ICBA supports the use of consumer credit reports and credit scoring models as tools to objectively assess a borrower’s creditworthiness and ability to repay a loan.
ICBA opposes reforms to the credit reporting system that impose significant operational costs on community banks, potentially impacting the affordability of loans.
ICBA opposes efforts that limit the value of credit scores, such as limiting accurate and legitimate negative information on credit reports. Such limitations make credit more costly for all consumers, especially those that work hard to maintain a good credit score.
ICBA opposes changes to the Fair Credit Reporting Act’s dispute process that would make it easier for individuals to make fraudulent claims of inaccuracies, imposing an undue burden on community banks as furnishers of credit information.
ICBA opposes the creation and mandatory use of a government-owned and controlled credit bureau which would stifle innovation and could be manipulated for political purposes.
Congress must subject credit reporting agencies to banking agency examination and supervision comparable to that which applies to community banks and other financial institutions.
ICBA supports innovative ways to provide credit to unserved and underserved consumers. While we support banks’ efforts to consider “alternative data” in credit decision processes, we oppose any efforts to require the incorporation of “alternative data.”
Credit Reporting Agencies (CRAs) collect consumer data, such as names, addresses, social security numbers, credit histories, and public information, then compile that information into consumer credit reports.
CRAs also use this information to develop proprietary credit scores or share that information with entities that develop credit score models, which indicate a consumer’s propensity to repay a loan. These credit reports and credit scores are sold to third parties, such as banks, insurance companies, employers, landlords, and other entities that would like more information on an individual before entering into a formal relationship.
The credit reporting system serves as an independent and consistent mechanism for community banks to assess a consumer’s past financial behavior and anticipate their future performance when making underwriting decisions.
The accuracy of credit reports, including the completeness and veracity of the information, is of the utmost importance to community banks, since the utility of the credit report is closely correlated with its accuracy and completeness. Competition among CRAs results in more accurate and higher quality data and lower credit costs for borrowers.
Preserving the Usefulness of Credit Reports. ICBA recognizes that mechanisms to correct inaccurate, incomplete, or unverifiable information in reports are necessary. However, we strongly oppose changes to the dispute process that would make it easier for individuals to make fraudulent claims of credit report inaccuracies.
While well intended, such changes could counter-intuitively decrease the credit report’s accuracy and usefulness by reducing the time banks have to resolve legitimate disputes. Significant resources would have to be expended by banks to respond to a high volume of fraudulent disputes.
Examination and Supervision of Credit Reporting Agencies. Community banks and other financial institutions are required by statute and regulation to safeguard personally identifiable information. All participants in the payments and financial systems with access to customer financial information should be subject to Gramm-Leach-Bliley Act-like data security standards, as banks are.
While the FTC and the CFPB currently have enforcement authority over CRAs, it is imperative that problems are caught and addressed before the enforcement stage. To ensure consumers receive enhanced protection of their personal information, Congress should subject credit reporting agencies to banking agency examination and supervision comparable to that which applies to community banks and other financial institutions.
Alternative Data. ICBA recognizes that there may be potentially millions of consumers with limited credit histories that could become eligible for credit through the use of alternative data and modeling. Alternative data and modeling techniques are changing the way that some financial service providers conduct business.
However, new regulations that require community banks to incorporate alternative data into their credit decision processes could prevent community banks from making loans to those who need access to credit the most, increase costs, and stifle innovation. Requiring banks to use alternative data could also have unintended adverse consequences for consumers because some alternative data may actually negatively impact their credit profiles.
Staff Contacts: Susan Sullivan and Michael Emancipator