Alternative Credit Reporting: Is Experian Really Going to Help You Rebuild Your Credit?

BillsExperian aims to bring millions of Americans into the mainstream credit market by incorporating rental data into credit reports. RentBureau, which Experian acquired last June, is the largest collector of rental payment data. It collects and reports rental data from property management companies nationwide so lessors can screen potential tenants. Experian’s announcement earlier this month that it will include positive rental data is being billed as a new way for the estimated 50 million unbanked consumers to build credit. 

Credit scores have increasingly become a key factor in families’ ability to acquire assets. Credit scores are used to determine whether or not a family can get a loan to buy a home or a car, start a business, fund post-secondary education, or even obtain a credit card. Employers are also starting to use credit scores in the hiring process to screen applicants. Thus, a thin credit file or a low credit score can prevent families from acquiring the assets that lead to economic mobility.

For these reasons, consumer advocates, credit analysts, and lenders have been exploring different options for calculating credit-worthiness. The reporting of nontraditional or alternative credit data has frequently been suggested as one of these options. Since traditional data, such as credit cards, mortgages, and student loans, are not typically available for lower income families, the use of nontraditional data, such as utility bills, mobile phone bills, and rental payments, is viewed as a means of incorporating these individuals into the credit reporting industry. For example, one third of people in the United States are renters and now, like mortgage owners, their payment histories will affect their credit scores.

Yet, there is much debate as to whether the inclusion of nontraditional credit data will be helpful or harmful to low-income and credit-thin families. Some argue that such reporting will catapult previously excluded families into the mainstream lending market, allowing them to access the credit needed to build assets. Others argue that alternative reporting could prove to be harmful and be used to further marginalize low-income families. If, for example, a family must choose between paying for groceries or paying the light bill most families will choose groceries, thereby negatively affecting their credit scores. The Shriver Center addressed this issue in-depth in the Clearinghouse Review article,Alternative Credit Data: To Report or Not to Report, That is the Question, and facilitated a discussion of industry experts in a webinar, Credit Scoring and the Un-Scored: Alternative Credit Data.

Although, Experian’s announcement highlights the fact that its use of positive rental data in its calculation of consumers’ FICO scores “will … help many renters who are looking for ways to rebuild their credit scores due to financial hardships such as a foreclosure or a bankruptcy,” it omits the fact that in 2012 Experian will also begin reporting negative data (i.e., missed payments). Reporting such negative data will most certainly push those same families struggling to recover from foreclosure and bankruptcy out of their rental homes.

To be financially stable members of the U.S. economy, families must have access to credit. It remains to be seen whether reporting alternative data is the appropriate way to ensure low-income and asset-poor families’ successful entry into the mainstream credit industry. One thing for certain is that Experian’s so-called concern for those ”recovering from financial hardship” is not all that it seems. 

Kelly Ward coauthored this blog post.

 

 

The Changing Landscape for Alternative Small-Dollar Loans

This year is providing a growing opportunity for mainstream financial institutions to offer affordable small-dollar loans while proving to be a difficult one for predatory lenders. First, Illinois passed legislation closing a gaping loophole in payday lending regulation. Now, the Dodd-Frank Wall Street Reform and Consumer Protection Act, signed into law by President Obama on July 21st, has the potential to significantly increase the number of affordable small-dollar loans available to consumers. Title XII of the Act “encourage[s] initiatives for financial products and services that are appropriate and accessible for millions of Americans who are not fully incorporated into the financial mainstream.” Specifically, the Act will incentivize financial institutions to offer low-cost, small-dollar loans that serve as safe alternatives to payday loans.

Rather than regulating high-cost payday lenders, the Dodd-Frank Act seeks to provide financial incentives to institutions to offer more competitively priced small-dollar loan products through loan loss reserve funds, technical assistance funding, and other programs and grants to promote financial access and education. The Act authorizes the Secretary of the Treasury to establish grants to eligible entities to provide low-cost small-dollar loans. In this case, eligible entities include any federally insured depository institution, state, local or tribal government entities, community development financial institutions (CDFI) and 501(c)3 organizations. In order to receive a grant, the loan provider must offer financial literacy and educational opportunities to each small-dollar loan consumer.

The Act also includes several provisions that are exclusive to CDFIs. A CDFI is a financial institution that expands the availability of credit, investment capital, and financial services in economically distressed communities. The new legislation allows for the creation of loan loss reserve funds in order to help defray the costs of any defaults. Concerns regarding defaults are one of the primary obstacles cited by bankers who have expressed interest in starting a small-dollar loan program. However, after offering small-dollar loans for two years, the charge-off ratios were in line with industry standards for unsecured loans to individuals and charge-off rates compared favorably with credit cards. In order to qualify for the grant, the CDFI must offer a small-dollar loan program that offers loan amounts of $2,500 or less, to be repaid in installments with no pre-payment penalties, as well as any other requirements established by the fund administrator. As blogged previously, not all payday loan alternatives are created equal. Therefore, it is necessary to define the parameters of the eligible loan programs in a way that creates products that are truly safe, reasonable, appropriate, and accessible for consumers.

One tool to help create a consumer-friendly product is the template proposed in the FDIC’s Small-Dollar Loan Pilot Program. According to the FDIC, the essential elements of safe, affordable and feasible product design include:

  • Loan amount of $2,500 or less;
  • Term of 90 days or more;
  • APR of 36% including fees;
  • Streamlined underwriting with proof of identity and income;
  • Credit report (but not necessarily score) to determine loan amount and repayment ability.

This two-year pilot program, completed in the fourth quarter of 2009, included 28 participating banks that made more than 34,400 small-dollar loans with a principal balance of over $40 million, all with an APR of 36% or below, including any fees.

Three banks headquartered in Illinois participated in the FDIC study: Community Bank – Wheaton/Glen Ellyn, Lake Forest Bank & Trust, and State Bank of Countryside. Lake Forest Bank was able to earn a small profit on the loans and intends to develop long-term relationships with performing borrowers. Losses on their small-dollar loan product were no higher than those on other consumer loans. Lake Forest Bank reported one of the most successful changes made to its program was reducing the minimum loan amount to $250 to accommodate borrowers who did not need large amounts of credit. Also on the state level, the Illinois Asset Building Group (IABG), a diverse statewide coalition invested in building the stability and strength of Illinois communities through increased asset ownership and asset protection, is working to promote alternative small-dollar loans in Illinois. For more information, see the IABG brief Alternative Small-Dollar Loans in Illinois: Creating Sound Financial Products Through Regulation and Innovation. With 2010 just half over, there are even more changes on the horizon for the alternative small dollar loan landscape. Stay tuned!

This article was coauthored by Hannah Weinberger-Divack.

 

The Good, the Bad, and the Predatory: Not All Payday Loan Alternatives Are Created Equal

Payday lenderThe key to limiting the damage caused by payday lenders is tough regulations. Yet, the reason that payday lenders have proliferated in the first place is that there is a large need for small dollar loans. So, in addition to regulating payday lending we also need to increase access to safe, affordable alternatives. Expanding and promoting such alternatives will help to alleviate the financial burden on low-income and low-asset families.

Alternative small dollar loans need to be more than just payday loans lite. Instead they must be structured to ensure that they are safe and affordable. Not all payday loan alternatives are created equal. A new study from the National Consumer Law Center, which evaluated over one hundred existing products, found that there is a wide range of product quality from genuine alternatives and ones that come close to products that are merely payday loans disguised in a different name. Credit unions dominate the genuine alternatives, but some banks are also offering beneficial products.

The authors argue for a real alternative to payday loans that will fill a need for convenient, emergency credit without leaving consumers in worse financial shape than they began. The study clarifies several myths regarding alternative payday loans:

  • Just because a product is slightly cheaper does not make it good. A real alternative must be truly affordable.
  • A small profit margin does not equal a good product. Loans should be judged by their impact on the borrower.
  • An alternative does not need to be structured like a payday loan. In fact, the classic high fee structure and short repayment period cannot be replicated if we are to create a genuine alternative.
  • Expensive loans should not be tolerated because there is consumer demand. In many cases payday loans delay tough choices needed to get one’s personal finances back on track and instead can serve to make a bad situation worse.

Instead the report suggests that alternatives should contain the following characteristics:

  • A genuine payday loan alternative must have no greater than a 36% annual rate, including interest and fees.
  • A minimum of 90 days loan repayment term in manageable installments.
  • Must not employ a security method such as electronic access to a bank account that puts money for food and rent at risk. 

Hannah Weinberger-Divack coauthored this post.