VIII. SCORING AND MODELING

Scoring and Modeling

VIII. SCORING AND MODELING

Scoring and modeling, whether internally or externally developed, are used extensively in credit card lending. Scoring models summarize available, relevant information about consumers and reduce the information into a set of ordered categories (scores) that foretell an outcome. A consumer's score is a numerical snapshot of his or her estimated risk profile at that point in time. Scoring models can offer a fast, cost-efficient, and objective way to make sound lending decisions based on bank and/or industry experience. But, as with any modeling approach, scores are simplifications of complex real-world phenomena and, at best, only approximate risk.

Scoring models are used for many purposes, including, but not limited to:

? Controlling risk selection. ? Translating the risk of default into appropriate pricing. ? Managing credit losses. ? Evaluating new loan programs. ? Reducing loan approval processing time. ? Ensuring that existing credit criteria are sound and consistently applied. ? Increasing profitability. ? Improving targeting for treatments, such as account management treatments. ? Assessing the underlying risk of loans which may encourage the credit card backed

securities market by equipping investors with objective measurements for analyzing the credit card loan pools. ? Refining solicitation targeting to minimize acquisition costs.

Credit scoring models (also termed scorecards in the industry) are primarily used to inform management for decision making and to provide predictive information on the potential for delinquency or default that may be used in the loan approval process and risk pricing. Further, credit risk models often use segment definitions created around credit scores because scores provide information that can be vital in deploying the most effective risk management strategies and in determining credit card loss allowances. Erroneous, misused, misunderstood, or poorly developed and managed scoring models may lead to lost revenues through poor customer selection (credit risk) or collections management. Therefore, an examiner's assessment of credit risk and credit risk management usually requires a thorough evaluation of the use and reliability of the models. The management component rating may also be influenced if governance procedures, especially over critical models, are weak. Regulatory reviews usually focus on the core components of the bank's governance practices by evaluating model oversight, examining model controls, and reviewing model validation. They also consider findings of the bank's audit program relative to these areas. For purposes of this chapter, the main focus will be scoring and scoring models. A brief discussion on validating automated valuation models (AVM) is included in the Validation section of this chapter, and loss models are discussed in the Allowances for Loan Losses chapter. Valuation modeling for residual interests is addressed in the Risk Management Credit Card Securitization Manual.

Scoring models are developed by analyzing statistics and picking out cardholders' characteristics thought to be associated with creditworthiness. There are many different ways to compress the data into scores, and there are several different outcomes that can be modeled. As such, scoring models have a wide range of sophistication, from very simple models with only a few data inputs that predict a single outcome to very complex models that have several data inputs and that predict several outcomes. Each bank may use one or more generic, semicustom, or custom models, any of which may be developed by a scoring company or by internal staff. They may also use different scoring models for different types of credit. Each bank weighs scores differently in lending processes, selects when and where to inject the scores into the

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processes, and sets cut-off scores consistent with the bank's risk appetite. Use of scoring models provides for streamlining but does not permit banks to improperly reduce documentation required for loans or to skip basic lending tenants such as collateral appraisals or valuations.

Practices regarding scoring and modeling not only pose consumer lending compliance risks but also pose safety and soundness risks. A prominent risk is the potential for model output (in this case scores) to incorrectly inform management in the decision-making process. If problematic scoring or score modeling cause management to make inappropriate lending decisions, the bank could fall prey to increased credit risk, weakened profitability, liquidity strains, and so forth. For example, a model could wrongly suggest that applicants with a score of XYZ meet the bank's risk criteria and the bank would then make loans to such applicants. If the model is wrong and scores of XYZ are of much higher risk than estimated, the bank could be left holding a sizable portfolio of accounts that carry much higher credit risk than anticipated. If delinquencies and losses are higher than modeling suggests, the bank's earnings, liquidity, and capital protection could be adversely impacted. Or, if such accounts are part of a securitization, performance of the securitization could be at risk and could put the bank's liquidity position at risk, for instance, if cash must be trapped or if the securitization goes into early amortization. A poorly performing securitization would also impact the fair value of the residual interests retained.

Well-run operations that use scoring models have clearly-defined strategies for use of the models. Since scoring models can have significant impacts on all ranges of a credit card account's life, from marketing to closure, charge-off, and recovery, scoring models are to be developed, implemented, tested, and maintained with extreme care. Examiners should expect management to carefully evaluate new models internally developed as well as models newly purchased from vendors. They should also determine whether management validates models periodically, including comparing actual performance to expected performance. Examiners should expect management to:

? Understand the credit scoring models thoroughly. ? Ensure each model is only used for its intended purpose, or if adapted to other

purposes, appropriately test and validate it for those purposes. ? Validate each model's performance regularly. ? Review tracking reports, including the performance of overrides. ? Take appropriate action when a model's performance deteriorates. ? Ensure each model's compliance with consumer lending laws as well as other

regulations and guidance.

Most likely, scoring and modeling will increasingly guide risk management, capital allocation, credit risk, and profitability analysis. The increasing impetus on scoring and modeling to be embedded in management's lending decisions and risk management processes accentuates the importance of understanding scoring model concepts and underlying risks.

TYPES OF SCORING

Some banks use more than one type of score. This section explores scores commonly used. While most scores and models are generally established as distinct devices, a movement to integrate models and scores across an account's life cycle has become evident.

FICO Scores

Credit bureaus offer several different types of scores. Credit bureau scores are typically used for purposes which include:

? Screening pre-approved solicitations. ? Determining whether to acquire entire portfolios or segments thereof.

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? Establishing cross-sales of other products. ? Making credit approval decisions. ? Assigning credit limits and risk-based pricing. ? Guiding account management functions such as line increases, authorizations,

renewals, and collections.

The most commonly known and used credit bureau scores are called FICO scores. FICO scores stem from modeling pioneered by Fair, Isaac and Company (now known as Fair Isaac Corporation) (Fair Isaac), hence the label "FICO" score. Fair Isaac devised mathematical modeling to predict the credit risk of consumers based on information in the consumer's credit report. There are three main credit bureaus in the United States that house consumers' credit data: Equifax, TransUnion, and Experian. The credit-reporting system is voluntary, and lenders usually update consumers' credit reports monthly with data such as, but not limited to, types of credit used, outstanding balances, and payment histories. A consumer's bureau score can be significantly impacted by a bank's reporting practices. For instance, some banks have not reported certain information to the bureaus. If credit limits are not reported, the score model might use the high balance (the reported highest balance ever drawn on the account) in place of the absent credit limit, potentially inflating the utilization ratio and lowering the credit score. Errors in, or incompleteness of, consumer-provided or pubic record information in credit reports can also impact scoring. Consumer-supplied information comes mainly from credit applications, and items of public record include items such as bankruptcies, court judgments, and liens.

Each bureau generates its own scores by running the consumer's file through the modeling process. Although banks might not use all three bureaus equally, the scoring models are designed to be consistent across the bureaus (even though developed separately). Thus, an applicant should receive the same or a similar score from each bureau. In reality, variations (usually minor) arise due to differences in the way the bureaus collect credit information (for example, differences in the date of data collection) or due to discrepancies among information the bureaus, which could include inaccurate information. FICO scores rank-order consumers by the likelihood that they will become seriously delinquent in the 24 months following scoring. FICO scores of 660 or below may be considered illustrative of subprime lending (as set forth in the January 2001 Expanded Guidance for Subprime Lending), although other characteristics are normally considered in subprime lending determinations as well.

Benefits of credit bureau scoring include that it is readily available, is relatively easy to implement, can be less expensive compared to internal models, and is usually accompanied by various bureau-provided resources. Disadvantages include that scoring details are, for the most part, confidential and that it is available to every lender (no competitive differentiation).

As is the case for any type of scores generated by models, FICO scores are inherently imperfect. Nevertheless, they usually maintain effective rank ordering and can be useful tools, particularly when resource or volume limitations preclude the development of a custom score. Several types of FICO scores are in use including Classic FICO, NextGen FICO Risk, FICO Expansion, and FICO Industry Options. Collectively, the scores are called FICO scores in this manual.

There are three different Classic FICO scores, one at each of the bureaus. According to , they are branded as Beacon scores at Equifax; FICO Risk or Classic (formerly known as EMPIRICA) scores at TransUnion; and Experian/Fair Isaac Risk Model scores at Experian. Scores range from 300 to 850, with higher scores reflecting lower credit risk.

NextGen FICO Risk scores draw their name from being touted as the "next generation" of credit bureau scores. They are branded as Pinnacle at Equifax; FICO Risk Score, NextGen (formerly PRECISION) at TransUnion; and Experian/Fair Isaac Advanced Risk Score at Experian. Compared to Classic scores, NextGen scores are reported to use more complex predictive variables, an expanded segmentation scheme, and a better differentiation between degrees of future payment performance. According to , the score range, 150 to 950, is

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widened, although odds-to-score ratios at interval score ranges remain the same. Cumulative odds may vary.

For accounts lacking sufficient credit file information to generate a Classic or NextGen FICO score, some lenders use the FICO Expansion score. The FICO Expansion score, introduced in 2004, likely draws its name from "expanding" the credit information considered in the score to beyond that collected in a standard credit report. The expanded information includes items such as payday loans, checking account usage, and utility and rental payments. The FICO Expansion score has the same range and scaling as the Classic scores.

FICO Industry Options scores draw their name from being specific to several options of industries, such as bankcard.

VantageScore

The bureaus historically used their own proprietary models (based on Fair Isaac modeling) to develop FICO scores. However, in 2006, the bureaus introduced a new scoring system under which a single methodology is used to create scores at all three bureaus. The new system is called VantageScore. Because a single methodology is used, the score for each consumer should virtually be the same across all three bureaus. Any differences are attributed to differences in data in the consumer's files. The score will continue to incorporate typical consumer report file content but will range from 501 to 990. The scores are scaled similar to the letter grades of an academic scale (A, B, C, D, and F). Again, the higher the score, the lower the credit risk. Consumers may likely have VantageScores that are higher than their FICO scores. This is due to scaling and that phenomena alone does not indicate that a consumer is a better credit risk than he or she was under the traditional FICO score system. Further, when determining whether subprime lending exists, the new scale will need to be considered (in other words, 660 may not be a benchmark when looking at VantageScores). The industry's rate of replacement of custom and generic scores with VantageScore remains to be seen as of the writing of this manual.

Other Scores

In addition to or instead of generic credit bureau scores, many banks use other types of scores. Brief discussions on a variety of these scores follow, in alphabetical order. The bureaus and other vendors offer models for many of these types of scoring.

Application Scoring:

Application scoring involves assigning point values to predictive variables on an application before making credit approval decisions. Typical application data include items like length of employment, length of time at current residence, rent or own residence, and income level. Points for the variables are summed to arrive at an application score. Application scores can help determine the credit's terms and conditions.

Attrition Scoring:

Attrition scores attempt to identify consumers that are most likely to close their accounts, allow their accounts to go dormant, or sharply reduce their outstanding balance. Identification of such accounts may allow management to take proactive measures to cost-effectively retain the accounts and build balances on the accounts.

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Scoring and Modeling

Bankruptcy Scoring:

Bankruptcy scores attempt to identify borrowers most likely to declare bankruptcy. HORIZON (by Fair Isaac) is a common credit bureau bankruptcy score.

Behavior Scoring:

Behavior scoring involves assigning point values to internally-derived information such as payment behavior, usage pattern, and delinquency history. Behavior scores are intended to embody the cardholder's history with the bank. Their use assists management with evaluating credit risk and correspondingly making account management decisions for the existing accounts. As with credit bureau scores, there are a number of scorecards from which behavior scores are calculated. These scorecards are designed to capture unique characteristics of products such as private label, affinity, and co-branded cards.

Behavior scoring systems are often periodically supplemented with credit bureau scores to predict which accounts will become delinquent. Using a combination allows management to evaluate the composite level of risk and thus vary account management strategies accordingly.

Adaptive control systems (ACS) commonly use behavior scoring. ACS bring consumer behavior and other attributes into play for decisions in key management disciplines (for instance, line management, collections, and authorizations) so as to reduce credit losses and increase promotional opportunities. ACS include software packages that assist management in developing and analyzing various strategies taking into account the population and economic environment. They are a combination of software actionable analytics and optimization techniques and use risk/reward logic. ACS recognize that accounts can go in several directions. They consider the possible outcomes of the options and determine the "best" move to make. With ACS, challenger strategies can be tested on a portion of the accounts while retaining the existing strategy (champion strategy) on the remainder. Continual testing of alternative strategies can help the bank achieve better profits and control losses. Many large banks use TRIAD (developed by Fair Isaac) or a similar ACS, but smaller banks may lack the capital or the infrastructure to implement such a process.

Collection Scoring:

Collection scoring systems rank accounts by the likelihood of taking delivery of payments due. They are used to determine collection strategies, collection queue assignments, dialer queue assignments, collection agency placement, and so forth. Collection scores are normally used in the middle to late stages of delinquency.

Fraud Detection Scoring:

Fraud detection scores attempt to identify accounts with potential fraudulent activity. Fraud continues to be pervasive in the credit card lending industry and detection of potential fraudulent activity can help identify and control losses as well as assist management in developing fraud prevention controls.

Payment Projection Scoring:

Payment projection scoring models use internal data to rank accounts, normally by the relative percentage of the balance that is likely to be repaid. Some models only forecast the relative percentage, while others rank the likelihood a cardholder will pay a moderate to high level of the account balance. The scores are normally used in the early to middle stages of delinquency.

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