It may take time and regulatory easing for depositories to emulate organizations like SoFi in transitioning to a "FICO-free" credit scoring model, but there is definite merit in leveraging alternative models to tap into a significantly underserved (yet creditworthy) segment of the population. Developing an alternative credit score or leveraging existing models enables a lender to penetrate this overlooked market and gain new consumers at a time of increased competition and reduced profit margins.
Heightened regulations have increased compliance costs for traditional lending institutions, driving capital constraints and reducing spending for revenue-generating technology projects. This has created an opportunity for new entrants to the market, such as Zest Finance
An Experian study estimated that 64 million consumers in the United States do not have a FICO credit score. Further,
Existing credit bureaus such as Experian and TransUnion have responded by
In addition to expanding opportunities to offer tailored products and a friendlier customer experience, alternative data points and algorithms used for credit analysis
The traditional underwriting process can also be enhanced by leveraging nonconventional variables such as credit card transactions, social media presence and utility bills. This can potentially reduce credit risk through expanded risk modeling and monitoring. Lenders should consider back testing alternative scoring models as a challenger to compare against the FICO model in a champion-challenger sandbox environment.
Alternative credit scoring presents tremendous opportunities, but it is not without risks and challenges. For example, lenders need to ensure the use of alternative credit scoring complies with regulatory standards like Equal Credit Opportunity Act or Fair Credit Reporting Act.
In addition, governance regarding data accuracy and objective application of the methodology is critically important. The industry needs to recognize that alternative credit scores are
Lenders can take proactive steps as using alternative credit scoring gains greater acceptance in order to mitigate some of these risks. For instance, lenders should develop a strong compliance program before the implementation of alternative credit scoring in the underwriting process to ensure adherence with all relevant regulations. Staff should be well-trained and knowledgeable in order to quickly identify any risk areas and adapt to evolving regulations.
Data and model calculation is of the utmost importance, and one way to ensure accuracy is to establish an enterprise-wide data governance structure that is cross-functional and includes representatives from all stakeholder groups with decision-making authority. In addition, procedures for ongoing analysis of data groups and their correlation to borrowers' credit histories should be created.
Compliance teams should conduct regular internal and external audits to ensure that procedures are followed without adverse impact, and test strategies on a representative sample before rolling out across the entire business. Again, champion-challenger testing should be implemented to validate changes to the organization's decision logic and risk policy.
Roadblocks and challenges aside, big data and advanced analytics are firmly ensconced as critical focus areas for the technology providers for the next decade. Industry players who are able to leverage the power of technology to create congruent business processes and solutions will emerge as the new thought leaders of the industry. A combination of new data sources, supporting technology and regulatory conditions and an innovative yet safe approach to products and offerings is the perfect storm to transform the current housing finance market and potentially, charge the economic engine of the country.
Adi Ghosh is a director focused on the primary and secondary housing finance market, and Harsh Sharma is a business consultant, with Sapient Global Markets based out of Washington D.C.