Income
vs. Insurance Credit Scores
The
Virginia Bureau of Insurance Report
This is the report cited most by the
industry as proof that insurance scores are not discriminatory to lower
income insurance consumers:
This analysis is comprised of a file
(provided by Fair, Isaac). The file contained the average credit score
by zip code for Virginia zip codes containing more than 100 credit
scores in the Trans Union database. "There were 956 zip codes
meeting this minimum number of credit score criteria. The average credit
score for these zip codes was 701, with a median score of 702 and a
minimum and maximum of 603 and 757 respectively. The Bureau matched
average credit score by zip code to the 1989 Federal Census demographic
data by zip code and performed various regression analysis to determine
if credit
scores could be used to determine a person's income or race."
"The bureau analyzed the relationship between credit scores and
income as well as the relationship between credit scores and race.
Neither Fair Isaac nor Trans-Union collects data on income or race, thus
requiring the bureau to obtain this information from the 1989 Federal
Census. Although, it did
not provide a one-to-one match, this did not preclude the Bureau from
analyzing whether correlations exist. Thus, average credit scores,
median household incomes, and racial make-up by zip code were analyzed
to obtain a general indication of correlation. Nothing in this analysis
leads the Bureau
to the conclusion that income or race alone is a reliable predictor of
credit scores."
Does this convince you? Note that this
was an analysis, not a study. This
analysis was done with "insurance" credit scores.
There is additional research cited in
Virginia's findings that the insurance industry failed to include.
The following research is done with
"creditworthy" credit scores.
This research was conducted by the Federal
Home Loan Mortgage Corporation (Freddie Mac) and five of the nations
Historically Black Colleges and Universities. They found that:
- Having poor credit is a common
problem in today's society.
- Credit problems extend across income
groups and are not unique to low-income borrowers.
- Minority borrowers are more likely
than white borrowers to experience credit problems.
Furthermore, according to a report
released by The Fair Housing Council of Greater Washington:
"It is highly probable that
credit scoring has a disparate impact on protected classes which
creates barriers to having access to equitable insurance
products."
and the Federal
National Mortgage Association (Fannie Mae), stated in an advisory:
"Mortgage lenders were told to
look at the factors which caused a bad credit score and not
automatically disqualify someone simply due to a "below
average" credit score."
The Virginia report goes on to
explain that:
"Based in the Bureau's
findings, there APPEARS to be concrete data that a
correlation exists between credit scores and losses. From this
purely, statistical perspective, therefore, the Bureau is unable to
make a recommendation prohibiting the use of credit scores in the
underwriting process. However, the Bureau has concerns about the
long-term effect that the use of credit scores may have on Virginia
consumers. As the number of insurers that use credit history as an
underwriting tool increases, there may be an increase in the number
of consumers that will be refused coverage, cancelled, non-renewed,
or charged higher premiums due to their adverse credit history. Conversely,
industry advocates of this practice argue that there may be an
increase in the number of consumers that will obtain coverage at
lower rates due to their good credit history.
As suggested in the white paper
prepared by the National Association of Insurance Commissioners, the
Bureau recommends that the insurance industry take steps to educate
consumers about the use of credit scores in the underwriting
process. If the Bureau finds that over time a significantly
greater number of companies are refusing to issue of refusing to
renew coverage solely on the basis of an adverse credit history, the
Bureau will consider proposing legislation to prohibit this practice"
Guess which part the insurance industry
fails to include when citing this reference?!
Virginia responded to the use of their
findings by the industry:
"Virginia regulators also
expressed disappointment with how their report to the legislature was
characterized. The report found a correlation between credit and
claims but found no causal relationship. In addition, while the
report offered no evidence of redlining under Virginia law, the
insurance department "continues to monitor" how CBUP (credit
based underwriting and pricing) impacts policyholders in its
jurisdiction."
"Representatives of both
departments called the NAII characterization of their reports
"overstated." Virginia regulators stressed that the data
reviewed for their study were prepared and provided by the insurers
and should not be used to extrapolate national conditions."
See
complete article.
Maryland
Department of Insurance Findings
This
information is compiled in the Maryland Insurance Department's Use of
Credit History by Insurers by Steve B. Larsen in 2002.
These numbers
speak for themselves.
| Exhibit
D - Demographic Data on Credit Scores, Race, and Income |
| Zip
Code |
21210 |
21217 |
| Median
Household Income |
$45,998.00 |
$14,813.00 |
| Population
Composition |
|
|
|
White |
12,002 |
3,665 |
|
Minority |
265 |
48,072 |
| Average
Insurance Premium |
$972.00 |
$1,357.00 |
| Credit
Ranges |
|
|
|
297-600 |
7.6% |
31.4% |
|
601-700 |
35.4% |
43.6% |
|
701-825 (The "700 Club") |
45.7% |
18.2% |
|
826-997 |
11.5% |
5.6% |
The
Washington Study
One of the most
interesting observations within the Washington study:
"At the request of the NAIC, the Academy of
Actuaries has evaluated four studies on insurance credit scoring. The
concluded that these studies do not directly address of whether this
practice has a disparate impact on people of color/and or the poor.
This is significant because the insurance companies have cited
these studies as evidence that insurance credit scoring does not have
a disparate impact. "Effects
of Credit Scoring on Auto Insurance Underwriting and Pricing",
State of Washington, Office of Insurance Commissioner.
Mike Kreidler, Washington Insurance Commissioner - Press
Release
"Income also was found to be a significant factor. The study
found that as incomes rise, credit scores improve and premiums go
down. Credit scoring raised the average costs for poor policyholders
relative to affluent policyholders."
"The intent of the study was not to single out a particular
company, but to see if industry-wide use of credit scoring in auto
insurance results in discrimination against the poor or people of
color," stated Insurance Commissioner Mike Kreidler. "It's
clear that interesting questions have been raised that warrant further
investigation."
It appears that more studies regarding
income vs. insurance scores are warranted. Why should it be up to the
consumer to prove this is a discriminatory and unfair practice? The
insurance companies have plenty of money to prove that it is not, why
then do they resist further studies?
The Insurance Associations ,(AAI, AIA,
NAII, NAMIC), have no interest in further studies, they state in their
latest
joint paper to the NAIC: (prior to the Washington Study)
"Should the working group
determine that a new study is warranted, the study
should determine the correlation between credit based insurance
scores and
loss ratio. Such a study would be the only truly objective and
meaningful
way of measuring whether or not credit scoring remains a relevant
factor to
premiums charged."
The same question comes to mind. Whoever
thought claims and credit would correlate and why? Was the old rating
method not profitable? Did basing rates on claims history and driving
history cause the insurance companies to lose money. It appears this is
not the case.
Reported
May 1, 2000 in the Detroit News (Michigan):
"Nationally, claim costs are down
about 3 percent to 4 percent over the past year. In part, rates are
falling because Americans are grayer, balder, fatter and better
drivers. As baby boomers age, they crash less. "We have a big
lump of suddenly safe drivers," Hunter
says. There are other reasons, too. Cars are safer
and air bags are cutting injuries, drunk driving is down. Some
states also have tightened licensing rules designed to keep uninsured
drivers off the road, which also may have helped. All that
means rates are falling for young and old"
Then it goes on to say:
"Avoiding tickets and accidents
is the best way to hold down auto insurance rates. But there are other
ways too. For instance, pay your bills. More insurers are using your
credit scores to set your auto insurance rate. "It's becoming the
new trend.""
So why do they need this new
factor? As one consumer put it in a recent email:
"This is arbitrary (at best)
and consumer gouging (at worst.)"
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