1. Credit Reporting Foundations Lessons from Europe

2. The ideal situation  It is fascinating to being able to decide what is the best model on which to found a credit bureau. Should there be a private bureau, a public registry, or both? Should data contribution be mandatory? What about inquiry? Do private bureaus need to be regulated and if so by whom? Who should have access to bureau data? What type of consent, if any, is needed?  Some of these questions often lead to philosophical debates at best, and soccer hooliganism at worst  Today I have the luxury to stand away from the debate and simply bring some experiences on how these debates were settled in different countries Space for product/client logo ©2015 Name Surname day/month/year2

3. European Landscape  Europe presents a fairly diversified landscape when it comes to credit bureaus, in terms of ownership structure, private bureau vs public registry, profit vs non profit, member structure, purpose for accessing, information handled and regulatory/supervision/oversight environment  Most European bureaus participate in ACCIS, the Association of Consumer Credit Information Suppliers established in Dublin in 1990, and currently bringing together 46 consumer credit reference agencies in 28 European countries and 6 associate members from all other continents.  I will use ACCIS data to concentrate on the regulatory environment differrences Space for product/client logo ©2015 Name Surname day/month/year3

4. Private Bureau or Public Registry? Industry or Independent owned? ©2015 4 Wide diversity in ownership structures: 32% are owned by lender associations or banks, 36% are subsidiaries of other organizations and 21% are privately owned. Source: ACCIS Survey 2011 2012

5. Profit / Non Profit ©2015 5

6. Mandatory or Voluntary Contribution? ©2015 6 In about 29% of cases, data sharing is required by regulation, and a further 19% is partially required

7. Consent Needed? ©2015 7 59% of responders stated that all/part of their data was shared on the basis of consent.

8. Consent Opt Out Allowed? ©2015 8 64% are able to opt out of this data being shared and 43% stated the consumer could withdraw this consent at a later date

9. Permissable Purpose? ©2015 9 55% of responders stated all or part of their data was shared on the basis of legitimate interests of the data processor and that the consumer is notified that data will be shared if they proceed with the product.

10. Permissable Purpose and Who Can Access? ©2015 10

11. Different Management of Positive and Negative Data Requirements ©2015 11 The basis for sharing, whether consent, legitimate interest or otherwise, does vary depending on the data, whether positive or negative, for 36% of credit bureaux. In addition to the legislation considered here, 43% of responders stated there were other laws or regulation that restricts data sharing

12. Conclusion - The ideal situation  I promised to stay out of the fray, but I do have an opinion  There is no ideal situation. Different situations can work with different combinations of underlying foundations, and also depend on local values and realities.  Not all countries must have public registries, not all countries must have licensed bureaus, not all countries require consent  The right balance must be struck between stakeholder rights, local values, and the level of available financial infrastructure  Incentives to share pooled and public data, together with oversight focused on guaranteeing quality and value added lenders and borrowers are the good practices that accelerate the credit reporting infrastructure maturity in a country. On the contrary, a difficult access to data and oversight focused on processes combine to slow down such growth Space for product/client logo ©2015 Name Surname day/month/year12

13. Thank you for your attention