In the last few years, consumer advocates were expressing concern about a return to the earliest days of credit reporting. Private businesses — banks, mostly — returned to gathering their own data and sharing it with other “affiliates” to make credit decisions. In June 2003, Citicorp made a statement to Congress that it did create such private databases but they were within the guidelines of federal law. It was the first time a major financial company disclosed that it kept such scores and shared those scores with other companies.

The danger for consumers? Nobody knows how heavily lenders lean on such private databases, and consumers obviously have no rights to correct errors. So while public credit scores have brought much more transparency to the lending process, it's uncertain how lenders are using data in unregulated databases they're creating for themselves.

It's an issue that merits continued scrutiny. Borrowers deserve full disclosure on why they're being denied credit or pushed into lending products they cannot afford.