Once a year, the SLOOS asks banks a different question: not how standards changed last quarter, but where they sit against the full range since 2005. In the July survey, more than half of banks put subprime card standards at the tight end of that twenty-year range, and between a fifth and a half said the same for subprime auto and other consumer loans. Far fewer reported tight levels for prime card and prime auto. Consumer was also the only loan category where standards were not easier than a year ago. Yet TransUnion's Q2 report, out Thursday, shows bankcard originations, which TransUnion reports a quarter in arrears, up 11.8% YoY led by subprime, and subprime personal loan originations up 29%.

CCM read:  The two are measuring different things. SLOOS asks 56 domestic banks who they will approve. TransUnion, counts what the whole market actually booked, banks and non-banks alike. Access is widening at the subprime end through lenders the survey never polls, and on the personal loan side through smaller loans rather than looser approval. Meanwhile the same Fed survey puts bank standards on loans to consumer credit intermediaries at the tight end of their post-2011 range, which is where much non-bank warehouse capacity sits. Growing subprime volume and a narrowing bank funding channel point the same direction: ABS.