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necessary for scorecards that were tested and rejected, not just the final scorecard, and competing methods to the one used to produce the scorecard.

      ● Retention of corporate intellectual property (IP)/knowledge. Practices such as writing unique code for each project and keeping it on individual PCs makes it harder to retain IP when key staff leave. Using programming-based modeling tools makes it more difficult to retain this IP as staff leaving take their coding skills with them. Most modelers/coders also choose to rewrite code rather than sort through partial code work previously written by someone else. This results in delays, and often ends with different answers obtained for the same question. To counter this, many banks have shifted to GUI software to reduce this loss and to introduce standardization.

      ● Integration across the model development tasks. Integration across the continuum of activities shown in Exhibit 3.1, from data set creation to validation, means that the output of each phase seamlessly gets used in the next. Practices such as rewriting Extract-Transform-Load (ETL) and scoring code, as well as that for deriving and creating variables into different languages is not efficient, as it lengthens the production cycle. It also presents model risk, as recoding into a different language may alter the interpretation of the original variable or condition coded. These would include parameters and conditions for both data sets and models. An integrated infrastructure for analytics also means a lowered implementation risk, as all the components across the continuum will likely work together. This is in addition to the integration and involvement of various stakeholders/personas discussed in the previous chapter.

      ● Faster time to results. It sometimes takes months to build a model and implement it in many institutions, resulting in the use of inefficient or unstable models for longer than necessary. Efficient infrastructure design can make this process much faster based on integrated components, faster learning cycles for users, and reduction of repetition (such as recoding).

      In discussing the points to consider when designing architecture/infrastructure to enable in-house scorecard development and analytics, we will consider the major tasks associated with performing analytics in any organization.

      Data Gathering and Organization

      This critical phase involves collecting and collating data from disparate (original) data sources and organizing them. This includes merging and matching of records for different products, channels, and systems.

      The result of this effort is a clean, reliable data source that ideally has one complete record for each customer and includes all application and performance data for all products owned. This would mean customer’s data from their mortgage, credit card, auto loan, savings and checking accounts, and ATM usage would all be in the same place. Later in the book, we will refer to using such variables in scorecard development. In some banks this is known as the enterprise data warehouse (EDW).

      In any analytics infrastructure project, this is typically the most difficult and lengthiest phase. Organizations have dirty data, disparate data on dozens and sometimes hundreds of databases with no matching keys, incomplete and missing data, and in some cases coded data that cannot be interpreted. But this is the most important phase of the project, and fixing it has the biggest long-term positive impact on the whole process. Without clean, trusted data, everything else happening downstream is less valuable. We recognize, however, that waiting for perfectly matched clean data for all products before starting scorecard development, especially in large banks with many legacy systems, is not realistic. There is a reason EDW is known as “endless data warehouse” in far too many places. In order to get “quick hits,” organizations often take silo approaches and fill the data warehouse with information on one product, and then build and deploy scorecards for that product. They then move on to the next set of products in a sequential manner. This helps in showing some benefit from the data warehouse in the short term and is a better approach than waiting for all data for all products to be loaded in.

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      1

       www.sas.com/en_us/industry/banking/credit-scoring.html

      2

      Basel Committee for Banking Supervision, Basel II: International Convergence of Capital Measurement and Capital Standards: A Revised Framework, Bank for International Settlements, November 2005.

      3

      European Banking Federation, Study on Internal Rating Based (IRB) models in Europe, 2014.

      4

      L. Einav, M. Jenkins, J. Levin, ”The Impact of Credit Scoring on Consumer Lending,” RAND Journal of Economics

1

www.sas.com/en_us/industry/banking/credit-scoring.html

2

Basel Committee for Banking Supervision, Basel II: International Convergence of Capital Measurement and Capital Standards: A Revised Framework, Bank for International Settlements, November 2005.

3

European Banking Federation, Study on Internal Rating Based (IRB) models in Europe, 2014.

4

L. Einav, M. Jenkins, J. Levin, ”The Impact of Credit Scoring on Consumer Lending,” RAND Journal of Economics, 44, no. 2, (Summer 2013): 249–274.

5

Reg. B, 12 C.F.R. § 202.2(p)(2)(iii)(1978)

6

http://time.com/money/3978575/credit-scores-auto-insurance-rates/

7

www.cbc.ca/news/credit-scores-can-hike-home-insurance-rates-1.890442

8

Jane Dokko, Geng Li, and Jessica Hayes, “Credit Scores and Committed Relationships,” Finance and Economics Discussion Series 2015-081. Washington, DC: Board of Governors of the Federal Reserve System, 2015; http://dx.doi.org/10.17016/FEDS.2015.081

9

www.wsj.com/articles/silicon-valley-gives-fico-low-score-1452556468

10

Basel Committee on Banking Supervision document, BCBS 239, Principles for Effective Risk Data Aggregation and Reporting, Bank for International Settlements, January 2013.

11

www.forbes.com/sites/stevedenning/2011/11/22/5086/#c333bf95b560

12

Supervisory Guidance on Model Risk Management, Federal Reserve Bank, www.federalreserve.gov/bankinforeg/srletters/sr1107a1.pdf

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