Federal Reserve Bank Paper Analyzes Credit Card Fair Lending Issues


The Federal Reserve Bank of Philadelphia recently published a discussion paper on credit card fair lending risks. The paper reviews qualitative fair lending risk assessment methods and potential quantitative analysis that may be performed to assess fair lending risk exposure in each of the following areas: (i) marketing; (ii) underwriting; (iii) credit line assignment; (iv) pricing; (v) servicing and collection; (vi) secured cards; and (vii) affinity partners. The authors note that the methods discussed are also applicable to other consumer credit products that utilize credit scoring models. The paper states that although statistical testing can be an important component of fair lending compliance management for credit card lending, “statistical analysis approaches in this area—and particularly disparate impact testing approaches—are not well established, and there are no formal regulatory guidelines for conducting such analysis.” With regard to quantitative risk assessments, the authors discuss the utility of proxy testing and explain the likelihood of false positives and false negatives as well as unassigned consumers. The authors state that “these limitations suggest that results derived from a proxy-based analysis should be treated with an appropriate degree of caution.”

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