Tech Sprint on Electronic Disclosures of Adverse Action Notices
On October 5-9, 2020, we hosted a virtual tech sprint on Electronic Disclosures of Adverse Action Notices (AANs).
October 5-9, 2020
More than 75 participants from more than 29 organizations formed 13 teams and worked throughout the sprint week to develop innovative electronic ways to notify consumers of, and inform them about, adverse credit actions.
Many teams observed that, when denied credit, consumers would benefit from additional information about
- the degree to which different denial reasons contributed to the creditor’s decision,
- what they could do to change the result, and
- what other credit options might be available.
Several teams suggested ways to offer more complete information, particularly about how changes to an application could lead to credit approvals in the future. Some teams suggested including other features within the notice such as links to a credit report and enhanced information about how to request credit report corrections when appropriate.
Other teams focused on ways in which the adverse action notice could provide financial literacy and other information and coaching to educate and empower consumers, for example, about loan programs that have credit score or other specific lending guidelines. Teams also presented creative approaches to improve the format and presentation of the notice itself in order to better engage consumers, particularly when delivered online and on mobile devices. Chat bot driven engagements, customized videos, and links to useful consumer-facing resources were among the innovations suggested.
Teams also proposed methods for identifying the principal reasons for credit denial for underwriting models that use artificial intelligence/machine learning. These solutions sought to offer effective means to improve their credit profile and improve their chances of credit approval. For example, one team proposed an interactive “approval simulator” powered by machine learning that a consumer could use to see what actions, or combination of actions, would most easily yield a credit approval.
We thank all the tech sprint participants and evaluation panelists who participated in the Tech Sprint on Electronic Disclosures of AANs.
Under the Equal Credit Opportunity Act (ECOA) and the Fair Credit Reporting Act (FCRA), applicants for credit are generally entitled to receive the reasons why creditors take adverse action on their applications and, when creditors use a credit score, the key factors adversely affecting that score.
After an application process and a week of team formation activities, participants from more than 29 organizations grouped themselves into 13 teams to work on creating innovative electronic ways to notify consumers of – and inform them about – adverse credit actions.
The week concluded with a Demonstration Day where each team presented their resulting innovations to a panel of experts who reviewed them on the following bases:
How new or different is the team’s approach? Does the approach introduce a potential paradigm shift in how consumers are provided adverse action notices?
To what degree does the solution have the potential to make a practical and concrete improvement to the way consumers are notified and informed about adverse credit actions? Does the solution provide value for a variety of stakeholders?
How long would it take to bring the solution to market and/or have users adopt the solution?