb.org/econ/br/brso97lm.pdf
- Memphis Regional Outlook, 2Q97: In Focus, Credit Scoring
- NR 97-46
May 20, 1997 OCC Alerts Banks to Potential Benefits and Risks Of Credit Scoring Models...
- OCC 95-63
- The Federal Reserve Board Consumer Advisory Council discusses credit scoring
- HUD: What We Know About Mortgage Lending Discrimination In America
- Equal Credit Opportunity; Proposed Rule - A search for "scor" produces 140 hits
- 11/12/99 - HUD Secretary Andrew Cuomo: "'In effect, FHA's new automated underwriting system will be like a glass box, exposed to the light of day and public scrutiny.'
'In contrast, some automated underwriting systems in use today are known as "black boxes" because outsiders aren't allowed to examine their inner workings.'"
Who could he be talking about?
One of Freddie Mac's 10 "myths associated with credit scoring": "Credit scoring models are a black box and we don't know how they work."
Try a word search on that page for "black box" and watch the squirming.
OCC
Subject: Credit bureau score validity
Date: Mon, 10 Aug 1998 00:39:27 -0400
From: Greg Fisher
To: Webmaster@occ.treas.gov
Julie L. Williams
Comptroller of the Currency (Acting)
Office of the Comptroller of the Currency
Do you regulate consumer reporting agencies with regard to the validity of credit bureau scores?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: Re: Credit bureau score validity
Date: Mon, 10 Aug 1998 06:52:39 -0400
From: John.Englund@occ.treas.gov
To: Greg Fisher
The Office of the Comptroller of the Currency (OCC) charters, regulates,
and supervises national banks to ensure a safe, sound and competitive
national banking system that supports the citizens, communities and economy
of the United States. We do not regulate credit bureaus.
--Webmaster@occ.treas.gov
Fed
Subject: Credit bureau score validity
Date: Mon, 10 Aug 1998 00:33:18 -0400
From: Greg Fisher
To: jim.mceneaney@bos.frb.org
Cathy E. Minehan
President and Chief Executive Officer
Federal Reserve Bank of Boston
Do you regulate consumer reporting agencies with regard to the validity of credit bureau scores?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: Credit Bureau Score Validity
Date: Mon, 10 Aug 1998 17:34:40 -0400
From: Anthony Ricko
To: gfisher@erinet.com
CC: Jim McEneaney
Mr. Fisher
This is in response to the question you posed to the Federal Reserve
Bank of Boston via our internet web page. The Federal Reserve Bank of
Boston does not have regulatory authority over consumer reporting
agencies. The Federal Trade Commission (FTC) is the primary federal
regulator for these entities. You can obtain additional information
concerning the FTC at www.ftc.gov.
I hope this information is helpful. Please feel free to contact me at
(617) 973-5987, if you have any questions.
Thanks, Anthony Ricko
FTC
Subject: Credit bureau score validity
Date: Mon, 10 Aug 1998 00:10:51 -0400
From: Greg Fisher
To: webmaster@ftc.gov
Do you regulate consumer reporting agencies with regard to the validity
of credit bureau scores?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: [Fwd: Credit bureau score validity]
Date: Wed, 19 Aug 1998 04:19:03 -0400
From: Greg Fisher
To: "webmaster@ftc.gov"
I wrote to you about a week ago with the attached message.
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject:
Credit bureau score validity
Date: Mon, 10 Aug 1998 00:10:51 -0400
From: Greg Fisher
To: webmaster@ftc.gov
Do you regulate consumer reporting agencies with regard to the validity
of credit bureau scores?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
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Subject:
Re: [Fwd: Credit bureau score validity]
Date: Wed, 19 Aug 1998 10:02:48 -0400
From: "Gregory E. Hales"
To: Greg Fisher
Sir:
Your e-mail was forwarded to the Consumer Response Center for handling.
Their e-mail address is: < crc@ftc.gov >
Greg Hales
+-------------------------------------------+
Gregory E. Hales, Webmaster
Federal Trade Commission
Telephone: [removed by Credit Scoring Site editor]
E-Mail: ghales@graywolf.ftc.gov
ghales@ftc.gov
+-------------------------------------------+
Subject: [Fwd: Credit bureau score validity] -Reply
Date: Thu, 20 Aug 1998 11:07:04 -0400
From: Matt Lewis
To: gfisher@erinet.com
Hello Greg,
Thank you for sending your e-mail message.
The Federal Trade Commission does not regulate Scoring, The FTC
regulates Nagative Credit Infromation only.
If you like to send a complaint to the FTC by the internet - Please go to the
following FTC Homepage to send your E-mail Complaint -
( www.ftc.gov/ftc/complaint.htm )
Our mailing Address Is:
Federal Trade Commission
Room 240
600 Pennslyvania Ave. N.W.
Washington, DC. 20580
Thank you,
FTC WASH DC
Subject: Re: [Fwd: Credit bureau score validity] -Reply
Date: Thu, 20 Aug 1998 11:57:49 -0400
From: Greg Fisher
To: Matt Lewis
References: 1
If you do not, who regulates credit scoring?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: Re: [Fwd: Credit bureau score validity] -Reply
Date: Sun, 30 Aug 1998 13:03:12 -0400
From: Greg Fisher
To: Matt Lewis
References: 1 , 2
If you do not, who regulates credit scoring?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: Re: [Fwd: Credit bureau score validity] -Reply
Date: Sat, 12 Sep 1998 17:05:30 -0400
From: Greg Fisher
To: Matt Lewis
References: 1 , 2 , 3
David Medine
Associate Director for Credit Practices
Federal Trade Commission
Who regulates credit scoring?
--
Greg Fisher
Cadillac Owner (1978 Eldo)(Red)
Subject: [Fwd: [Fwd: Credit bureau score validity] -Reply] -Reply
Date: Wed, 16 Sep 1998 13:36:52 -0400
From: David Medine
To: gfisher@erinet.com
Credit scoring is not regulated directly. However, to the extent it
implicates the Fair Credit Reporting Act or the Equal Credit
Opportunity Act, the Federal Trade Commission has jurisdiction
if the entity involved is not a federally insured depository
institution. The latter would be governed by their regulator, such
as the Comptroller of the Currency or the Office of Thrift
Supervision. Hope that is helpful.
Subject: Re: [Fwd: [Fwd: Credit bureau score validity] -Reply] -Reply
Date: Sun, 27 Sep 1998 21:43:36 -0400
From: Greg Fisher
To: David Medine
References: 1
Thank you.
Has there been any study by the FTC in the past three years to determine if credit scoring by consumer reporting agencies is valid? Has there been any in the past ten years?
Subject: Re: [Fwd: [Fwd: Credit bureau score validity] -Reply] -Reply -Reply
Date: Tue, 29 Sep 1998 01:15:46 -0400
From: David Medine
To: gfisher@erinet.com
I am not aware of any such studies.
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