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Truth On Credit Scoring
Will Set Consumers Free
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By Birny Birnbaum; Birny Birnbaum, a
former insurance regulator, directs the Center for
Economic Justice, an Austin, Texas-based non-profit that
advocates on behalf of low-income and minority consumers
on insurance matters. Birny Birnbaum
The biggest reason why insurance
credit scoring continues to be a hot-button issue for
consumers and legislators around the country is that
insurers have simply not told the truth about credit
scoring and its detrimental effect on insurance
consumers.
The "Final Say" in last weeks edition of National
Underwriterby Ernie Csiszar, president and CEO of the
Property Casualty Insurers Association of America
assembles much of the misinformation in one place and
makes the bizarre claim that insurers need to generate
grass-roots support for credit scoring.
How this will occur is anyones guess, since the vast
majority of consumers oppose credit scoring. (In 2003, a
Scripps Howard Texas Poll on insurance credit scoring
found that fully 68 percent of Texans supported a total
ban.) Consumers oppose credit scoring for many reasons.
* First, even if we assume that credit reports are
accurate and complete, credit scoring is inherently
unfair.
Fully 87 percent of family bankruptcies result from job
loss, major medical bills and divorce. It is only in the
cloistered world of insurance actuaries and executives
that charging higher auto- and homeowners insurance
rates to some who suffered an economic or medical
catastrophe is considered fair.
* Second, credit scoring discriminates against poor and
minority consumers.
A Missouri insurance department study last year found
race to be the single best predictor of an insurance
score, and that credit scores for minorities were
consistently lower than scores for non-minorities.
In addition, a Texas insurance department study found a
consistent pattern of differences in credit scores among
the different racial/ethnic groups. The average credit
scores for whites and Asians are better than those for
African-Americans and Hispanics. In addition,
African-Americans and Hispanics tend to be over
represented in the worst credit-score categories and
underrepresented in the better credit-score categories.
Seems pretty unequivocal, doesn't it? But Mr. Csiszar
cites Texas Insurance Commissioner Jose Montemayors
letter to the Texas Legislature, in which Mr. Montemayor
concludes no bias in credit scoring. Mr. Montemayors
explanation might be plausible if it did not contradict
the actual findings of his departments study.
Interestingly, for many years, insurers have justified
the use of credit scoring based on a simple correlation
between credit scores and loss ratios. Yet, the Missouri
and Texas insurance departments found precisely this
type of relationship strong correlation between credit
scores and race. For insurers, what's good for the goose
is apparently
not good for the gander.
* Third, credit scoring is arbitrary and penalizes
consumers for rational behavior.
The fact is that credit reports often have errors or
missing data. Not all lenders report to even one of the
major credit bureaus, let alone all three.Consequently,
a consumers credit score can vary from very bad to very
good based upon which bureau provided the information. I
recently checked my credit reports from all three
bureaus and found
the information on inquiries completely different in
each bureaus report.
A consumers payment history makes up a small portion of
the factors in a credit scoring model. Rather, factors
concerning the type of credit, the length of credit
history, inquiries, credit balance to limits, and when
loans were opened carry more weight than whether a
consumer pays bills on time. The absence of credit
information hurts a score more than a late payment.
And lets not even get into errors in credit reports.
Identity theft is the fastest growing financial crime,
and it directly affects consumers credit scores. It
seems we learn each week about a credit bureau getting
hacked or a lender losing data affecting millions of
consumers.
For all practical purposes, an error in a credit report
is irreparable for an insurance consumer. The process of
finding out that credit was used in pricing, that a
credit score resulted in an adverse action, obtaining
the reasons for the adverse action, obtaining a credit
report, and then trying to get the credit bureau and
lenders to fix the errors is not only next to impossible
but so time consuming as to make the exercise irrelevant
in challenging an insurers credit score.
* Fourth, credit scoring undermines the critical role of
insurance in loss prevention.
Insurance has two critical purposes to provide
consumers, businesses and communities with an essential
financial security tool in the event of a catastrophic
event, and to promote loss prevention. Insurance credit
scoring undermines insurance availability and
affordability and, just as important, undermines the
loss prevention role of insurance.
Insurance credit scoring minimizes the role of rating
factors that are under a consumers control and that
provide economic incentives for less risky behavior.
Instead of transparency in rating to help a consumer
understand what type of behavior will be rewarded with
lower premiums, credit scoring makes insurance rating an
opaque process
disconnected from loss prevention.
While criticizing opponents of credit scoring for
pointing out that credit scoring discriminates against
minorities" playing the race card" Mr. Csiszar has
absolutely no hesitation in playing one group of
consumers against another. He throws out the tired
claims that credit scoring rewards fiscally responsible
consumers and that a ban on credit scoring will cause
good risks to subsidize bad. Both claims have been shown
to be false for years, but that never stops insurers
from engaging in class warfare.
The fact is that a credit history is not a measure of
financial responsibility and that a good credit history
does not equate to a good credit score. A review of
actual credit scoring models which are public
information in Texas shows that the vast majority of
factors in credit scoring have nothing to do with
payment history and everything to do with economic
status.
The fact is that a credit report contains only a small
piece of a consumers financial picture there is no
information on savings, investments, insurance or
routine payments for rent and utilities. Together with
the arbitrary nature of credit scoring, described above,
these facts lay the fiscal responsibility myth further
in the grave.
As for subsidies, insurers have lost sight of the
fundamental purpose of insurance for consumers to spread
risk in a fashion that provides economic incentives for
less risky behavior and economic disincentives for more
risky behavior. It is not a subsidy to treat two
consumers the same if they have similar risk profiles
but a different number of
credit cards or loans from different types of lenders.
Rather, it is basic fairness.
Mr. Csiszars arguments about credit scoring are belied
by the facts about credit scoring. If consumers embrace
credit scoring the way that insurers say they should,
why don't we see even one insurer advertising its use of
credit scoring? We see ads for safe drivers, but no ads
telling consumers about the great rates for good credit
scores. The answer, of course, is consumers loathe
credit scoring and insurers know it.
Mr. Csiszars reaction to the Texas chapter of AARP
opposing credit scoring should not be the dismissive "go
figure," but some serious reflection on why a group of
consumers who allegedly benefit from credit scoring
demand a ban on the practice. Opponents of credit
scoring, contrary to Mr. Csiszars claims, are not
opposed to risk-based pricing. We are opposed to unfair
practices that discriminate against minorities and
undermine the basic role of insurance in our society.
If insurers could see beyond the short-term bottom line,
they'd see a richer long-term bottom line with the end
of credit scoring. Consumers fight against insurance
credit scoring grows stronger every day.
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