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Credit Score Accuracy and Implications for Consumers December 17, 2002: Consumer Federation of America National Credit Reporting Association

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When a consumer applies for employment, or for a service that reviews credit histories, (such as insurance, an apartment rental, utilities, cell phone accounts) these data users may also request and receive a credit report and/or scores from one or more repositories, to be used to evaluate the consumer’ s application. Job applicants or employees must provide consent before a report is pulled, but other users derive a permissible purpose to review credit from the consumer’ s act of submitting an application, except in Vermont, where oral consent is required to review a credit report for credit uses. . | Credit Score Accuracy and Implications for Consumers December 17 2002 Consumer Federation of America National Credit Reporting Association Table of Contents I. About Privacy.1 II. The Growing Importance of Credit Scores.2 III. Controversial Issues Affecting Consumers.4 A. Speed. 4 B. Customized or Risk-Based Pricing. 4 C. Effect on Discrimination. 4 D. Statistical Validity.5 E. Untested Scoring Formulas.5 F. Inaccurate credit reports.6 IV. How Does the System Work .8 A. Non-Mortgage Credit.9 B. Employment and Services Other Than Loans.10 C. Other Data Providers.10 D. Mortgage Credit.11 1. Portfolio Loans.11 2. Loans Sold in the Secondary Market.13 3. Credit Rescoring.14 4. Federal Housing Administration FHA and Department of Veterans Affairs VA Loans.15 V. Study Design.16 A. Phase One. 16 B. Phase Two.17 C. Phase Three. 18 VI. Findings . 20 A. Phase One. 20 1. Almost One in Ten Files was Missing a Credit Score from at Least One Repository.20 2. A Substantial Number of Files Met the Criteria for Further Review.20 3. Numerous Files Contained Additional Repository Reports and Information not Relevant to the Consumer s Credit History.21 4. Scores Reported by the Three Repositories for a Given Consumer Varied Substantially.22 5. Reports Contained Limited Information to Help Consumers Understand the Principal Reasons for their Credit Scores.23 6. In Depth Reviews Revealed Significant Errors and Inconsistencies Some of Which were Likely Artificially Lowering Consumer Credit Scores and Some of Which were Likely Artificially Raising Consumer Credit Scores.24 B. Phase Two. 25 1. Scores Reported by the Three Repositories for a Given Consumer Varied Substantially.25 2. Reports Scored With Different Versions of Scoring Software Reflected Almost No Difference in Overall Variability of Credit Scores.26 3. Reports Contained Limited Information to Help Consumers Understand the Principal Reasons for their Credit Scores.27 ii C. Phase Three - Specific Types of Errors.28 1. .

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