IDEAS home Printed from https://ideas.repec.org/p/fip/fedpdp/14-02.html
   My bibliography  Save this paper

Fair lending analysis of credit cards

Author

Listed:

Abstract

This paper discusses some of the key fair lending risks that can arise in various stages of the marketing, acquisition, and management of credit card accounts, and the analysis that can be employed to manage such risks. The Equal Credit Opportunity Act (ECOA) and its implementing Regulation B prohibit discrimination in all aspects of credit transactions and include specific provisions relating to processes that employ credit scoring models. This paper discusses some of the areas of credit card operations that may be assessed in an effort to manage the risk of noncompliance with fair lending laws and regulations. Particular attention is focused on approaches to testing for the risk of disparate impact on a prohibited basis in credit scoring models and model-intensive prescreened marketing campaigns, as well as in judgmental credit card underwriting. The paper concludes by discussing how the fair lending risks associated with credit scoring models may be managed by synchronizing compliance oversight with an institution's model governance framework. The methods discussed in this paper are also applicable to other consumer credit products that utilize credit scoring models.

Suggested Citation

  • Dubravka Ritter & David Skanderson, 2014. "Fair lending analysis of credit cards," Consumer Finance Institute discussion papers 14-2, Federal Reserve Bank of Philadelphia.
    • Handle: RePEc:fip:fedpdp:14-02
    as

    Download full text from publisher

    File URL: https://www.philadelphiafed.org/consumer-finance/consumer-credit/fair-lending-analysis-of-credit-cards
    Download Restriction: no
    File URL: https://www.philadelphiafed.org/-/media/frbp/assets/consumer-finance/discussion-papers/dp14-02.pdf
    File Function: Full text
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Robert B. Avery & Kenneth P. Brevoort & Glenn Canner, 2012. "Does Credit Scoring Produce a Disparate Impact?," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 40, pages 65-114, December.
    2. Dubravka Ritter, 2012. "Do we still need the Equal Credit Opportunity Act?," Consumer Finance Institute discussion papers 12-03, Federal Reserve Bank of Philadelphia.
    3. Stephen L. Ross & John Yinger, 2002. "The Color of Credit: Mortgage Discrimination, Research Methodology, and Fair-Lending Enforcement," MIT Press Books, The MIT Press, edition 1, volume 1, number 0262182289, December.
    4. M. Cary Collins & Keith D. Harvey & Peter J. Nigro, 2002. "The Influence of Bureau Scores, Customized Scores and Judgmental Review on the Bank Underwriting Decision-Making Process," Journal of Real Estate Research, American Real Estate Society, vol. 24(2), pages 129-152.
    5. Robert B. Avery & Raphael W. Bostic & Paul S. Calem & Glenn B. Canner, 2000. "Credit Scoring: Statistical Issues and Evidence from Credit-Bureau Files," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 28(3), pages 523-547.
    6. M Collins & Keith Harvey & Peter Nigro, 2002. "The Influence of Bureau Scores, Customized Scores and Judgmental Review on the Bank Underwriting Decision-Making Process," Journal of Real Estate Research, Taylor & Francis Journals, vol. 24(2), pages 129-152, January.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Vitaly Meursault & Daniel Moulton & Larry Santucci & Nathan Schor, 2022. "One Threshold Doesn’t Fit All: Tailoring Machine Learning Predictions of Consumer Default for Lower-Income Areas," Working Papers 22-39, Federal Reserve Bank of Philadelphia.
    2. Ryan M. Goodstein & Alicia Lloro & Sherrie L.W. Rhine & Jeffrey M. Weinstein, 2021. "What accounts for racial and ethnic differences in credit use?," Journal of Consumer Affairs, Wiley Blackwell, vol. 55(2), pages 389-416, June.
    3. Valentina Dimitrova-Grajzl & Peter Grajzl & A. Joseph Guse & Richard M. Todd & Michael Williams, 2018. "Neighborhood Racial Characteristics, Credit History, and Bankcard Credit in Indian Country," Comparative Economic Studies, Palgrave Macmillan;Association for Comparative Economic Studies, vol. 60(3), pages 410-441, September.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Jonathan Spader, 2010. "Beyond Disparate Impact: Risk-based Pricing and Disparity in Consumer Credit History Scores," The Review of Black Political Economy, Springer;National Economic Association, vol. 37(2), pages 61-78, June.
    2. Danny Ben-Shahar, 2008. "Default, Credit Scoring, and Loan-to-Value: a Theoretical Analysis under Competitive and Non-Competitive Mortgage Markets," Journal of Real Estate Research, American Real Estate Society, vol. 30(2), pages 161-190.
    3. repec:max:cprpbr:24 is not listed on IDEAS
    4. Zilong Liu & Hongyan Liang, 2025. "Racial Disparities in Conforming Mortgage Lending: A Comparative Study of Fintech and Traditional Lenders Under Regulatory Oversight," FinTech, MDPI, vol. 4(1), pages 1-23, February.
    5. Rodríguez-García, Jair Hissarly & Venegas-Martínez, Francisco, 2021. "Reducción de la brecha del crédito en México en un ambiente de incertidumbre generada por la pandemia COVID-19: Un enfoque de ciencia de datos (machine learning) [Reducing the credit gap in Mexico ," MPRA Paper 105133, University Library of Munich, Germany.
    6. Jonathan S. Spader & Roberto G. Quercia, 2008. "Mobility and exit from homeownership: Implications for community reinvestment lending," Housing Policy Debate, Taylor & Francis Journals, vol. 19(4), pages 675-709, January.
    7. Berger, Allen N, 2003. "The Economic Effects of Technological Progress: Evidence from the Banking Industry," Journal of Money, Credit and Banking, Blackwell Publishing, vol. 35(2), pages 141-176, April.
    8. Manthos D. Delis & Panagiotis Papadopoulos, 2019. "Mortgage Lending Discrimination Across the U.S.: New Methodology and New Evidence," Journal of Financial Services Research, Springer;Western Finance Association, vol. 56(3), pages 341-368, December.
    9. Beck, T.H.L. & Behr, P. & Madestam, A., 2011. "Sex and Credit : Is There a Gender Bias in Microfinance?," Discussion Paper 2011-101, Tilburg University, Center for Economic Research.
    10. Gabriel, Stuart A. & Rosenthal, Stuart S., 2005. "Homeownership in the 1980s and 1990s: aggregate trends and racial gaps," Journal of Urban Economics, Elsevier, vol. 57(1), pages 101-127, January.
    11. Vitaly Meursault & Daniel Moulton & Larry Santucci & Nathan Schor, 2022. "One Threshold Doesn’t Fit All: Tailoring Machine Learning Predictions of Consumer Default for Lower-Income Areas," Working Papers 22-39, Federal Reserve Bank of Philadelphia.
    12. David Bjerk, 2007. "Racial Profiling, Statistical Discrimination, and the Effect of a Colorblind Policy on the Crime Rate," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 9(3), pages 521-545, June.
    13. Tackie, Nii O. & Aboagye, Judith N. & Johnson, Gwendolyn J. & Braxton, Millicent & Hunt-Haralson, LaTanya & Wall, Gertrude D., 2013. "The Impact Of Selected Socioeconomic Factors On Asset Building In Rural Communities," Professional Agricultural Workers Journal (PAWJ), Professional Agricultural Workers Conference, vol. 1(01), pages 1-15.
    14. Patrick Bayer & Fernando Ferreira & Stephen L. Ross, 2018. "What Drives Racial and Ethnic Differences in High-Cost Mortgages? The Role of High-Risk Lenders," The Review of Financial Studies, Society for Financial Studies, vol. 31(1), pages 175-205.
    15. Song Han, 2011. "Creditor Learning and Discrimination in Lending," Journal of Financial Services Research, Springer;Western Finance Association, vol. 40(1), pages 1-27, October.
    16. Lei Ding & Leonard Nakamura, 2016. "The Impact of the Home Valuation Code of Conduct on Appraisal and Mortgage Outcomes," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 44(3), pages 658-690, July.
    17. Stephen L. Ross, 2005. "The Continuing Practice and Impact of Discrimination," Working papers 2005-19, University of Connecticut, Department of Economics, revised Jul 2006.
    18. Dharmapala Dhammika & Ross Stephen L, 2004. "Racial Bias in Motor Vehicle Searches: Additional Theory and Evidence," The B.E. Journal of Economic Analysis & Policy, De Gruyter, vol. 3(1), pages 1-21, September.
    19. Robert B. Avery & Kenneth P. Brevoort & Glenn Canner, 2012. "Does Credit Scoring Produce a Disparate Impact?," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 40, pages 65-114, December.
    20. Berger, Allen N. & Buch, Claudia M. & DeLong, Gayle & DeYoung, Robert, 2004. "Exporting financial institutions management via foreign direct investment mergers and acquisitions," Journal of International Money and Finance, Elsevier, vol. 23(3), pages 333-366, April.
    21. AKM Rezaul Hossain, 2004. "The Past, Present and Future of Community Reinvestment Act (CRA): A Historical Perspective," Working papers 2004-30, University of Connecticut, Department of Economics.

    More about this item

    Keywords

    ECOA; Regulation B; Discrimination; Fair lending; Consumer lending; disparate treatment; Disparate impact; Credit card; Scoring model; Model governance;
    All these keywords.

    JEL classification:

    • G21 - Financial Economics - - Financial Institutions and Services - - - Banks; Other Depository Institutions; Micro Finance Institutions; Mortgages
    • G28 - Financial Economics - - Financial Institutions and Services - - - Government Policy and Regulation
    • K23 - Law and Economics - - Regulation and Business Law - - - Regulated Industries and Administrative Law

    NEP fields

    This paper has been announced in the following NEP Reports:

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:fip:fedpdp:14-02. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Beth Paul (email available below). General contact details of provider: https://edirc.repec.org/data/frbphus.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.