2025 ModelBank FHB
2025 ModelBank FHB
Financial institution
© Celent 2
Detailed Description
Celent Perspective
In a major digital transformation project for retail lending, First Hawaiian Bank implemented a new
AI/ML loan scoring model and custom data to bring more loan applicants into its approvable credit box.
This automated underwriting system drove loan growth and gained operating efficiency by dramatically
reducing manual underwriting. Deploying a custom credit model, coupled with process redesign to
integrate it with the Bank’s loan origination system, increased FHB loan application approvals in
previously un-scorable populations.
First Hawaiian Bank:
● Is one of the first regional banks in the US to build an AI/ML automated loan underwriting
platform for consumer lending that expands its addressable market and originations.
● Implemented the platform for credit card underwriting to test the model with a lower balance
loan product attractive to a broad customer segment.
● Created an on-premises data lake to manage expanded customer, transaction, and product data.
FHB is now building a cloud-based data storage capability on Snowflake integrated with its
cloud-based AI/ML models.
● Automated the underwriting of 95% of credit card applications not otherwise reviewed for
Fraud, OFAC, or other high-risk characteristics and increased loan approval rates to 65%.
● Is developing AI/ML models for consumer loans, consumer lines of credit, and indirect auto loan
products that are planned to launch in 2025.
© Celent 3
Detailed Description
Detailed Description
First Hawaiian Bank (FHB or “the Bank”), founded in 1858, is Hawaii’s oldest and
largest financial institution. The bank has 48 branches throughout Hawaii, three in
Guam, and one in Saipan, serving one of the most demographically diverse
regions in the United States. Like in many areas of the U.S., a significant number of
applicants face challenges to accessing credit products due to having no credit file
or a limited ‘thin’ credit file.
As the sole local bank issuer of credit cards, First Hawaiian Bank is the market leader in Hawaii, Guam,
and Saipan. However, because the Bank maintains a conservative credit risk profile, it has historically
been limited in its ability to approve applicants due to the limitations of legacy tools and corresponding
underwriting methodology. By increasing approval rates 35% without a deterioration in credit quality,
this initiative enabled the Bank to reach more people while remaining within its risk appetite and
ultimately better serving its constituents without placing depositors or shareholders at increased risk.
Opportunity
Reliance on traditional credit bureau scoring methods and manual end-to-end applicant processes did
not support sustainable loan growth in terms of scalability or risk measurement accuracy. FHB led with
the data-rich, AI/ML-underwritten consumer credit card product as a test case to provide inclusive,
automated loan underwriting. The new AI-driven process transformed the historically opaque and
manual underwriting process into a largely automated, score-based decision. This initiative is the first
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Detailed Description
major leg of multiple initiatives to re-engineer FHB customers’ end-to-end loan origination experience,
from loan application intake, know-your-customer (KYC) fraud checks, underwriting, approval, to loan
booking.
The top challenges that FHB looked to address included:
● Legacy scoring model: FHB’s standard licensed credit bureau score was a legacy version
originally launched in 2004 and focused on mortgage lending. FHB found that it could not make
accurate card credit decisions based on score alone and began to rely heavily on the manual
analysis of credit report data to make decisions.
● Traditional model limitations: To control for limitations in its legacy credit bureau model, FHB
applied additional underwriting policy controls as pass/fail criteria, such as excluding customers
with bankruptcies or delinquencies. Manual analysis was restrictive as only one control failure
could trigger a loan application decline, regardless of the trend of the total customer credit file.
● Dependence on manual processes: Without an updated scoring methodology, underwriters
manually examined virtually all applications, with an “instant” decisioning rate of under 10%.
● Restricted lending growth: The lack of custom models to address the geographically and
demographically diverse Hawaii and Oceania populations and the aged legacy scoring model led
to loan application approval rates under 40%.
● Model development resource constraints: FHB’s internal data science team estimated that
building an in-house custom scoring model would take 18–24 months, would have “blind spots”
from utilizing bank-only data, and would delay the execution of competing FHB business and
technology priorities.
FHB decided that AI/ML models were the best path to improve the accuracy of credit risk scoring and
underwriting, with additional non-FHB elements to increase automation by reducing additional
underwriting policy controls. The models and processing technology solution needed to be accurate,
efficient, and compliant while requiring little to no in-house IT staff support.
FHB estimated that expanding access to previously un-scorable credit card applicants could drive a 20%
to 50% increase in credit application approval rates without requiring the bank to accept additional
credit risk. In addition, process automation would reduce manual processing. The Consumer Products
Division sponsored the initiative to support a strategy for the lending business to scale efficiently as
credit applications increased by reducing manual loan underwriting dependencies.
Solution
First Hawaiian Bank decided to partner, not build, an AI/ML credit model analytics and decisioning
system. It then integrated the model with its loan origination system.
Solution Partners
FHB partnered with Zest AI, a pioneer in AI lending technology since 2009, to develop a custom
underwriting solution for the credit card portfolio (the “Consumer Credit Cards model”). Zest AI holds
over 50 patents issued and pending and has a strong relationship with US regulators. By partnering with
Zest AI, the Bank mitigated potential AI project pitfalls of optimizing for the wrong metrics, insufficient
data to support model training, and the requirement to commit a data scientist team for at least a year.
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Detailed Description
Zest AI provided the AI-automated underwriting solution, professional services, additional data, and
modeling expertise. They developed a machine learning model using tens of millions of data points
derived from almost half a million borrowers and credit bureau data representative of the Hawaii, Guam,
and Saipan geographies. The custom model was trained on 256 data features to create a custom model
for FHB’s unique customer base.
● AWS provides private cloud hosting of the credit card scoring model, which Zest AI manages for
FHB. Banks frequently opt for private clouds over public clouds due to the desire for enhanced
security of systems and sensitive financial data, control and customizable security, and
compliance with regulatory requirements. There were no other changes to other existing FHB
on-premise and cloud solutions during this initial phase.
● MeridianLink is FHB’s loan origination system provider. FHB uses MeridianLink Consumer
(formerly known as LoansPQ). MeridianLink worked with FHB and Zest AI to create a two-way
integration between the LOS and Zest AI. Zest AI and MeridianLink have an ongoing multi-client
relationship, which reduces engineering needs and integration costs for FHB and other banks.
The LOS was also modified to return (display) Zest AI model results that are different from credit
score-based decisions. FHB stores input and output data in the LOS and in an on-premises FHB
data mart.
● TSYS is the credit card payment processor used by FHB. TSYS provides digital engagement
platform solutions, account information, and statements, and is the Bank’s solution for card
payment authorization, posting, and settlement.
● FIS is FHB’s core system provider. FHB uses IBS Loans as the system of record for consumer, small
business, and commercial loans/lines of credit.
In addition, Sharefile is used to facilitate secure sharing of model development data and ongoing
production reporting. Tableau was used to develop executive and risk-monitoring dashboards based on
existing FHB data marts.
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Detailed Description
Figure 1 is a high-level overview of the main processes and vendors comprising FHB’s loan origination
and automated underwriting platform. Loan applicants submit their application to the bank via any
point-of-sale (mobile, internet, or branch) channel. The point-of-sale (POS) system transmits the data to
the LOS, which then pulls credit bureau data and scores and transmits this information to Zest AI.
Figure 1: First Hawaiian Bank – New Loan Origination and Underwriting Platform Overview
The Zest AI model analyzes the bureau data, generates custom risk scores, and sends the scores and key
factors (i.e., credit score attributes1) to the LOS, which returns an underwriting decision or other action
to the loan applicant through FHB’s digital channels.
1
Credit score attributes, or factors, are information used to assess a person’s creditworthiness and determine their likelihood of
repaying a loan. Attributes are used to calculate a credit score. Typical credit score attributes include payment history, amounts
owed, length of credit history, new credit, and types of credit.
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Detailed Description
Figure 2: First Hawaiian Bank – New Loan Processing and Decisioning Environment
Automated declines reduce human underwriter time spent on rejecting loan applications that don’t
generate revenue. Automated approvals also reduce human underwriter time on approved loans to
increase operating margin efficiency.
Second, automation enabled FHB to create new auto-decisioning thresholds based on AI/ML risk scores
and credit policy guidelines. The bank periodically reviews the thresholds and can quickly increase or
decrease them as needed.
Third, the system also gave FHB the flexibility to evaluate credit applications in the gray area of credit
policy, where most policy requirements are met but one or two fail. The system refers the application to
a human underwriter for further review and approval on an exception basis.
Finally, FHB was able to retain the use of FICO as a benchmark and in-house scores, including pre-existing
analytics such as in-house “propensity to apply” scores.
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Detailed Description
2
SR 11-7 is Supervisory Guidance on Model Risk Management issued by the US Federal Reserve Board and the Office of the
Comptroller of the Currency (OCC).
3
A "thin file" or “no file” credit report means a person has little to no credit history and insufficient data to generate a credit
score. This can be due to a lack of credit accounts, a short history of credit usage, or credit activity that hasn’t been reported to
the credit bureaus.
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Detailed Description
Zest AI and bank test data showed potential loan approval rate increases ranging from 35% to 47%, with
no deterioration in credit risk performance.
Critically, while many AI/ML model providers offer to incorporate broad selections of data to improve
model prediction accuracy, they put the onus on the financial institution (FI) to extract, prepare, and
deliver that data. Zest’s broad approach—from leveraging data already resident in a credit report to
building mature and explainable approaches to fair lending and regulatory compliance
concerns—demonstrated a clear understanding of the pressures that FIs face in integrating new
technologies, and were as essential as the technology in achieving adoption at FHB.
Implementation
The internal First Hawaiian Bank team included experts from six cross-functional bank divisions:
1. Consumer Credit & Originations: Project management and implementation
2. Enterprise Data & Analytics: Model due diligence and testing
3. Analytics Risk Management: Model documentation review and monitoring
4. Credit Administration Division: Credit strategy review and approval
5. Consumer Compliance: Fair lending and regulatory review
6. Consumer Products Division: Use case and product expertise
The internal team ensured that the solution satisfied a spectrum of FHB requirements including
expeditious implementation, low supporting resources required, model efficacy, and robust compliance
documentation. FHB’s involvement was heaviest during the model development, review, and approval
process. The team also created a framework for implementation across bank products and set standards
for documentation. The team remains involved for quarterly model performance and monitoring
meetings.
With respect to credit policy, AI/ML analytics is a first for FHB and required a considerable shift in the
existing application and approval strategies used. They rebuilt the underwriting process to maximize the
model’s potential benefits while remaining within established risk appetite limits. This delivered benefits
for customers, staff, and shareholders while maintaining the confidence of FHB’s regulator and board of
directors. The project required FHB Credit Committee approval of product-specific underwriting
adjustments that would allow for risk-conscious capture of a financially viable (expected revenue and
profit) portion of the estimated approval rate uplift.
Implementation Timeline
Outsourcing the AI/ML model development, data management, and private cloud hosting enabled First
Hawaiian Bank to put the system into production quickly. The project went from kick-off to launch with
no financial outlay required by FHB until production launch. Excluding due diligence and vendor selection
prior to development, the project was completed in six months from kick-off to launch, versus an
estimated 18–24 months to build an in-house custom credit risk scoring model.
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Detailed Description
Starting in March 2023, the Bank completed vendor contracting, project planning, data requirements
and collection, and custom AI modeling. Starting in June 2023, they finalized the model (deployment,
testing, and refinement), integration to the LOS, final testing, and management sign-off. In October 2023,
AI-automated decisioning went live, followed by post-production monitoring and performance
evaluation. The first quarterly business review with FHB and Zest AI was held in February 2024, and the
first annual business review was held in October 2024.
Results
The solution has been in production for just over one year, with annual results as of the third quarter of
2024. Project benefits began immediately at production launch as credit card loan application approval
rates began increasing and continued increasing as loan application volume increased. The scalability
and client experience benefits from increased instant decisioning also increased return from the project,
but were not quantified.
Credit Decisioning Automation Results
Most FHB credit card applicants can now receive instant decisions at their chosen touch point: online,
in-branch, or via phone. Ninety-five percent of all applications not otherwise reviewed for fraud, Office
of Foreign Assets Control (OFAC) regulations, or other high-risk characteristics benefited from the new
process. FHB increased instant (automated) decisioning (for both approved and declined loan
applications) to 55% after one year (October 2023 – September 2024), a thirteenfold increase from 4%
(Figure 3). Automated approvals reached 40% of loan applications at the same time.
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Detailed Description
Figure 3: First Hawaiian Bank Dramatically Increases Automated Underwriting with AI/ML
The system also enabled FHB to instantly decline loans. This reduced human underwriter time spent on
loan applications that don’t generate revenue and worsen operating margin. Instant declines rose from
zero to 14% in September 2024. These automated decisioning rates continue to remain stable over time.
Figure 4 shows overall (manual and automated) approval rates during the same time period. Overall
underwriter approvals increased strongly from 48% to 65% in September 2024 as the combination of
improved scoring penetration into FHB’s borrower population and unlocked underwriter capacity
allowed for focus on decisions where judgement matters, rather than on repetitive manual processes.
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Detailed Description
Figure 4: First Hawaiian Bank Increases Credit Card Loan Approval Rates with AI/ML
The AI/ML system opened the credit box and gave FHB the analytical ability to review and approve some
loans on an exception basis, make a product/rate counteroffer, and/or appropriately price products
according to applicant credit risk.
An additional material benefit of a more accurate risk score is that it helps decline loans with indicators
that could presuppose an unacceptably high default rate, which would have been approved based on the
legacy scoring method. FHB observed a 7.2% “newly declined” population during model development,
which with some assumptions indicates annual avoided cost (everything else constant and assuming
default at 12 months) of $1MM+ (15,000 applications * 7.2% swap-out rate * 20% empirical default rate
* $5,000 median exposure at 12 months and a fully-drawn line). This is a large project benefit that FHB
will track in detail in 2026.
Lessons Learned
FHB’s Consumer Products Division built the initial proof-of-concept system using a one-time data
provision and a custom monitoring structure. This helped launch the solution, evaluate model
performance, and realize benefits quickly. However, the project would have benefitted from
centralization and curation of bank consumer data; planning for this is underway. Newer centralized data
management, data curation, and analytics activities will facilitate expansion of the system to other loan
product types.
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Detailed Description
Additionally, the project required close collaboration with multiple bank divisions. Maturation of FHB’s
due diligence and implementation processes for AI/ML and generative AI models can further improve
the speed of project implementation by providing different stakeholders with a template for approval.
Future Plans
The project is currently on track to increase division profitability by 15% within the project's five-year
pro-forma financial analysis period. Any unmodeled improvement in application volume, approval rate
uplift, or product-level profitability will increase project value into perpetuity as applicant cohorts age.
FHB began with consumer credit cards because they are easier to process and underwrite. Currently in
development is a Zest AI and FHB joint proposal to retrain the model with a new data source estimated
to provide an additional 3% uplift in loan approval rates, and to use project research to further adjust
underwriting requirements providing an additional 3% to 5% increase in approval rates.
AI/ML Underwriting for New Loan Products
The success of this initiative led First Hawaiian Bank to implement an IT road map through 2027 to
expand the number of loan products underwritten with AL/ML, improve the bank client experience,
enhance credit risk measurement, and further increase decision speed.
For example, scoring models for consumer loans and lines and indirect auto loan products will launch in
2025. Future consumer loan and line applications will be received through MeridianLink
Modern—converted from the current MeridianLink Classic—from direct mail, social media, and mobile
app channels. For indirect auto loans, MeridianLink is integrated with the Dealertrack4 channel. The
AI/ML system will provide score and decision support data directly into the LOS to allow FHB the
capability to scale its review process without adding additional staffing.
More accurate credit scoring will also allow for expanded counteroffers, cross-selling, or to adjust
product pricing based on credit risk. This capability further expands the product and credit box and
increases loan revenues.
Enhanced Data Management
Increased analytic modeling also necessitates improved data management. Data is currently stored in
three on-premises FHB data marts, organized by platform. On-premise data storage for a cloud-deployed
analytic solution is not the optimal long-term data solution for the project as it expands to additional
loan types and lending volume grows. FHB plans to enhance data management on Snowflake in late
2025 to ingest raw data directly from vendors, increasing the speed at which data is available and its
accuracy. The Snowflake AI Data Cloud is a cloud-based data management platform for storing,
managing, and analyzing data. Benefits include secure access to data, scalability, the ability to build and
deploy AI/ML applications, efficient data sharing across clouds and organizations, and a unified data
infrastructure.
4
Dealertrack is a web-based platform and dealer management system (DMS) that helps dealerships manage their business
operations and find financing for customers buying vehicles.
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Detailed Description
FHB also plans to adopt Zest AI’s LuLu Pulse solution. LuLu Pulse is a generative AI “lending intelligence
companion” that leverages public data from the National Credit Union Administration (NCUA) and the
Federal Financial Institutions Examination Council (FFEIC) in the US. These entities have bank and credit
union call report datasets to provide insights and answers to business and credit risk queries. LuLu Pulse
will answer general questions related to lending and industry insights, can answer credit risk queries, and
will enable searching and sharing of reports and model documentation linked to FHB’s Zest AI scoring
models.
Data management will also be enhanced to support this generative AI initiative. FHB will create
self-service public and private data stores to support the 2025–2026 phased LuLu Pulse portfolio
management and risk analysis initiative.
New Data Sources
For 2026, there are also plans to expand the data sources utilized by the existing credit scoring models to
further improve accuracy, to expand AI/ML scoring into small business loan products, and to integrate
LuLu Pulse with existing FHB portfolio data to enable dynamic portfolio management.
Outlook
These new data management and AI capabilities will help FHB reimagine the receipt and storage of
application and credit risk data as well as a rebuild of loan origination data management, modeling, and
loan processing across the bank’s consumer lending businesses. Legacy relational database storage will
migrate to the cloud, and curated loan product-level datasets will be created that support executive and
self-service dashboarding of key lending metrics. As First Hawaiian Bank expands the use of AI/ML credit
decisioning to other types of consumer loans, their performance metrics will also improve in those lines
of business.
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Detailed Description
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Detailed Description
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