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It has nothing to do with the CRA's. They don't make the decision. It has to do with LENDER regulations where lenders are required to analyze the applicants income, debt and ability to pay.
The CRA's are merely trying to create a product to assist the lender in that criteria, the assist is for profit yes, but it is still the result of stiffer regs being put on lenders. Lenders who do not comply would be potentially considered as "predatory" since they did not make reasonable nor well informed credit decisions.
IMO
Look at it this way: Income Estimation is basically another "score" like FICO or FAKO that lenders will use as a PART of their decision. If there is not adequate information to make a decision on income, then they will ask for verification, just like they may ask for ID verification on some apps.
Sometimes CCCs want a utility statement and copy of DL for ID. Sometimes they want paystubs or W2 for income.
The "estimation" equation will try to eliminate the need for those docs part or much of the time.
I read this article and find it very concerning. Yes, I agree that the right intention was in play when it started, but I fear that it can potentially open a can of worms if indeed what this article states is true.
If I am in the process of establishing business with a lender (cc, car loan, mortgage, etc), then I have no problem providing proof of my income to that lender as part of its decision process. I say that with the expectation that any documentation that I provide will be considered confidential between me and that lender for the purpose of conducting business and that it can't be given to 3rd parties for marketing purposes. And yes providing my confidential income information for collection in Experian's database is considered a marketing purpose as they sell access into the database.
With that said, the #1 concern I have with this "database" used to collect information regarding incomes that is available to any lender with or without my consent. When I look at my "soft pulls" today, the majority of softpulls that I see are from companies I have never heard of, or done business with. I don't want my private income information to be available to companies that i do not do business with. I keep hoping that someone speaks up and shows that there is an opt-out option on being including in such a database.
My #2 concern is this "estimation" business. I realize it was put there to appease the retail CCC that like the instant credit marketing at the cash register. But to everyone's point, I guarantee that if you look at my credit report, you will never guess how much money I report to the IRS each year. I joke that if you asked three of my closest friends, they don't have a clue how much money I make. Yes, supposedly the CCC can't use the estimate solely to make their decision. But how enforceable is that really? The article states the CCC's can use this estimator to make decisions on adjustments to your credit limit. Yet this article also glosses over that during test runs of the model, it determined individuals to have an income of $35k when in actuality they made $50k. So it isn't perfect.
I am shocked that there is not an opt-out option here. I would not be as much up in arms over this portion if there was the ability for an individual to not be included in any estimator or database. An individual should be allowed to choose between privacy and convenience. I personally would choose privacy even if it meant that I had to give up the ability to apply for credit at check-out and had to manually provide proof of income to a lender.
The issue is not providing proof of income to a lender to help them decide whether to do business with me, or how much credit I can afford. The issue boils down to accuracy, privacy, and security concerns of these "databases" and estimator systems.
@Anonymous wrote:I read this article and find it very concerning. Yes, I agree that the right intention was in play when it started, but I fear that it can potentially open a can of worms if indeed what this article states is true.
If I am in the process of establishing business with a lender (cc, car loan, mortgage, etc), then I have no problem providing proof of my income to that lender as part of its decision process. I say that with the expectation that any documentation that I provide will be considered confidential between me and that lender for the purpose of conducting business and that it can't be given to 3rd parties for marketing purposes. And yes providing my confidential income information for collection in Experian's database is considered a marketing purpose as they sell access into the database.
With that said, the #1 concern I have with this "database" used to collect information regarding incomes that is available to any lender with or without my consent. When I look at my "soft pulls" today, the majority of softpulls that I see are from companies I have never heard of, or done business with. I don't want my private income information to be available to companies that i do not do business with. I keep hoping that someone speaks up and shows that there is an opt-out option on being including in such a database.
My #2 concern is this "estimation" business. I realize it was put there to appease the retail CCC that like the instant credit marketing at the cash register. But to everyone's point, I guarantee that if you look at my credit report, you will never guess how much money I report to the IRS each year. I joke that if you asked three of my closest friends, they don't have a clue how much money I make. Yes, supposedly the CCC can't use the estimate solely to make their decision. But how enforceable is that really? The article states the CCC's can use this estimator to make decisions on adjustments to your credit limit. Yet this article also glosses over that during test runs of the model, it determined individuals to have an income of $35k when in actuality they made $50k. So it isn't perfect.
I am shocked that there is not an opt-out option here. I would not be as much up in arms over this portion if there was the ability for an individual to not be included in any estimator or database. An individual should be allowed to choose between privacy and convenience. I personally would choose privacy even if it meant that I had to give up the ability to apply for credit at check-out and had to manually provide proof of income to a lender.
The issue is not providing proof of income to a lender to help them decide whether to do business with me, or how much credit I can afford. The issue boils down to accuracy, privacy, and security concerns of these "databases" and estimator systems.
I agree. It's the "estimating" that bothers me. After all, just how accurate have all of us found the FICO Simulator to be? Huh?
@LynetteM wrote:
@Anonymous wrote:I read this article and find it very concerning. Yes, I agree that the right intention was in play when it started, but I fear that it can potentially open a can of worms if indeed what this article states is true.
If I am in the process of establishing business with a lender (cc, car loan, mortgage, etc), then I have no problem providing proof of my income to that lender as part of its decision process. I say that with the expectation that any documentation that I provide will be considered confidential between me and that lender for the purpose of conducting business and that it can't be given to 3rd parties for marketing purposes. And yes providing my confidential income information for collection in Experian's database is considered a marketing purpose as they sell access into the database.
With that said, the #1 concern I have with this "database" used to collect information regarding incomes that is available to any lender with or without my consent. When I look at my "soft pulls" today, the majority of softpulls that I see are from companies I have never heard of, or done business with. I don't want my private income information to be available to companies that i do not do business with. I keep hoping that someone speaks up and shows that there is an opt-out option on being including in such a database.
My #2 concern is this "estimation" business. I realize it was put there to appease the retail CCC that like the instant credit marketing at the cash register. But to everyone's point, I guarantee that if you look at my credit report, you will never guess how much money I report to the IRS each year. I joke that if you asked three of my closest friends, they don't have a clue how much money I make. Yes, supposedly the CCC can't use the estimate solely to make their decision. But how enforceable is that really? The article states the CCC's can use this estimator to make decisions on adjustments to your credit limit. Yet this article also glosses over that during test runs of the model, it determined individuals to have an income of $35k when in actuality they made $50k. So it isn't perfect.
I am shocked that there is not an opt-out option here. I would not be as much up in arms over this portion if there was the ability for an individual to not be included in any estimator or database. An individual should be allowed to choose between privacy and convenience. I personally would choose privacy even if it meant that I had to give up the ability to apply for credit at check-out and had to manually provide proof of income to a lender.
The issue is not providing proof of income to a lender to help them decide whether to do business with me, or how much credit I can afford. The issue boils down to accuracy, privacy, and security concerns of these "databases" and estimator systems.
I agree. It's the "estimating" that bothers me. After all, just how accurate have all of us found the FICO Simulator to be? Huh?
Here is what I believe might be forgotten: Lenders want to lend money. No, let me restate that: lenders have to lend. This is why you get the promo mailings and offerings.
I hear people state they are concerned they may get passed up due to an innaccurate estimation. On the one hand there is concern that income is private. But then on the other hand concern that estimations may be innaccurate. Either we want the estimations accurate or we want the privacy meaning not accurate, correct?
If one is concerned the estimation is innaccurate, then verification of real information is necessary with the lender. If one is concerned with privacy, then estimation is preferred where sufficient and if the lender feels inclined to lend based solely on estimation.
But we must remember that lenders are in the business to lend. If they do not lend, they don't stay in business. So if you are qualified or potentially qualified, there may be a little more involved in the application or credit process, but in the end you will be able to get the credit or loans you want AND are qualified for.
I understand the privacy issues. But on the other hand, when you apply, except for very few exceptions, you must disclose your income. And the terms of application give the lender the right to verify your employment, income and credit references. So once you apply, you are no longer entitled to privacy in relationship to that lender.
This is more red tape and regs the lenders must comply with. But in the end, they will figure out how to lend as long as we have free market capitalism.
Also, CR's used to contain income information. When I was 20 I had my employer provide me a statement of income on company letterhead. I gave that to the local credit bureau (EQ affiliate now) and they updated as "verified" who my employer was, what my salary was and when this was submitted/verified.
This made my application for credit much easier at that time, because most lenders would allow that as income verification, until the date verified seemed to old.
I am trying to figure out where I am not clear here. In my mind, there are two primary issues from this article. The estimator system and the income/employment database being open to any financial institution, such as the one from Experian that the article referenced.
I have no problem with a lender needing to verify my income, employment, credit in order to conduct business with me. Again that isn't my issue here. If I have legitimate business with a lender, they are more than welcome to ask me for documentation, talk to the IRS, call my employer, etc. Heck they are welcome to call my Grandmother to confirm that I like Apple Pie and attend at least one Baseball game a year if they like. I am not arguing that point. In fact I want them to do those things as I would hope that it will enable them to make better business decisions and we can keep this huge financial mess from happening again. I believe that was the original intent of these new rules. No argument there. The key there though is that I, the consumer, am selecting what lender has the right to see that information. If I wish to do business with a particular lender, then i fully understand that that particular lender needs to confirm and verify my ability to pay them for the service that I am requesting.
I also believe and do argue that all of the above can be done in a manner without the lender providing this verification documentation to 3rd parties such as CRA's for inclusion in a database. In the telecom industry, it is referred to as "Customer Proprietary Network Information" that can't be shared even internally except as needed to conduct business. There are very strict rules and penalties that are enforced to protect this information. I believe that something similar could be done in the banking industry as well to protect this information. The FCRA and the other laws dictate that a lender can report to the CRA our payment histories and current status of our account, but I believe that income levels and who we are employed with showed not be included as a default practice.
As for my concerns of the estimator system, it is an educated guess based upon one's CR. However I don't believe that it is possible to generate a fairly accurate estimate strictly from looking at one's CR. No one knows all of the risks or negative ramifications of an incorrect estimate (high or low). But I am confident that there are risks. The question is whether the benefits outweigh the risks.
My whole issue with the estimator system and the database of incomes/employment is that I believe that an individual should be able to choose to opt-in/out of either of these systems. Just like you can opt-out of "no-call lists" etc. Yes, by opting out it means that you can't apply at the register for instant credit. Yes, you may have to manually provide the necessary documentation, or sign a waiver to let the lender get the information from your employer, bank, and IRS. Just like on the flip side an individual may like the "instant credit" offers/discounts at the a retailer, and not want to deal with the documentation hassles, thus that individual would want to "opt-in".
My whole point has been that an individual should have the choice to opt in or out, understanding the pro's and con's to their decision.
And so far... no one has shown me that there is an opt-in/out option with either of these systems.
Well you can't opt out of a CB's files - you can only opt out of prescreened offers. (The data provided on a prescreened offer, by the way, contain none of the TL details from your CBR.) They only provide the details of your CBR to those you app credit with and in the T&C's for the app you consented to the INQ. It will be the same way with the "income" estimator. Not really a big deal. I'd rather they agree to proceed with some made up income number than my having to suppy anybody with my tax returns. They're none of anybody's business.
@Anonymous wrote:Look at it this way: Income Estimation is basically another "score" like FICO or FAKO that lenders will use as a PART of their decision. If there is not adequate information to make a decision on income, then they will ask for verification, just like they may ask for ID verification on some apps.
Sometimes CCCs want a utility statement and copy of DL for ID. Sometimes they want paystubs or W2 for income.
The "estimation" equation will try to eliminate the need for those docs part or much of the time.
Personally, I don't believe they could come up with a statistically validated method to impute income by using credit limits or even spending patterns, but who knows? I have seen various state governments trying to impute income in child support cases and they seldom hit the mark. I hope CRAs can do better.
As long as there is a mechanism whereby an applicant can supply validated proof of income to overcome errors made by the CRAs, I think it might be ok. Besides, I would think that to comply with the ECOA CCCs will not have a really high threshold for approval at lower credit limits. If they later decide to raise a CL would the law require them to verify an increased income?