FICO Fool’s Gold

By Edward Jamison, Esq.

Oh man, those engineers at FICO must be having themselves one rip roaring laugh right about now. They pulled the fast one of the year on November 29th when they supposedly disclosed FICO score point values to Liz Weston from MSN. Ms. Weston, who is one of smarter consumer credit journalists, took the bait hook line and sinker and published this article soon thereafter.


http://articles.moneycentral.msn.com/Banking/YourCreditRating/weston-5-ways-to-kill-your-credit-scores.aspx?page=1

Essentially what happened was FICO simulated the impact of a variety of credit behaviors on FICO scores of both 680 and 780. The score “damage” was summarized into the below chart. Weston’s article was titled “5 Ways to Kill Your Credit Score”, which to me means that the article was simply meant to illustrate that doing one of the following actions can hurt you…and that your should avoid them at all costs. The problem is the info is already being misinterpreted and abused.



Here’s where the fun really begins, what FICO did not disclose and what Ms. Weston might now know is that four of the five actions listed above will cause your credit file to be scored in a new scorecard. What this means…well, what this means is complicated. FICO scores measure your credit file’s potential risk by scoring it using a unique algorithm specifically designed for your file type, called a scorecard. That means if you have a bankruptcy then you’re scored in a bankruptcy scorecard. If your credit file only has one or two accounts then it’s scored in what’s referred to as a thin file scorecard, and so forth and so on.

Point being, all of our credit files are not scored the same way and not using the same FICO formula. Four of the five actions above are negative. And, when a clean file suddenly is hit with something negative it will go from essentially a “clean credit file” scorecard to a “derogatory file” scorecard. The result is a completely different measurement for EVERYTHING on your file. So adding a foreclosure or a settlement or a 30-day late payment or a bankruptcy to your credit file doesn’t “cost” it the points you see above. It causes everything on your file to have a new value so the score change can’t be attributed just to the negative item. The score change has to be attributed to the change in scorecards.

Next, not all 680s and 780s are created equally. Meaning, your 680 might have been caused by a completely different set of credit circumstances as my 680. Same goes for the 780. Case in point, John Ulzheimer, a credit expert who has forgotten more about credit scores than most people know, ran similar simulations on his own personal credit reports using the myFICO website tools. It just so happens that Mr. Ulzheimer’s FICO score for the simulations was also 780. This is perfect because I’m about to illustrate just how different FICO’s hypothetical 780 is from a real credit report with the same score of 780.

The score damage on the original 780 in FICO’s simulation of filing a bankruptcy was a negative hit of between 220 and 240 points. On Ulzheimer’s real credit file with a real FICO score of 780 the hit was between 195 and 255 points. Missing a payment on an account that was current, also known as the dreaded “30-day” late, caused FICO’s FICO score to drop between 90 and 110 points. On Ulzheimer’s 780 FICO score the same 30-day late payment caused his score to drop 40 to 75 points.

As you can see the point differences for the exact same action on the exact same FICO score (780) was anything but exactly the same. Ulzheimer even trumped Weston by re-interviewing FICO’s Public Affairs Director, Craig Watts. He was able to confirm from Watts that the examples in the FICO chart were “hypothetical” and “could vary significantly” from consumer to consumer. You can Ulzheimer’s his full article here.

http://www.credit.com/news/experts/2009-11-29/real-fico-score-damage-point-amounts-clarified.html

As interesting as the MSN article is and as hard as it is for me to say this, I believe writing this article was quasi-irresponsible. Not so much because of the content was wrong, because it wasn’t. As I said, Weston is right at the top of list of credit journalists who cover the industry. The problem as I see it is you could have disclaimed the charts and results with “this is just a hypothetical example” a dozen times and people are still going to focus on the point differences and believe them and think that they now know how many points things are worth, which will be an incorrect assumption in almost every case. This will lead to more consumer confusion on a topic that’s already confusing as hell.

My point is already being proven. Within two days of the publishing of Ms. Weston’s article two separate writers picked up and misrepresented the data. Instead of interpreting the information as a general approximation of what COULD happen to your score if you made various mistakes, the data is purposely being positioned as a new breakthrough into FICO’s black box. The titles of those two article are “FICO Reveals How Common Credit Mistakes Affect Scores” and “FICO Reveals the Impact of Their Credit Scores on Consumers”, the second title making absolutely no sense and neither being truly accurate.

Look, I recognize that these are simple “search engine content” pirates and they’re just jacking and using someone else’s content to benefit their own affiliate programs. Point being, they’re never going to get it right and they don’t care because they just want the keywords for their websites to attract search engine traffic for certain key credit terms. The problem is this stuff gets picked up and spread all over the world wide web and inevitably finds it’s way into credit related chat rooms, blogs, forums and even legitimate media and thus takes on an air of legitimacy.

It would have been great if Weston had thought about this before she published her story.

Busy Couple of Weeks for FICO

By Edward Jamison, Esq.

Over the past few weeks the news surrounding FICO has been coming fast and furious. The Federal lawsuit filed by FICO against Experian, TransUnion and VantageScore Solutions was partially dismissed but left several counts that will now proceed to trial later this year. Additionally, the credit scoring company announced that FICO 08, their newest credit score, would be available at all three of the national credit reporting agencies starting in August 2009. This means that Experian has finally agreed to install and make available the credit score several months after TransUnion and Equifax had done so.

Regarding the FICO lawsuit:

On July 24th the Honorable Ann Montgomery ruled on a request to dismiss a lawsuit filed in Federal court by FICO (more formally referred to as Fair Isaac) against VantageScore Solutions, TransUnion and Experian. Judge Montgomery dismissed some of the counts and left others in place therefore leading the parties toward trial later this year.

The lawsuit, among other things, claims breach of contract and trademark infringement. The Order sheds a public light on a number of very interesting things that were not previously known, including email communication between executives of the credit reporting agencies. Some of the more interesting nuggets of gold, with emphasis added, from the Order are;

1. The proposed joint venture between the three credit reporting agencies was referred to as either “Operation Triad” or “Project Trident” and eventually lead to the creation of VantageScore Solutions and subsequently the VantageScore scoring model. VantageScore is a credit risk score but uses a different credit scoring range (501-990) as the FICO score (300-850). VantageScore also converts their numeric score to an alpha display using the academic A-F range, which seems comical considering VantageScore is not a lender and doesn’t underwrite loans. The assertion that they know how to grade a consumer’s as being an “A” versus a “B” is a responsibility solely for a lender, not a credit score developer.

It’s also important to note that while Equifax was originally named as a defendant they reached a settlement with FICO on or around June of 2008 and is no longer a party to the lawsuit. The fact that the bureaus named the project after a military weapon sheds light on their mindset at the time.

2. In February of 2005 Experian enlisted the assistance of a consulting firm, which at the time was called Mercer Oliver Wyman. Today this firm is referred to as Oliver Wyman and is a division of Marsh & McLennan. According to the Order this firm created a document for Experian that suggested “through the joint venture (VantageScore), the credit bureaus could build their own scoring model and transfer Fair Isaac’s revenue ENTIRELY to themselves.” The difficulty of replacing entrenched credit scoring systems seems to have been grossly underestimated. I wonder if Experian asked for a refund considering the consultant’s misread of the market.

3. The original VantageScore scoring model “relied on the algorithms in Experian’s own in-house, tri-bureau scoring model, which Experian made available to the team.” The bureaus announced VantageScore to the market in March of 2006. FICO files their lawsuit on October 11th of the same year. This seems to contradict VantageScore’s marketing literature, “The nation’s three consumer credit reporting companies – Equifax, Experian and TransUnion – worked together to develop a tri-bureau generic credit scoring system.”

4. Each of the credit bureaus pays $300,000 annually to secure royalty-free and global licenses for the use of the VantageScore model.

5. Prior to the introduction of VantageScore TransUnion’s royalty payments to FICO was $40,000,000. After the introduction of VantageScore the royalty payments were $44,000,000. No time frames were given so these figures could represent an annual amount or cover some other period of time but assuming the comparison is apples to apples it seems to suggest that FICO has not lost any market share to VantageScore. This means consumers applying for credit will likely have their loans underwritten by a lender using a FICO score.

6. With respect to the confusion in the consumer market of other scores with similar score ranges to that of the FICO score (300-850), “The evidence identified by Fair Isaac lends support to the inference that Defendants intentionally copied Fair Isaac’s 300-850 mark and that consumers confused Defendants credit scores with FICO credit scores as a result.” In English what this means is the credit bureaus intentionally chose score ranges that were similar to FICO’s 300-850 in order to confuse consumers who were shopping online for the credit scores. This has been a consistent criticism of both Experian and TransUnion for years. Equifax does not sell any credit score to consumers other than the legitimate FICO score so they’re not a target of the criticism. The simple question “why did you choose a score range similar to FICO’s” is one that they finally had to answer in court, although smart consumers already knew what they were up to.

7. The published FICO score ranges of 300 to 850 seems to not be the actual FICO score range. From the Order “Fair Isaac argues in response that the term 300-850 is not the "actual scoring range for any of [Fair Isaac's] classic FICO credit scores. The actual scoring range for the first FICO score developed for Trans Union is 397-871, for Experian is 368-839, and for Equifax is 407-829. Every version of these scores has a different range-none of which is 300-850."

Regarding FICO 08:

According to a press release issued by FICO on July 22nd “FICO 08 Credit Score Available at All Three National Credit Reporting Agencies” by the end of July. Experian had refused to adopt the model because of their ongoing litigation with Fair Isaac. And already “five of the seven largest U.S. banks and four of the five largest credit card issuers” have begun testing or using the new score.

What this means is consumers who have a large amount of credit card debt or are highly utilized will likely see lower FICO 08 scores. This is because of the added importance of credit card debt built within the model. It also means adding yourself onto the credit card of another person in an attempt to “piggyback” your way to a better score will be impossible sooner rather than later.

A benefit to consumers is FICO 08’s logic, which ignores very low dollar collections, commonly referred to as nuisance collections. Consumers who are seeing their scores lowered by collections with an original amount less than $100 will see immediate benefit with FICO 08. This is an incentive for lenders to more quickly adopt the new score because savvy consumers who have these small collections will know that a lender who uses FICO 08 will see them in a much better light. Nothing will incent a lender to adopt the newer model faster than prospects going to competing banks just to ensure a better credit score.

This is the 20 year anniversary of the introduction of the FICO score at a credit bureau. Consumers who conduct banking or insurance business at pretty much any bank, mortgage lender, or insurance company are subject to FICO’s evaluation.

Credit Card Issuers Behaving Badly

by Edward Jamison, Esq.

Over the past 12-18 months most of the large credit card issuers have been changing the terms of some of their customer’s accounts. The reason they’ve been doing so is because of a general lack of comfort for credit risk as well as the slumping economy. Changing the terms is usually allowed under almost any circumstance, depending on the cardholder agreement.

Some of the more common actions being taken by credit card issuers, and the reasons why, are as follows;

Credit Limit Reductions – This is being done on a very large scale. In fact, Fair Isaac published the results of a study that measured the breadth of credit limit reductions during a 7-month period in 2008. Their findings show that 16% of cardholders saw their credit limits reduced in 2008, which translates to roughly 32 million consumers. Out of the 32 million, 22 million had a median FICO score of 770. This means that their credit limits were reduced for a reason other than poor credit or elevated credit risk. For these people it was because of inactivity, under-usage, or general lack of profitability. The remaining 11 million did have some sort of credit problem such as late payments, collections or adverse public records hitting their credit files so the reduction in credit limits wasn’t a surprise. What is important to remember is this study took place over a 7-month period from April through October 2008. Credit card issuers have been lowering credit limits since October 2008 and were doing so well before April 2008. What this means is the FICO numbers, while very accurate, are likely to underplay the true amount of consumers who have seen their credit limits reduced.

Increased Interest Rates – There are no numbers to quantify the breadth of rate increases but we know it’s significant. The excuse being given by some banking industry leaders is that a rate increase is meant to be both punitive and motivational. It’s punitive in order to punish cardholders who have done something wrong, like miss a payment due date. And it’s motivational because the logic is if your debt is more expensive then you’ll be more likely to pay it off faster. And while both are certainly true in some circumstances it’s hard to honestly argue that increasing an interest rate always leads to a consumer accelerating their payments. In fact, an alternative and much more damaging result is more likely which is to push an already struggling consumer over the edge into default. This doesn’t do the consumer or the creditor any good because of the damage it does to the consumer’s credit files and credit scores and it could motivate the consumer to seek the services of a debt settlement company or even a bankruptcy attorney. In either of the latter cases the lender gets much less, if any, of the money they are owed.

Increased Minimum Payment Requirements – The amount of money you are required to pay your credit card issuer each month is referred to as the “minimum payment required.” This amount is a percentage of the overall balance. Normally it’s 2% of the outstanding balance. But, in recent months some credit card issuers have increased that minimum requirement to 5% from 2%. This means if you were normally making a $350 minimum payment now you are required to make a $875 minimum payment. Don’t misinterpret this as them gouging you, like when they increase your interest rate. In this case they simply want back more of their money instead of less of their money. But, this also can lead to consumers defaulting on loans because they simply don’t have the capacity to make the larger monthly payment.

Reduction in Grace Period – The grace period is an often misunderstood component of a credit card account. The grace period is the amount of time between when the statement billing period has closed and the date when your payment is due. A simpler way to define the grace period is the period of time before interest begins to accrue on the balance. Some people incorrectly define the grace period as being the amount of time AFTER the due date a payment can be made before the credit card issuer starts to report your account to the credit bureaus as being past due. That’s incorrect. Grace period has nothing to do with credit reporting. The reason a grace period would be reduced is all about cash flow for the bank. If you never revolving a balance from one month to the next then you’re not going to earn the bank any interest income. As such, it would be reasonable for the bank to want their money back faster since it’s not earning for them. This allows them to lend it out to other people who are going to generate more income.

As of today every single one of these practices is perfectly legal, as long as the action doesn’t breach your contract with the creditor. However, many of them will be much more difficult to apply to your account as of July 2010, when a new set of credit card rules goes into effect. As of today the best way to avoid the negative ramifications of these actions is to only charge what you can afford to pay off at the end of the month. And, it would be in your best interest to pay off credit card debt as quickly as you can. This way things like interest rates, grace periods or minimum payments don’t matter to you.

New FICO Scores Abound, Three New Credit Scores Hit the Market this Month

by Edward Jamison, Esq.

Last month I wrote about the newest version of the FICO score to be installed and available via TransUnion; FICO 08. Since I wrote that article FICO has announced three more new scores to be released some time this month. These new scores and details about those score are;

1. The FICO Mortgage Score – This score is actually a variation of the FICO score currently available at Equifax, which is called BEACON. This new score, which comes at the request of players in the mortgage industry, is meant to give them a better understanding of credit risk posed by mortgage borrowers rather than just general credit risk across all different types of accounts. This new score is what’s referred to in the credit scoring industry as an “Industry Option” score. The Industry Option score uses the standard FICO score as a foundation and then adjusts that score up or down based on the consumer’s credit risk for a specific type of loan, in this case a mortgage loan. So, for example, if my FICO score at Equifax is 750 but I’ve managed my previous mortgage loans very responsibly it is likely that my mortgage score will be slightly higher. This is because I actually pose less risk to mortgage lenders because I’ve exhibited that I can manage mortgage debt based on previous experience, which is displayed on my Equifax credit report. This score will be available some time in April.

2. The FICO Auto Score – The industry option scores do not stop for just mortgage lenders. There is actually an entire suite of these scores available for other lenders as well. They are available for credit card issuers, auto lenders, personal finance lenders and installment lenders. TransUnion will be making the FICO Auto Industry Option score available immediately to lenders who loan money to consumers who are buying a car, new or used, or are refinancing an existing car loan. The new auto score is expected to easily outperform the previous auto score version at TransUnion. According to FICO, “auto lenders may be able to identify as many as 5 percent to 15 percent more potential delinquencies among consumers as they could with the previous FICO auto score.” This increased predictive power will help to accomplish two things sorely needed in the auto-lending environment. First, it will allow lenders to loan more money into a dying auto market. And second, it will allow healthy auto lenders to loan deeper into the credit score pool because of the increased ability to identify the future bad accounts before they even make it to their books.

3. The FICO Bankcard Score – In addition to the auto score available at TransUnion FICO has also made available it’s newest Industry Option score designed specifically for credit card issuers. This new score, called the Bankcard Industry Option, does the same things as the mortgage and auto versions, which is to give credit card issuers a better crystal ball to use when making decisions about whether or not to approved or deny credit card applications and whether or not to modify the terms of an existing credit card customer’s account. It’s my belief that of all of the industry specific scores, this is the most commonly used. According to FICO this newer score will also do a better job of identifying riskier credit card users than the previous version of the same score. According to FICO, “…testing found that the new scores could potentially increase issuers' delinquency prediction rates by 6 percent to 12 percent…” This is a significant improvement especially when you apply the average loss of a credit card account for a major credit card issuer who might have 30 million active credit cards in circulation.

One of the biggest hurdles to implementing one of these new scores is the work to accommodate a new, different scoring model. This is one of the reasons VantageScore, a product of the credit bureau’s joint venture VantageScore Solutions hasn’t done well. It’s a different score with a different score range and likely performs very differently than a FICO score.

In order to make the transition from previous versions of FICO to these newer scores as painless as possible FICO has done a good job of keeping the structure of the newer scores identical to that of the older versions. The score range is still 300 to 850. And the new scores maintain the same set of adverse action codes, also commonly referred to as score factor codes or reason codes. They have also maintained the same minimum scoring criteria, which means if a bank has traditionally seen a 2% “no score” rate, they should continue to see the same.

FICO releases a new generation of scoring models every few years for each of the three national credit reporting agencies; Equifax, Experian and TransUnion. And in most cases it doesn’t make the headlines when it happens. Given the current state of the economy and especially the credit environment any time a newer better score becomes available it seems to draw more attention. This probably won’t change any time soon.

FICO 08, The Ins and Outs

March 2, 2009
by Edward Jamison, Esq.

On January 29, 2009 TransUnion rolled out and made available the credit-scoring model called FICO 08. This is the newest version of the FICO® credit score, which is simply a redevelopment of their widely used industry standard classic score. The long awaited release of this model is good news for lenders, low risk borrowers, and those with low credit card balances. It’s bad news for piggybackers, companies that sell piggybacking services, consumes with a lot of credit card debt, and the flop of the century, so far, in the credit scoring world known as VantageScore.

FICO 08 will eventually be the industry standard credit score despite not being available yet from Equifax or Experian. We should see FICO 08 at Equifax before the fall and at Experian as soon as they start losing customers to TransUnion or Equifax. Experian has alluded to the fact that their ongoing litigation with Fair Isaac over VantageScore is causing some stress in their relationship and delaying the roll out of FICO 08. The problem is eventually lenders are going to get sick and tired of getting caught in the middle of the “Experian versus FICO” arm wrestling match and move their business elsewhere when they find out that Experian isn’t offering the new gold standard credit scoring model. When that happens you will be able to time the FICO 08 implementation at Experian with the second hand on your favorite watch.

So what is so different about FICO 08 and the other versions of the FICO score? There are three primary differences of note. They are:

1. Negligible Collection and Public Record Exclusion – The newest FICO score will ignore any collections or public records with an original amount less than $100. It’s important to note that for a collection to be bypassed by the score, thanks to the new logic, it has to be reported as a 3rd party collection agency account and not the collection department of a credit card company. If the collection shows up as “trade” then it will still count against your score even if it is less than $100. And, if the original amount was over $100 but it has been paid down to a current balance of less than $100 it will still count in your score. This is exceptional news for consumers who are haunted by low dollar collections caused by misdirected final utility bills and some insurance snafus.

2. Credit Card Utilization – Credit card utilization, the ratio of your current balances to your current credit limits on revolving credit card accounts, remains a highly important factor in your FICO credit score. However, in FICO 08 it takes on a whole new level of importance. Consumers who have balances that approach the reported credit limit will find their scores lower with FICO 08 than with previous versions of the scoring software. FICO’s research has apparently discovered that consumers who are highly utilized with their credit cards are more risky than they were in the past, hence the more punitive treatment.

3. No Piggybacking Allowed – This new version of FICO apparently has the ability to determine if an authorized user credit card account is an attempt to game the credit scoring system through piggybacking, which is the process whereby a consumer with poor credit would pay to be added to the credit card of someone with good credit as an authorized user. Fair Isaac will not disclose how they’re able to tell the difference between a legitimate authorized user account belonging to, say, a husband and wife versus one that has been made it to a credit report through other means, such as piggybacking. You will recall that FICO 08 was originally going to completely ignore all authorized user accounts. This new logic seems to split the difference between ignoring all authorized user relationships and doing nothing to discourage the use of piggybacking services.

So why does FICO 08 pose a problem for VantageScore? It’s actually quite simple. As long as FICO keeps improving what they refer to as their “classic” risk scores the less compelling it is for a lender to test, let alone switch, to a new score brand. Implementing a new version of FICO is much easier than implementing a whole new scoring model, like Vantage. In fact, a company called SubscriberWise has already implemented FICO 08 not more than two weeks after it became available.

The best advice for consumers who will begin to be scored with this new FICO score is for them to continue to do what they’re doing now. Continue to make all of your payments on time. Continue to work down your credit card balances as much as possible. Continue to apply for credit only when needed. If you can do all of these things then your FICO 08 score will be solid as a rock and, who knows, maybe your VantageScore will be solid too, although nobody will care.