You are on page 1of 52

Credit Scoring

Development and Methods

James Marinopoulos
Head of Retail Decision Model

Retail Decision Models


12/01/10 1
Group Risk - Retail Risk
Alan Greenspan:
President, Federal Reserve Board
May 1996

“… We should not forget that the basic economic function of these


regulated entities (banks) is to take risk. If we minimise risk
taking in order to reduce failure rates to zero, we will, by
definition, have eliminated the purpose of the banking
system.”

Retail Decision Models


12/01/10
Group Risk - Retail Risk
Risk Families
We are managing different groups of Risk

Customer fails
to pay
Change in
Losing money market
Wrong Strategy prices

Processing failures and


frauds

Regulatory compliance

Retail Decision Models


12/01/10
Group Risk - Retail Risk
Retail Decision Models Responsibilities
■ Policy
– Set Group policy on Decision Models
– Approve Decision Model policy changes
■ Monitor, Validate and Approve
– New Scorecard Developments
– Existing Scorecard Functionality
– Proposed changes to Decision Models Processes
– New Decision Models Systems functionality
– Decision Models Systems functionality changes
■ Governance
– Monitoring
– Undertake bank validations, reports and presentations for APRA
■ Risk Measurement
– Set risk benchmarks for scorecards
– Risk grading models
■ Advise
– Worlds best practice in Decision Models
– Risk related issues surrounding Decision Models
Retail Decision Models
12/01/10 4
Group Risk - Retail Risk
RDM Structure and Responsibilities
H e a d o f
R e t a i l D e c i s i o n M o d e ls
J a m e s M a r i n o p o u l o s

S e n i o r S e n i o r S e n i o r
D e c i s io n M o d eD l e M c ia s n i o a n g eM r o d S e y l s M t e a m n sa g A e s r s u r a n c e M a n a g e
( D e v e l o p m e n t s ( )V a l i d a t i o n s )
Q u y e n P h a m - N N g i uc hy eo nl a s Y a n n Gi o sr a e m e J u d d

G r a d u a t e M a n a g e r
J a n e t L o n g D e c i s i o n M o d e l V a l i d a t i o n
K a t h y Z o v k o

M a n a g e r
D e c i s i o n M o d e l M o n i t o r i n g
V a l e n t i n a D r a g a n

G r a d u a t e
M a r i a D e m e t r i o u

Relationship Ongoing Validations Systems


Developments Monitoring
Change Requests Data Analysis

Retail Decision Models


12/01/10 5
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 6
Group Risk - Retail Risk
What is credit scoring?
■ A statistical means of providing a quantifiable risk factor for a given
customer or applicant.
■ Credit scoring is a process whereby information provided is converted into
numbers that are added together to arrive at a score. (“Scorecard”)
■ The objective is to forecast future performance from past behaviour.
■ Credit scoring developed by Fair & Isaac in early 60s
– Widespread acceptance in the US in early 80s and UK early 90s
– FICO scores make 75% of US Mortgage loan decisions
– Behavioural scoring accepted as more predictive than application
scoring
■ Decision Models are used in many areas of industries:
– Banking and Finance
– Insurance
– Retail
– Telecommunications

Retail Decision Models


12/01/10 7
Group Risk - Retail Risk
Application Scoring
■ Application scoring is a statistical means of assessing risk at the point of
application for credit
– The application is scored once
■ Application scoring is used for:
– Credit risk determination
– Loan amount approval
– Limit setting

Credit
Decision

Retail Decision Models


12/01/10 8
Group Risk - Retail Risk
Behavioural Scoring
■ Behavioural scoring is a statistical means of assessing risk for existing customers
through internal behavioural data
– Customers/accounts scored repeatedly
■ Behaviour scoring is used for:
– Authorisations
– Limit increase/overdraft applications
– Renewals/reviews
– Collection strategies

Debit $1344. 12
Debit $234.
Debit $1344.
01 12
Debit $234.
Debit
Debit
$1344. 12
$987.56 01
Risk
Debit $234. 01
Debit $6543.22
$987.56
Debit Grading
Debit $6543.22
Debit $987.56
Debit $32423.11
Debit$32423.11
Debit $6543.22
Total $2556.00
Debit
Total $32423.11
$2556.00
Total $2556.00

Retail Decision Models


12/01/10 9
Group Risk - Retail Risk
Sample scorecard characteristics
■ Characteristics used in scorecards are similar to those used in
traditional judgemental lending, e.g.:

 Application  Financial
 Purpose of loan  Assets
 Deposit  Liabilities
 Security  Monthly repayment
 Total Monthly income

 Bureau Character
 No. of bureau defaults  Time at current employment
 Adverse ANZ behaviour  Residential status
 Time at current address

■ The difference being that attributes within these characteristics are given
formal weights (scores) and added to produce a resulting score
Retail Decision Models
12/01/10 10
Group Risk - Retail Risk
Scorecard points (example)
Residential status
Owner Renter LWP/Other
+25 -30 +10

Time in employment (years)


<2 3-4 5-6 7+
2 10 15 25

Total monthly income


0 <$500 <$1000 <$1500 <$2000 <$3000 >$3000
0 15 25 31 37 43 48

Total defaults
No Defaults 1 2+
0 -70 -250

Retail Decision Models


12/01/10 11
Group Risk - Retail Risk
Other Types of Scoring
■ Attrition
■ Authorisations
■ Recovery
■ Response
■ Profitability
■ Customer

Retail Decision Models


12/01/10 12
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 13
Group Risk - Retail Risk
Good/Bad Odds
■ A scoring system does not individually identify a good performer from a
bad performer, it classifies an applicant in a particular “Good/Bad odds”
group.
■ An applicant belonging to a 200 to 1 group, appears pretty safe and
profitable.
■ If the applicant belongs to a 4 to 1 risk group, we would no doubt find
the risk unacceptable.
■ There is a “cut-off” point where it is not profitable for the bank to accept
a certain Good to Bad ratio
■ Based on the above, it is accepted that there will be some “bads” above
the cut-off level set, and some “goods” below the cut-off level set.

Retail Decision Models


12/01/10 14
Group Risk - Retail Risk
'Good/Bad' Discrimination
■ The objective of a scorecard is to have characteristics which
discriminate between Good and Bad accounts with a sufficiently
high probability.
– Some characteristics are legally or ethically not used
■ The score will be a measure of the probability of being a Good or
Bad performer.
■ If the scorecard is performing well then the average scores of ‘Bads’
are lower than the average scores of the ‘Goods’.
Goods
Number
Of Clients

Bads
120

160

240

280

360

440

480

560

600

680

720

760

800
200

320

400

520

640
40

80
0

Score

Retail Decision Models


12/01/10 15
Group Risk - Retail Risk
Performance Charts
Goods
Number
Of Clients
■ The Good/Bad Odds at
each score can be 8
determined and plotted
onto a Performance chart Bads

40
0

80

120

160

200

240

280

320

360

400

440

480

520

560

600

640

680

760

800
720
Score

16400 14
Graph 2 - Log Odds Performance Chart
12
3250
10
645
Good/Bad Odds

Log GBOs (Base 2)


8
128
6

25 3
2 to 1 4
8 to 1
5 2

0 0
0

40

80

120

160

200

240

280

320

360

400

440

520

560

640

680

720

760
480

600

800
Retail Decision Models
12/01/10 16
Group Risk - Retail Risk
Application Scorecard Construction
Flow Chart
Outsourcing
Data Integrity •External Data Source
•Product Identification •Scorecard Vendor
•File Data Availability
•Sampling
•Data Extraction/Cost Generic Scorecard

Statistical Analysis Validation


•Characteristic Analysis
•Multivariate model build Set cut-off Score
•Reject Inference

Implementation
Customised Scorecard
Scorecard Monitoring
Retail Decision Models
12/01/10 17
Group Risk - Retail Risk
Model Build
■ Once the characteristics have been selected a statistical
model can be developed.
■ Multivariate statistical methods include
– Logistic Regression
– Stepwise methods
– Residual analysis
■ Not all predictive characteristics are used in the model.
– An inter-correlation effect may exist between variables.
– For example, age may be correlated with time at current
employment and therefore only one is necessary in the model.

Retail Decision Models


12/01/10 18
Group Risk - Retail Risk
Models
■ Expert Systems
■ Decision Trees
■ Linear Regression
■ Logistic Regression has the following form:

 p 
 = ∑ j =0 β j x j
k (
exp ∑ j =0 β j x j
k
)
ln

1− p 
Neural Networks
p=
(
1 + exp ∑ j =0 β j x j
k
)

Retail Decision Models


12/01/10 19
Group Risk - Retail Risk
Model Build
■ The model is built on dichotomous data. In this case a 1 for “Good”
customers and a 0 for “Bad” customers.
1

0.8

0.6

0.4

0.2

0
0 200 400 600 800 1000

Retail Decision Models


12/01/10 20
Group Risk - Retail Risk
Logistic Regression
■ The logistic regression fits the probability better than Linear
regression.
1

0.8

0.6

0.4

Good/Bad Probability
0.2 Logistic
Linear (Good/Bad Probability)

0
0 200 400 600 800 1000

Retail Decision Models


12/01/10 21
Group Risk - Retail Risk
Reject Inference and Validation
■ Reject Inference
– Reject Inference is only necessary for scorecards were there is no
performance information for rejected applications
• Applications that are rejected must be included in the final model.
– Behavioural scorecards deal only in existing customers, therefore
do not require reject inference.
■ Validation
– A randomly selected control group (hold out sample) or proxy
portfolio to test the model.

Retail Decision Models


12/01/10 22
Group Risk - Retail Risk
Measures of discrimination
■ Receiver Operating Curve (ROC)
– The Receiver Operating Curve is the area under the curve generated when
the cumulative Bads are plotted against the cumulative goods (Lorenz Curve).
■ Gini coefficient (G)
– This discrimination measure is geometrically defined as the ratio of the area A
of the shaded semi-circular area to the area B of the triangle in the Lorenz
diagram.

1
ROC = (G + 1)
2
■ PH (percentage Good for 50% Bad)
– This is defined as the cumulative proportion of Goods up to the median value
of the Bads.

12/01/10
Retail Decision Models Gini.xls 23
Group Risk - Retail Risk
Measures of discrimination – (I)
• Scorecard performance can be Lorenz C urve

judged on the level of 1

0.9
discrimination 0.8

• Two measure that can be used are: 0.7


Gini=0.62%

Cumulative Bads
Gini (or ROC)
0.6

0.5

PH - % of Goods below 50% 0.4

of bads 0.3

0.2
• 1% of PH could mean an additional 0.1

3% approvals 0
0 0.2 0.4 0.6 0.8 1

• 1% of PH could mean an reduction 10%


Cum ula tive Goods
of 0.2% bad debts

Retail Decision Models


12/01/10 24
Group Risk - Retail Risk
Measures of discrimination –(II)
■ Discrimination measures should be determined for discrete
attributes 2
(Obs − Exp)
– Chi-Squared ∑ Exp

 Gi 
– Fico (Kullback Divergence)100∑ (Gi − Bi ) ln 
 Bi 
Based on a book by Solomon
Kullback
“Information Theory and Statistics”

Retail Decision Models


12/01/10 25
Group Risk - Retail Risk
Issues for Successful Implementation
■ Cultural Change
■ Requires top management support
■ Operational process
– Redesign to minimise manual intervention and maximise cost
savings.
■ Data Integrity
– Quality of the overall decisions, and subsequently the Portfolio, is
dependant upon the accuracy of the data input. The first time!
■ Setting the Cut-off score correctly

Retail Decision Models


12/01/10 26
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 27
Group Risk - Retail Risk
Business Objectives
■ Increase consistency of lending decisions
– Consistent & unbiased treatment of applicant
• Customers with the same details get the same score
– Total management control over credit approval systems
• Allows for loosening or tightening of lending through credit cycles
• Potential increase in approvals
■ Reduce operating costs
– Increase in automated processing
■ Improve customer service
– Fast and consistent decisions at application point
– More appropriate limit and authorisation decisions
– Reduction in collection actions on low risk accounts
– Risk based allocation of credit limits and issue terms

Retail Decision Models


12/01/10 28
Group Risk - Retail Risk
Business Objectives (cont)
■ Improved portfolio management
– Manage credit portfolios more effectively and dynamically
• Better prediction of credit losses
• Management ability to react to changes fast & accurately
• Ability to measure & forecast impact of policy decisions
• Quick and uniform policy implementation
– Improved Management Information Systems (MIS)
• Permits MIS to be developed to assist business needs and marketing
activities
• MIS can be fed back into future scorecard developments and collection
activities

Retail Decision Models


12/01/10 29
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 30
Group Risk - Retail Risk
World Banks
■ ANZ
■ European Banks
– Banking market in Europe is restructuring
– Banks are merging across country boundaries
■ UK bank visits
– Bank A - bank with many recent acquisitions
– Bank B - bank dealing with mainly credit cards
– Bank C - ex building society now owned by bank
– Bank D - large diverse bank
■ National Australia Bank

Retail Decision Models


12/01/10 31
Group Risk - Retail Risk
World Banks
UK Banks AUS Banks
M ortgages - Y Y - Y Y

Personal Loans Y - - Y Y Y

Current A ccounts Y - Y - Y Y

Credit cards Y - - Y Y Y

LM I - In House In H ouse - External External

Retail FU M ? £58b £47b £8b $100b+ $60b

? A pp Scrds
Scorecards 20 - 70 ? 50 (12)
1 Beh Scrds
U nder
Application scorecards N ew New New All All
Developm ent
Best 40% > 6 m onths on
B ehavioural scorecards Existing - Product Just Developed
Existing B ooks

Data Storage Adequate Good Good Good G ood A verage

B & W B & W B & W B & W Black (C redit Black (Credit


Bureau
(Equifax) (Equifax) (Experian) (Experian) Advantage) Advantage)

Scoring M odelling Staff 20+ 3 30+ ? 40+ 15


Retail Decision Models
12/01/10 32
Group Risk - Retail Risk
Bureaus
■ Fair Isaac is the main bureaus in USA
– “White” and “Black” data is supplied to and from all financial institution
■ Fair Isaac (Equifax) and Experian are the two main bureaus in UK
– “White” data is supplied to a financial institution if the supply to bureau
– Currently few banks supply and receive “white” data
• Mergers are leading most banks to look at this option
– Fair Isaac is trying to beat Experian in having bureau scores in the UK
• This is only possible when all banks supply “white” data
■ Credit Advantage is used in Australia
– Provides “Black” data only
– Linked with Decision Advantage (previously Equigen)
– Bureau scores used for ANZ Small Business
• We could use Dunn & Bradstreet for over $250k lending
■ Baycorp is used in New Zealand
– Provides “Black” data only
– Baycorp is also a collections agency
– NZ puts the smallest amount lost as a default
■ Baycorp and Credit Advantage have just merged

Retail Decision Models


12/01/10 33
Group Risk - Retail Risk
Credit Scoring & Bureaus Around the World
“We are not alone!”
Behavioural
Application Behavioural Scorecards - Customer
Data Collection/ Generic Scorecards Scorecards - Customer Relationship
Country No Scoring Centralisation Scorecards Only Product Based Based Management Bureau
UK W &B
U SA W &B
C anada W &B
So uth Africa BB
Spain BB
Australia BB
N ew Zealand BB
Italy BB
G erm an y BB
Fran ce -
B elg iu m -
C zech Rep ub lic -
Ho ng K on g BB
S in gapo re -
T h ailan d -
India -
K orea -
Leb an on -
Saudi Arab ia -
Retail Decision Models
12/01/10 34
Group Risk - Retail Risk
BASEL - The New Accord
■ The New Accord will give banks with sophisticated risk
management capabilities increased flexibility
■ More emphasis on bank’s internal measures of risk, supervisory
review and market discipline
■ Decision support technology has an important role to play
■ Incentivise better risk management
■ Data warehouses are fundamental to addressing many of the
requirements
■ SMB sector will be key The New Basel Capital Accord

■ More risk sensitive


■ Competitive equality

Pillar 1 : Pillar 2 : Pillar 3 : Market


Minimum capital Supervisory
discipline
requirement review
process
Retail Decision Models
12/01/10 Paul%20Russell%2013a[1] 35
Group Risk - Retail Risk
Pillar 1 : credit risk
■ Internal Rating Based (IRB) approach
– Foundation
• Bank sets Probability of Default (PD)
• Standard Exposure At Default (EAD)
• Standard Loss Given Default (LGD)
– Advanced
• Banks sets PD, EAD & LGD
■ Better recognition of credit risk mitigation techniques
■ Behavioural scoring
– Internal
– External
■ Data storage

Retail Decision Models


12/01/10 36
Group Risk - Retail Risk
Future direction of scoring
■ “Adaptive Control” first implemented 1985 in USA
– Champion/Challenger processes for determining actions based on scores
– Required 10 years to be widespread in US
■ Customer Relationship Management
– Profitability (NIACC)
– Attrition
– Propensity to Buy (Cross Sell)
– Life time revenue
■ Recovery scorecards
■ Operations Research Methods
– Simulation modelling

Retail Decision Models


12/01/10 37
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 38
Group Risk - Retail Risk
Monitoring Examples
■ 1. Operation Stability Reports
– The four types of front end monitoring reports:
1.1 Approval Statistics Report
1.2 Population Stability Report
1.3 System Rules Referral Report
1.4 Portfolio Statistics Report
– Operational statistics can be obtained as soon as an automated
decision process is implemented
– Early warning indicators of decision functionality error and
scorecard validity
– Should be produced by Business Units or MIS

Retail Decision Models


12/01/10
Group Risk - Retail Risk
Loan Approval/Declines by Score
Approva/Declinal Rates by Score

100%
Auto Declined
90% Manually Declined
Manually Approved
80% Auto Approved

70%
Percentages

60%

50%

40%

30%

20%

10%

0%
<=500

>1000
751-800

801-850
501-550

551-600

601-650

651-700

701-750

851-900

901-950

951-1000
Score Bands
Retail Decision Models
12/01/10 40
Group Risk - Retail Risk
Population Stability
■ Compare each characteristic and attribute
– over time
– against benchmarks
■ Plot score distributions over time for potential change
■ Indicates potential drift in performance
NO YES 90%
Population Stability
Dec-96 25% 75% Dec-96
80%
Mar-97 23% 77% Mar-97
Jun-97
Jun-97 24% 76% 70% Sep-97
Dec-97
Sep-97 22% 78% Mar-98
60%
Dec-97 21% 79% Jun-98
Sep-98
Mar-98 19% 81% 50% Dec-98
Mar-99
Jun-98 19% 81% Jun-99
40% Sep-99
Sep-98 22% 78% Dec-99

Dec-98 20% 80% 30%

Mar-99 20% 80%


20%
Jun-99 18% 82%
Sep-99 18% 82% 10%

Dec-99 17% 83%


0%
Benchmarks 29% 71% NO YES
Retail Decision Models
12/01/10 41
Group Risk - Retail Risk
Monitoring Requirements
■ 2. Performance Analysis
– The two types of back end monitoring are:
2.1 Scorecard Performance Report
2.2 Characteristic Analysis Report
2.3 Dynamic Delinquency Report
– Performance Analysis is undertaken once a certain level of
customer maturity has been established
– Should be produced by BU and Group Risk

Retail Decision Models


12/01/10
Group Risk - Retail Risk
Loans - Approval & Delinquency Rates
% Approved (LHS)
Loans Approval & Delinquency Rates
Delinquency Rates (RHS)

100% 25%
90%

Delinquency Rates
80% 20%
Approval Rates

70%
60% 15%
50%
40% 10%
30%
20% 5%
10%
0% 0%
1-300 301- 351- 401- 451- 501- 551- 601- 651- 701- 751- >800
350 400 450 500 550 600 650 700 750 800

Score

 Even with manual assessment below the cut-off score of 350 the
delinquency rates are higher
Retail Decision Models
12/01/10 43
Group Risk - Retail Risk
Scorecard Performance
■ Scorecard performance based on 30+ delinquency
– Good/Bad odds increase as expected by score
Non Delinq
Delinq
Score Distribution & G/B Odds
HL GB Odds

4000 40.0

3500 35.0

3000 30.0

2500 25.0

2000 20.0

1500 15.0

1000 10.0

500 5.0

0 0.0

951-1000
551-600

701-750

851-900
501-550

601-650

651-700

751-800

801-850

901-950

>1000
<=500

Score
Retail Decision Models
12/01/10 44
Group Risk - Retail Risk
Presentation Topics
Overview of
Overview of scoring
scoring

ScorecardModelling
Scorecard Modelling

Business Objectives
Business Objectives

WorldBanks
World Banks

Monitoring
Monitoring

FutureDirection
Future Direction

Retail Decision Models


12/01/10 45
Group Risk - Retail Risk
Future Direction
■ Modelling
■ Experimental Design
– Champion/Challenger Strategies
– Hypothesis testing (uni & multi- dimensional)
■ Quality Control Techniques
– Control Charts
■ Operations Research
– Optimisation techniques
– Simulation Models
– Stress Testing

Retail Decision Models


12/01/10 46
Group Risk - Retail Risk
Conferences
■ Fair Isaac and Experian are the two main credit scoring companies world wide
■ Fair Isaac (Every year, alternating in Europe and USA)
– Main bureau and FICO Scores in USA
– Equifax in UK
– Systems included TRIAD
– Conference was mainly selling FICO products and systems (but also Technical)
■ Experian (Every year, in Europe)
– Formerly CCN
– Systems include Transact and Hunter
– Conference on world wide banking, financial, telecommunications and predictive
modelling usage (Business and/or Management)
■ University of Edinburgh (Every 2 year in Edinburgh)
– Very technical academic papers
– Proposal to run alternate years in a USA university

Retail Decision Models


12/01/10 47
Group Risk - Retail Risk
Three Portfolio Dimensions:
Volume, Loss, and Profit
Low
high cutoffs
E [ Volume ]

High
cutoffs

low

high
Retail Decision Models
12/01/10 48
Group Risk - Retail Risk
Efficient Frontiers in two dimensions
0.6
Low
Cutoffs

0.6
E[Loss] OP

High
Cutoffs OP
E[Profit]

0.0
0.2 E[Volume] 0.9
0.6
Low High Low
Cutoffs Cutoffs Cutoffs
0.2
0.2 E[Volume] 0.9
E[Loss]

OP
Efficient Frontier
High
Cutoffs
0.0 12/01/10 Retail Decision Models
49
0.2 E[Profit] 0.6
Group Risk - Retail Risk
Improved portfolio performance
0.6
Low
Single Score Cutoffs

0.6
E[Loss] OP Combined
Scores
High
Cutoffs OP
Combined
E[Profit]
Scores Single Score
0.0
0.2 E[Volume] 0.9
0.6
Low High Low
Cutoffs
Combined Cutoffs Cutoffs
Scores 0.2
0.2 E[Volume] 0.9
E[Loss]
Single Score
OP
Efficient Frontier
High
Cutoffs
0.0 12/01/10 Retail Decision Models
50
0.2 E[Profit] 0.6
Group Risk - Retail Risk
Best Practices
■ Combining Application & Behavioural scores (Bayesian estimates)

s
t
Reject set with
combined scores

Accept set with


combined scores

Equal- odds
line ω c (s, t)
Retail Decision Models
12/01/10 51
Group Risk - Retail Risk
Other Techniques
■ Customer Relation Management
■ Survival Analysis
■ Multiple Indicator Multiple Cause

Proportional Hazards.ppt
Measuring Customer Quality.doc
Retail Decision Models
12/01/10 52
Group Risk - Retail Risk

You might also like