Asia Pacific Credit Coalition
Asia Pacific Credit Coalition
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The Asia-Pacific/ Australia Region

 

WHY ADDITION IS BETTER THAN SUBTRACTION: MEASURING IMPACTS FROM SYSTEM-WIDE DELETION AND SUPPRESSION OF DEROGATORY DATA IN CREDIT REPORTING

Published: October 2021

 This study examines a proposed approach to credit reporting in response to the COVID-19 pandemic. The relative narrow and targeted credit reporting response from the CARES Act appears to have been largely successful. However, there were calls by some members of Congress for an outright system-wide ban on credit reporting any adverse information, covering all consumers during (and for some period after) the COVID-19 crisis—a policy referred to as “suppression and deletion.” This research uses 5 million credit records from 2011 and 2017 to simulate the impact on credit scores and, more importantly, on consumer access to credit if the large-scale suppression and deletion policy were implemented. 


ARE EXPANDING PCRS CROWDING OUT PCBS?

Published: July 2021

 This report looks at the dynamics between private credit bureaus (PCBs) and public credit registries (PCRs) and finds growing global momentum to strengthen PCRs, sometimes to the detriment of PCBs. This trend has potentially harmful effects, as shown in 10 country case studies featured in the report. Credit information sharing systems are vital infrastructure and should be structured optimally. International best practices dictate that PCRs are complementary to PCBs, with PCRs playing a supervisory and risk monitoring role, while PCBs provide predictive credit and other data to lenders and other market actors to aid underwriting credit and eligibility determination for individuals and to assess loan portfolio risk and performance. 


COMMENTS TO CFPB ON ECOA & REG B

Published: December 2020

 The CFPB requested information to identify opportunities to prevent credit discrimination, promote fair, equitable, and nondiscriminatory access to credit, and address potential regulatory uncertainty under the Equal Credit Opportunity Act (ECOA) and Regulation B. In our response, we argue that non-financial lenders should be explicitly recognized as creditors. This would make the credit reporting system fairer, more forgiving, and more inclusive. We echo our call for a positive data reporting mandate made in earlier publications, particularly in the context of the COVID-19 healthcare and economic crisis. 


PHILIPPINE CREDIT INFORMATION STUDY

Published: November 2020

 This report analyzes the Philippine credit information sharing system and offers recommendations and possible amendments to the Credit Information Sharing Act (CISA) in order to improve and modernize the system. 


DATA FOR GOOD: COVID-19 SPECIAL EDITION

Published: October 2020

 Part I of the U.S. Chamber of Commerce’s Technology Engagement Centre white paper on Data for Good and the Need for a National Data Strategy features our report on Data for Good: COVID-19 Special Edition. It looks at the role of tech in responding to national healthcare and economic priorities during the pandemic. It is Part III in our U.S. Data Ecosystem series. 


CREDIT INFORMATION SHARING IN HONG KONG

Published: July 2020

This paper evaluates Hong Kong’s credit information sharing system dynamics in Hong Kong, including data gaps, the real estate bubble, and the new entrant. 

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ADDITION IS BETTER THAN SUBTRACTION: THE RISKS FROM DATA SUPPRESSION AND THE BENEFITS OF ADDING MORE POSITIVE DATA IN CREDIT REPORTING

Published: June 2020

This report looks at the potential impacts of negative credit data suppression or deletion measures during the COVID-19 pandemic period. While the proposed measures are well-intended, they harm more consumers than they help. Instead, the report recommends adding positive telecommunications payments to make the system fairer and more forgiving, giving consumers a chance to rebuild their credit history, since negative telecommunications data is already reported. This solution also protects the integrity of the national credit reporting system, vital for post-pandemic economic recovery. 


REPLY TO THE HTF REPORT ON BUILDING A PCR IN INDIA ALTERNATIVE DATA INITIATIVE: REPORT & STUDY SUMMARIES

Published: May 2020

This paper summarizes PERC’s research into alternative data. 


ENSURING THE SMALL BUSINESS PAYCHECK PROTECTION PROGRAM WORKS: LESSONS LEARNED FROM GULF COAST SMES POST-KATRINA

Published: April 2020

This discusses the need to ensure that the Small Business Paycheck Protection Program works by using lessons learned from Gulf Coast SME recovery post-Katrina.


PERC RESEARCH FINDINGS FOR COVID-19 ECONOMIC RECOVERY EFFORTS

Published: March 2020

PERC has conducted years of research on disaster recovery (following major hurricanes, such as Katrina, Rita, and Wilma in 2005), credit access for lower income Americans, and credit reporting in general. This white paper discusses those findings and draws lessons for the economic recovery phase of the current COVID-19 crisis.


POTENTIAL IMPACTS OF CREDIT REPORTING PUBLIC HOUSING RENTAL PAYMENT DATA

Published: February 2020

This first of its kind joint-study by PERC and U.S. Department of Housing & Urban Development (HUD) investigates the impacts of reporting public housing authority (PHA) tenant rental payment data to credit bureaus. Credit invisibility affects 1 out of every 5 Americans, but in the lowest-income census tracks, almost 1 out of every 2 Americans (45%) are credit invisible. This report found that including full-file (both positive and negative) payment data eradicated credit invisibility and increased twice as many scores as it decreased. The system would become more inclusive and fairer, as mortgages are currently reported but rent is not. Seattle, Cook County, & Louisville PHAs participated, and HUD is now planning discussions around pilot programs for reporting PHA rental payment data.


FTC/CFPB ACCURACY IN CONSUMER REPORTING COMMENTS

Published: February 2020

In these comments, we call for legislation requiring mobile network payment data to be reported to credit bureaus. We also comment on credit data accuracy practices, and call for more research to be done following our 2011 report on data accuracy & the FTC’s 2013 report. Changes and new phenomena in data accuracy such as NCAP and the CFPB’s complaint portal should be assessed using these reports as a benchmark. 

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DATA FOR GOOD: PROMOTING SAFETY, HEALTH, AND INCLUSION

Published: January 2020

This paper surveys the socially beneficial, ancillary uses of core data in the marketplace. This paper is Part III of our US Data Ecosystem series, and raises considerations for national data privacy legislation. 


ALTERNATIVE DATA IN THE US: PROGRESS, PROMISE, AND PARALYSIS

Published: August 2019

This paper highlights new solutions in the alternative data and proven payment data space that are benefiting the credit invisible but advocates that the first-best solution for consumers would be pervasive full-file credit reporting of utility, telecom, and rental payment data directly to the main consumer databases operated by the nationwide CRAs.

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DATA FLOWS, TECHNOLOGY, AND THE NEED FOR NATIONAL PRIVACY LEGISLATION

Published: July 2019

Does being a victim of a data breach increase the risk of identity theft? In this first-of-its-kind joint-study with the U.S. Chamber of Commerce Technology Engagement Center, which we hope will contribute to informed and evidence-based federal preemptive privacy legislation, no evidence is found that data breaches lead to increased consumer harm. 


REPLY TO THE HTF REPORT ON BUILDING A PCR IN INDIA

Published: September 2018

This report addresses the Reserve Bank of India’s High-Level Task Force (HTF) Report published in June 2018 regarding the proposed Indian public credit registry (PCR).


FOSTERING COMPETITION AMONG LENDERS: PROPOSED LIGHT-TOUCH MANDATORY CCR UNLIKELY TO WORK

Published: April 2018

This report explores the possible impacts of the proposed Comprehensive Credit Reporting bill in Australia.


FHFA CREDIT SCORE REQUEST FOR COMMENTS INPUT

Published: March 2018

In these comments we support the FHFA’s effort to update the credit score used/required by the GSEs and explore how more than one score could be considered or permitted. We wish the FHFA would go further and create a more flexible process that would allow the credit score(s) used to be updated more regularly and also permit more credit score flexibility to enable scores that use alternative data to be utilized.


THE CASE FOR A PUBLIC CREDIT REGISTRY IN INDIA: ADDITIONAL EVIDENCE FOR CONSIDERATION

Published: March 2018

This paper examines a range of policy and market issues associated with the proposed introduction of a public credit registry (PCR) in India.


CRYPTO-CURRENCIES: MISNAMED, MISUNDERSTOOD, AND A MISTAKE FOR CASUAL INVESTORS

Published: January 2018

Let me begin by declaring that Bitcoin has jumped the shark. Hopefully, the news of exchanges being shut down and wild price swings will provide sufficient red flags to potential investors so that they may avoid being drawn into this self-evident Ponzi scheme. Alas, this likely does not mean the end for crypto-currencies…for better or for worse. 

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THE IMPACT OF CREDIT REPORTING AND CREDIT SCORING ON THE MFI SECTOR

Published: January 2018

This research analyzes a series of questions pertaining to the impacts on microfinance institutions (MFIs) when using credit bureau data (conventionally referred to as credit files) for purposes of underwriting credit; for the same purposes, it also analyzes credit scoring models and credit decisioning platforms that use credit bureau data. 


DATA PROTECTION AND CREDIT INFORMATION SHARING

Published: November 2017

This white paper discusses different data protection regimes and argues that whether a system is considered siloed or omnibus what really matters (in a practical sense) are the details and whether there is sufficient regulatory flexibility to account for “on the ground” realities. Credit information sharing is a focus of the white paper.

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CHANGING THE LENDING LANDSCAPE: CREDIT DESERTS, THE CREDIT INVISIBLE, AND DATA GAPS IN SILICON VALLEY

Published: November 2017

This report presents findings from the pilot effort of the Credit Deserts Project, which aims to map the incidence of Credit Invisibility, in which consumers have credit reports with no or insufficient data with which to generate a traditional credit score. Previous research suggests that Credit Invisibles disproportionately live in lower income areas of communities and help form what we call Credit Deserts.


THOUGHT PAPER – CREDIT REPUTATION RANSOMING: HELD HOSTAGE TO ZOMBIE DEBT

Published: March 2017

This Thought Paper describes a way debt collectors can leverage the credit reporting of newer debt to have consumers pay older debt which is no longer credit reporting.


PERSONALIZED CREDIT EDUCATION: CONSUMER AND SMALL BUSINESS OWNER ATTITUDES, IMPACTS AND IMPEDIMENTS

Published: November 2016

This study is the final report on research that examines resulting credit score changes and consumer attitudes following the use of personalized credit education sessions by study participants. The credit education service examined is offered by a national credit bureau. Such services (offered by for-profit non-lender/non-creditor entities) are covered and inhibited by CROA.


CRA CREDIT EDUCATION SERVICES: AN EXAMINATION OF CONSUMER IMPACTS

Published: April 2016

This study was designed to gauge the impact of a personalized credit education service from a national credit bureau on consumer understanding of credit reports and scores as measured by changes in credit scores and results from a participant survey. 


IMPLICATIONS OF SILOED AND SEGMENTED DATA IN CREDIT MARKETS 

Published: December 2015

This white paper examines implications of fragmented data in credit markets, with particular focus on commercial / small business credit data and lending.


PREDICTING FINANCIAL ACCOUNT DELINQUENCIES WITH UTILITY AND TELECOM PAYMENT DATA

Published: May 2015

This paper examines whether utility and telecom payments (non-financial data) are predictive of either future delinquencies on traditional credit accounts (bank card or mortgages) or of having future derogatory public records.


IS CROA CHOKING CREDIT REPORT LITERACY?

Published: April 2015

This report examines whether the Credit Repair Organizations Act (CROA) is unduly inhibiting the use of needed credit report and education services. It then explores whether the 20 year old CROA could be revised in ways that maintain consumer and credit market protections.


RESEARCH CONSENSUS CONFIRMS BENEFITS OF ALTERNATIVE DATA

Published: March 2015

This paper reviews research carried out by score developers, CRAs, and other organizations on the impacts and potential of alternative data. 

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THE IMPACTS OF INFORMATION SHARING ON COMPETITION IN LENDING MARKETS 

Published: October 2014 

This study examines how shifting to full file credit sharing systems might impact lender competition. It specifically explores whether bank concentration falls following a shift to full-file credit sharing. 


CREDIT BUREAUS IN EMERGING MARKETS: OVERVIEW OF OWNERSHIP & REGULATORY FRAMEWORKS 

Published: September 2014 


CREDIT IMPACTS OF MORE COMPREHENSIVE CREDIT REPORTING IN AUSTRALIA AND NEW ZEALAND 

Published: August 2012 

This report details the impacts of more comprehensive credit reporting in Australia and New Zealand. The report summarizes the results from a joint undertaking by PERC and Dun & Bradstreet Australasia using credit data from 1.8 million Australians. 


FINANCIAL INCLUSION THROUGH CREDIT REPORTING: HURDLES AND SOLUTIONS 

Published: April 2010 

This policy brief, a white paper produced for the APCC in April 2010, examines the logic of information sharing as it relates to financial inclusion and suggests some policy concerns and policy targets designed to promote a financial inclusion agenda. 


ROADMAP TO REFORM: LESSONS FROM AROUND THE WORLD TO GUIDE CONSUMER CREDIT REPORTING REFORM IN AUSTRALIA 

Published: October 2008 

PERC’s Roadmap to Reform details the benefits of comprehensive credit reporting, as well as detailing transitional challenges of switching to a full-file system.  


THE STRUCTURE OF INFORMATION SHARING AND CREDIT ACCESS: LESSONS FOR POLICY 

Published: July 2008 

This white-paper, produced for the Asia-Pacific Credit Coalition, outlines recent developments in the economic impact of information sharing in consumer credit markets. 


HOW SAFE AND SECURE IS IT? 

Published: January 2005 

This study is an assessment of personal data privacy and security in business process outsourcing firms in India. 


PRIVACY RIGHTS AND POLICY WRONGS: HOW DATA RESTRICTIONS CAN IMPAIR INFORMATION-LED DEVELOPMENT IN EMERGING MARKETS 

Published: January 2004 

This paper highlights a potential threat to a new model for economic development posed by European-style data privacy regulatory regimes. 

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