You can develop internal scoring criteria for grant of credit, as long as you dont violate the Fed Civil Rights Act.
There is not one sentence that I am aware of in fedral code that regulates how you do credit scoring, or make credit decisions, other than that they not be discrimatory. Residence status is not a discrimatory status, as far as I know!
As with all credit scorecards, they are proprietary business trade secrets, including the FICO models. It is not illegal for you to consider what you feel is relevant, as long as it is not discriminatory.
Meaning, bottom line, that you dont discriminate on the basis of age, religion, national origin, race, or sex.
REsidence, depending upon your business, may be an important criteria for you. I know of no single statute that prohiits a potential lendor from considering residential status as a lending criteria. Your banking gurus apparently also cant cite any such probitory regulatons.
FICO scoring leaves out many relevant factors that some lendors feel are critical to loan approval. FICO is not a financial evaluatiion, and was never intended to be.
It is basically a risk analysis, based on prior and current status, of the likelihood for payment default in the next two years, or so. Mortgage lendors, for example, rely on a detailed financial discosure that far surpasses the limited items considered in a credit reporting agencie's credit file.
While FICO, and maybe the banker group gurus you were speaking with, might not want to include such information as marital status, income, all debts, even if not showing in a credit file with the CRAs, residential status, or unpaid debts even beyond normal CR "drop-off" dates, in their considerations, I see no prohibition from a lendor considering that information in their decision making.
