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Fair lending analysis of credit cards

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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
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    File URL: https://www.philadelphiafed.org/consumer-finance/consumer-credit/fair-lending-analysis-of-credit-cards
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    File URL: https://www.philadelphiafed.org/-/media/frbp/assets/consumer-finance/discussion-papers/dp14-02.pdf
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    References listed on IDEAS

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    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.
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    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.

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    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

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