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Credit Card Activities Manual
Credit Card Activities Manual
Types of Scoring
VIII. Scoring and Modeling
Scoring and modeling, whether internally or externally developed, are used extensively in credit card lending. Scoring models summarize available, relevant information about consumers and reduce the information into a set of ordered categories (scores) that foretell an outcome. A consumer's score is a numerical snapshot of his or her estimated risk profile at that point in time. Scoring models can offer a fast, cost-efficient, and objective way to make sound lending decisions based on bank and/or industry experience. But, as with any modeling approach, scores are simplifications of complex real-world phenomena and, at best, only approximate risk.
Scoring models are used for many purposes, including, but not limited to:
Credit scoring models (also termed scorecards in the industry) are primarily used to inform management for decision making and to provide predictive information on the potential for delinquency or default that may be used in the loan approval process and risk pricing. Further, credit risk models often use segment definitions created around credit scores because scores provide information that can be vital in deploying the most effective risk management strategies and in determining credit card loss allowances. Erroneous, misused, misunderstood, or poorly developed and managed scoring models may lead to lost revenues through poor customer selection (credit risk) or collections management. Therefore, an examiner's assessment of credit risk and credit risk management usually requires a thorough evaluation of the use and reliability of the models. The management component rating may also be influenced if governance procedures, especially over critical models, are weak. Regulatory reviews usually focus on the core components of the bank's governance practices by evaluating model oversight, examining model controls, and reviewing model validation. They also consider findings of the bank's audit program relative to these areas. For purposes of this chapter, the main focus will be scoring and scoring models. A brief discussion on validating automated valuation models (AVM) is included in the Validation section of this chapter, and loss models are discussed in the Allowances for Loan Losses chapter. Valuation modeling for residual interests is addressed in the Risk Management Credit Card Securitization Manual.
Scoring models are developed by analyzing statistics and picking out cardholders' characteristics thought to be associated with creditworthiness. There are many different ways to compress the data into scores, and there are several different outcomes that can be modeled. As such, scoring models have a wide range of sophistication, from very simple models with only a few data inputs that predict a single outcome to very complex models that have several data inputs and that predict several outcomes. Each bank may use one or more generic, semi-custom, or custom models, any of which may be developed by a scoring company or by internal staff. They may also use different scoring models for different types of credit. Each bank weighs scores differently in lending processes, selects when and where to inject the scores into the processes, and sets cut-off scores consistent with the bank's risk appetite. Use of scoring models provides for streamlining but does not permit banks to improperly reduce documentation required for loans or to skip basic lending tenants such as collateral appraisals or valuations.
Practices regarding scoring and modeling not only pose consumer lending compliance risks but also pose safety and soundness risks. A prominent risk is the potential for model output (in this case scores) to incorrectly inform management in the decision-making process. If problematic scoring or score modeling cause management to make inappropriate lending decisions, the bank could fall prey to increased credit risk, weakened profitability, liquidity strains, and so forth. For example, a model could wrongly suggest that applicants with a score of XYZ meet the bank's risk criteria and the bank would then make loans to such applicants. If the model is wrong and scores of XYZ are of much higher risk than estimated, the bank could be left holding a sizable portfolio of accounts that carry much higher credit risk than anticipated. If delinquencies and losses are higher than modeling suggests, the bank's earnings, liquidity, and capital protection could be adversely impacted. Or, if such accounts are part of a securitization, performance of the securitization could be at risk and could put the bank's liquidity position at risk, for instance, if cash must be trapped or if the securitization goes into early amortization. A poorly performing securitization would also impact the fair value of the residual interests retained.
Well-run operations that use scoring models have clearly-defined strategies for use of the models. Since scoring models can have significant impacts on all ranges of a credit card account's life, from marketing to closure, charge-off, and recovery, scoring models are to be developed, implemented, tested, and maintained with extreme care. Examiners should expect management to carefully evaluate new models internally developed as well as models newly purchased from vendors. They should also determine whether management validates models periodically, including comparing actual performance to expected performance. Examiners should expect management to:
Most likely, scoring and modeling will increasingly guide risk management, capital allocation, credit risk, and profitability analysis. The increasing impetus on scoring and modeling to be embedded in management's lending decisions and risk management processes accentuates the importance of understanding scoring model concepts and underlying risks.
Types of Scoring
Credit Scoring Model Development
A scoring model evaluates an applicant's creditworthiness by bundling key attributes of the applicant and aspects of the transaction into a score and determines, alone or in conjunction with an evaluation of additional information, whether an applicant is deemed creditworthy. In brief, to develop a model, the modeler selects a sample of consumer accounts (either internally or externally) and analyzes it statistically to identify predictive variables (independent variables) that relate to creditworthiness. The model outcome (dependent variable) is the presumed effect of, or response to, a change in the independent variables.
The sample selected to build the model is one of the most important aspects of the developmental effort. A large enough sample is needed to make the model statistically valid. The sample must also be characteristic of the population to which the scorecard will be applied. For example, as stated in the March 1, 1999 Interagency Guidance on Subprime Lending (Subprime Lending Guidance), if the bank elects to use credit scoring (including application scoring) for approvals or pricing in a subprime lending program, the scoring model should be based on a development population that captures the behavioral and other characteristics of the subprime population targeted. Because of the significant variance in characteristics between subprime and prime populations, banks offering subprime products should not rely on models developed solely for products offered to prime borrowers.
Both a large number of good and bad accounts are necessary to maximize the model's effectiveness. There are no hard and fast rules, but the sample selected normally includes at least 1,000 good, 1,000 bad, and about 750 rejected applicants. Often, the sample contains a much higher volume of accounts. The definition of good and bad accounts (the dependent variable) differs among banks, especially between prime and subprime issuers. Furthermore, definitions of bad for scoring purposes are not necessary the same as definitions of bad used by banks for charge-off or nonaccrual consideration. For prime portfolios, good accounts tend to be defined as accounts with sufficient credit history and little or no delinquency. Bad accounts for prime portfolios are normally distinguished by adverse public records, delinquency of 90 days or more, accounts with a history of delinquency, and accounts charged-off. Rejected applicants are applicants that management refused to accept because of their risk parameters. Certain inferences are made to break down the rejected applicants into good and bad accounts. This procedure, known as reject inferencing, makes certain assumptions on how rejected applicants would have performed had they been accepted and attempts to mitigate any accept-only bias of the sample. The process is used as it would be cost-prohibitive and potentially detrimental to make loans to consumers who would otherwise be rejected just for the sake of improving models.
After a representative sample has been assembled, the accounts are analyzed to determine the characteristics and attributes common to each group. The characteristics may be based on data sources such as the consumer's credit report, the consumer's application, and the bank's records. Characteristics are the questions asked on the application or performance categories of the credit bureau report. Attributes are the answers given to questions on the application or entries on the credit bureau report. For example, if education is a characteristic, college degree or high school diploma illustrate possible attributes.
The characteristics, which may number in the hundreds, are refined into a much smaller group of predictive variables, which are those items thought to best indicate whether a new applicant will eventually fall into the good or bad performance category. Ideally, the predictive variables also maintain a stable relationship with the performance measurement over-time. Commonly used predictive variables include, but are not limited to, prior credit performance, current level of indebtedness, amount of time credit has been in use, pursuit of new credit, time at present address, time with current employer, type of residence, and occupation. Examiners should expect that management has excluded factors lacking predictive value or that by law cannot be used in the credit decision-making process (such as race).
Once the predictive variables have been selected, points are assigned to the attributes of those variables. Each attribute is awarded points, and determining the number of points to award each attribute may be the most difficult element of the process. There are several methods for calculating and assigning points, all using a form of multivariate statistics. A scoring table is constructed, for which characteristics are on one axis and attributes are on the other axis. Points are awarded to each cell of the matrix. The consumer's characteristics and attributes are compared with the scoring table, or scorecard, and are awarded points according to where they fall within the table. The points are tallied to arrive at the overall score. Whether a high score means low or high risk depends on the model's construction.
Once designed and prior to implementation, the model is evaluated for integrity, reliability, and accuracy by a party independent of its design. This process is referred to as validation. A sample from the development sample may be held-out and scored with the new model. Performance is then monitored, and a model that demonstrates separation and rank ordering on the hold-out sample is considered valid. Validations for independent samples are also usually conducted prior to release of the model and post-implementation.
Validation has long been fundamental to a successful score modeling process, and evaluating a bank's model validation process has long been a central component of the examination. The Subprime Lending Guidance requires management to review and update models for subprime lending to ensure that assumptions remain valid. Validation is also an integral part of the proposed rulemaking for the revised Basel capital accord.
Basel Considerations Regarding Credit Scoring
A bank must be able to demonstrate a strong relationship between the IRB risk drivers (such as scores) and comparable measures used for credit risk management. Thus, even if a bank uses custom scores for underwriting or account management, generic bureau scores could possibly be used for IRB segmentation purposes if the bank can demonstrate a strong correlation between these measures. A bank using credit scores as segmentation criterion would have to validate the choice of the score (bureau, custom, and so forth) as well as demonstrate that the scoring system has adequate controls.
Examiners will expect that all aspects of the risk segmentation system, including credit scoring, are subject to thorough, independent, and well-documented validation. Validation for the risk segmentation system is ultimately tied to validation of the bank's quantification of IRB risk parameters. Examiners will also expect that the IRB validation process include:
Examiners do not validate models; rather, validation is the responsibility of bank management. Examiners do, however, test the effectiveness of the bank's validation function by selectively reviewing aspects of the bank's validation work. Examiners could also identify concerns with a model's performance as a by-product of the credit risk review or other examination procedures.
Examiners should evaluate the bank's validation framework, including written validation policies, to determine if it is proper. Key elements of a sound validation policy generally include:
A clear understanding of the scoring model's intended use is critical to properly assessing a model's performance. But, regardless of the intended use, the three key components of a validation process, as mentioned in the prior section, apply: evaluation of the conceptual soundness of the model; ongoing monitoring that includes verification and benchmarking; and outcomes analysis.
Evaluating conceptual soundness involves assessing the quality of the model's construction and design. Examiners should determine whether management reviews documentation and empirical evidence supporting the methods used and the variables selected in the model's design. Modelers adopt methods, decide on characteristics, and make adjustments. Each of these actions requires judgment, and validation should ensure that judgments are well-informed. Examiners should expect management to review developmental evidence for new models and when a material change is made to an existing model.
The purpose of the second component of validation, ongoing monitoring, is to confirm that the model was implemented appropriately and continues to perform as intended. Process verification and benchmarking are its key elements. Process verification includes making sure that data are accurate and complete; that models are being used, monitored, and updated as designed; and that appropriate action is taken if deficiencies exist. Benchmarking uses alternative data sources or risk assessment approaches to draw inferences about the correctness of model outputs before outcomes are actually known. The time needed to generate a sufficient number of representative accounts (good and bad) to evaluate the effectiveness of the model post-implementation will vary depending on the product-type or customer group. Consequently, benchmarking becomes an important tool in the validation process because it provides an earlier-read of model performance than is available from back-testing.
The third component of validation, outcomes analysis, compares the bank's forecasts of model outputs with actual outcomes. It should include back-testing, which is the comparison of the outcomes forecasted by the models with actual outcomes during a sample period not used in model development (out-of-sample testing).
Benchmarking and back-testing differ in that when differences are observed between the model output estimates and the benchmark, it does not necessarily indicate that the model is in error. Rather, the benchmark is an alternative prediction, and the difference may be due to different data or methods. When reviewing the bank's benchmarking exercises, examiners should find out whether management investigates the source of the differences and determines whether the extent of the differences is appropriate.
Examiners can compare the delinquency rate at each score interval as a simple test of overall performance of the scoring system. If the system is performing adequately, a correlation between the scores and delinquency rates (that is, delinquency rates increase as projected risk (as reflected in the scores) increases) should be evident. Examiners may also want to review the results of various tests that management may be using. For example, divergence statistics and the population stability index are sometimes used. Divergence statistics measure the distance between the average score of satisfactory accounts and average score of unsatisfactory accounts. The greater the distance, the more effective the scoring system is at segregating good and bad accounts. If the difference is small, a new or redeveloped scoring system may be warranted. The population stability index compares divergence with the original development sample and helps identify and measure erosion in the model's predictive power. Other advanced statistical tools include Chi square, Kolomogorov-Smirnov (K-S) tests, and Gini coefficients. While examiners generally do not need to know the specifics of all of these types of tests, they should be aware that these tests are common in the industry and should expect management to be able to explain the validation tools used. Management's development of effective processes and exercise of sound judgment are just as important as the measurement technique used.
Incorporation of combinations of model expertise and skill levels in the validation process is not uncommon. For example, internal staff could be used to verify the integrity of data inputs while a third party could be used to validate model theory and code. Examiners should determine what management's procedures are for ensuring that vendors' validation procedures are appropriate and meet the bank's standards. Management is ultimately responsible for ensuring the validation processes used, whether internal or external, are appropriate and adequate.
While scoring models developed in-house are becoming more prevalent, banks continue to purchase a number of models from vendors and the bureaus. Vendors are sometimes unwilling to share key formulas, assumptions, and/or program coding. In these cases, the vendor typically supplies the bank with validation reports performed by independent parties. The independent party's work can only be relied on if the information provided is sufficient to determine the adequacy of the scope, the proper conveyance of findings to the vendor, and the adequacy of the vendor's response thereto. Examiners assessing risks of modeling activities should pay particular attention to situations in which management has exclusively relied on a vendor's general acceptance by others in the industry as sufficient evidence of reliability and has not conducted its own comprehensive review of the vendor and its practices.
Examiners should evaluate management's processes for re-tooling or re-developing models that exhibit eroding performance. If evidence reliably shows that the behavior shift is small and likely to be of short duration, a policy shift or change to the model may not be warranted. But, if evidence suggests that the behavior shift is material and is likely to be long-term, there are several approaches management may consider to limit losses, depending on the ability to identify the most likely reason(s) for the performance shift. It can adjust its underwriting policy to narrow the market to a group believed to perform better than the population in general. This usually involves making changes to the bank's business strategy and, thus, is rather limited as a short-term risk management tool. Banks may also develop or purchase scoring models based on more recent information about the current population. In this case, the bank must weigh the costs of developing or purchasing a model against that of carrying an increased number of bad accounts booked by the existing model. One of the most common, and often the easiest, adjustments is to manage the cut-off score to maintain a targeted loss rate consistent with profit objectives.
Selecting a cut-off score involves determining the optimum balance between approval and loss rates. Management evaluates how much additional revenue will be added if the approval rate is increased and what the cost associated with the incremental increase in the bad rate will be. They also often give consideration to marketing expenses and customer service expenses. How management chooses to balance the competing goals determines the cut-off score. Odds charts are often involved in setting cut-off scores and are discussed in the next section.
As time passes, cut-off scores and models become less predictive because of economic changes, demographic shifts, and entry into new markets. Examiners should assess management's practices for reviewing cut-off scores and models, including resulting acceptance and loss rates. By monitoring the rates, management can appropriately adjust the cut-off score to change either acceptance rates or loss rates, depending on the strategic goals. For example, management could grow the portfolio by lowering the cut-off score (when lower scores equate to higher risk), taking on an elevated degree of credit risk and accepting increased loss rates. These dynamics of the scoring environment highlight the need for thorough tracking and calibration procedures.
Validation Charts and Calibration
In general, validation charts (also commonly known as odds charts) reflect the estimate of the percentage of borrowers in a defined population who will evidence a certain trait or outcome, such as delinquency, loss, or bankruptcy. Examiners normally expect management to develop its own odds chart(s) when it has sufficient historical data. When properly developed, customized odds charts are more predictive than odds charts that are available from the bureaus. Validation charts available from the bureaus display the odds of poor performance (such as delinquency, loss, or bankruptcy) observed at a given bureau score. Each set of charts available from the bureaus is specific to a model, an industry, and an application (where application refers to how the scores will be used). For example, the bureaus have validation charts available for the bankcard industry and for subprime lending. The bureaus' validation charts can be helpful as a starting point for management in setting risk strategies but do not precisely predict the actual odds that each bank will experience. Rather, a bank's particular market will have different characteristics and, thus, different odds. The risk ranking based on bureau score will generally hold, but the actual odds of going bad that each score represents will vary between banks and portfolios. Thus, management must provide for sufficient calibration processes. For example, if the bureau odds chart indicates that 1 out of every 20 consumers with a credit score of XYZ will be a bad account and the bank is realizing 5 out of every 20 consumers with a credit score of XYZ is a bad account, calibration most likely is needed.
Calibration most often adjusts or refines an odds chart when significant variation exists from the general forecast. But, there are other instances for which the scores and scaling could be adjusted, or calibrated. For example, calibration might be used to make all scores positive. For example, if a model's scores are (52), (6), and 15, an entity could add 52 points, so the scores would be 0, 46, and 67. Also, calibration might be used to compress the scale (for example, if every 31 points doubles the odds of bad, a bank could calibrate the scale such that the bad odds are doubled every 20 points). Calibrations might also be done to make users feel comfortable (for example, if an existing cut off score is XYZ based on an internal model that predicts that one percent of accounts with a score of XYZ will be bad, then calibration could be used to ensure that accounts that are scored XYZ would continue to tie to the likelihood that one percent will be bad. In this way, the bank would not have to change the cut-off score to keep getting the same caliber of customers). Examiners should ascertain whether recent calibrations are well-documented and have been properly executed.
Credit Scoring Model Limitations
One limitation is that scoring model output is only as good as the input that is used. If data going into the scoring model is inaccurate (for instance, if information on the consumer's credit bureau report is erroneous), the model's output (score) will be erroneous. Depending on how the erroneous information is weighted in the scoring formula, the impact on the score could be substantial. Moreover, if management does not select and properly weight the best predictive variables, the model's output will likely be less effective than had the most predictive variables been used and properly weighted. Management must make sure that the variables used in the models are appropriate, predictive, and properly weighted to arrive at the best credit decision and that data inputs are complete and accurate.
The effectiveness of the model output (scores) can also be constrained by factors such as changing economic conditions and business environments. Examiners should identify whether management monitors warning signs of market deterioration, such as increases in personal bankruptcies, which may affect the accuracy of model assumptions. Robust models are typically more resilient to these types of changes.
Models, even if good at risk-ranking an overall market segment, can be limited if they do not reflect the bank's population. A model is typically developed for a certain target population and may be difficult to adapt to other populations. In most cases, a credit scoring model should only be used for the product, range of loan size, and market that it was developed for. When a bank tries to adapt the model to a different population, performance of that population may likely deviate from expectation. When a bank implements or adapts a model to a new market or population for which it was not designed, examiners should determine whether management performs an analysis similar in scope to the one used to validate the model at implementation.
Credit scoring is good at predicting the probability of default but generally not at predicting the magnitude of losses. (Normally, other models, such as loss models, focus on predicting the level (magnitude) of risk.) Generic credit scoring models in particular most likely rank order the risk appropriately but generally do not accurately predict the level of the risk. Thus, banks that use generic models should not assume that their loss rates will be the same as those reflected in industry odds charts. How accounts ultimately perform depends on a number of factors, including account management techniques used, the size of line granted, and so forth.
Scorecards could be considered, by their very nature, to be antiquated when they are put into production. They are based on lengthy historic data and take time to develop. Moreover, models are calibrated using historical data, so if relevant un-modeled conditions change, the model can have trouble forecasting out of sample.
Along similar lines, during times of strong economic growth, models may be ill-prepared to predict borrower performance in recessionary conditions, particularly if the historic period observed did not include recessionary conditions. There are several behaviors that could impact the model's effectiveness in recessionary times. One is that consumers might prioritize their payments to pay off secured debt rather than unsecured debt. In hard times, this could leave a bank that is holding the consumer's unsecured credit card debt as one of the last to get paid, if paid at all.
The effectiveness of scoring models can also be limited by human involvement. For example, when models are augmented by managerial judgment (for instance, in the case of overrides), results from the model and subsequent validation processes can become seriously compromised. In addition, unsupported overconfidence in the models could lead some banks to move up or down market to make larger or more risky loans, respectively. Without proper model validation, such movements could result in the bank taking on more credit risk than it can control.
Automated Valuation Models
Summary of Examination Goals – Scoring and Modeling
Examiners normally select models for review in connection with the examination when model use is vital or increasing. Focus may also be placed on models new or acquired since the prior examination. Quantitative or information technology (IT) specialists are sometimes needed for some complex models, but examiners normally can perform most model reviews.
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