In July 2022, the Consumer Financial Protection Bureau ("CFPB") announced a public enforcement action against an auto finance company totaling $19.2 million in penalties and significant redress for each impacted customer. With this action, the CFPB indicated that they will be prioritizing accurate credit furnishing. Modeling the potential customer impact of inaccurate data furnishing can help estimate risk exposure, target remediation priorities, and demonstrate good-faith efforts to regulators.
How FTI Consulting Can Help
FTI Consulting's Consumer Finance experts have a strong understanding of the impact of credit reporting fields on consumer credit and how financial institutions evaluate credit risk and utilize credit scores. We use our industry knowledge to determine the likely impact of inaccurately furnished fields and inadequate dispute responses (i.e., late response, no response or inaccurate response).
Modeling and Data Analytics Capabilities
FTI Consulting's Ph.D. statisticians have extensive prior experience developing consumer credit scoring models. Our dedicated Data & Analytics practice uses industry-leading tools and platforms to efficiently process large quantities of structured and unstructured data. Our experience developing models based on unique inputs and requirements includes:
- Quantifying economic damages
- Developing statistical, econometric and financial models in large data sets to analyze liability, damages, disgorgement, and remediation needs
- Identifying gaps and improvements in quantitative models for manual overrides
- Quantifying remediation needs
- Formulating practicable remediation rules across customer populations
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