All posts by Guest Contributor

By: Amanda Roth Doesn’t that sound strange: Pricing WITH competition?  We are familiar with the sayings of pricing for competition and pricing to be competitive, but did you ever think you would need to price with competition?  When developing a risk-based pricing program, it is important to make sure you do not price against the competition in any extreme.  Some clients decide they want to price lower than the competition regardless of how it impacts their profitability.  However, others price only for profitability without any respect to their competition.  As we discussed last week, risk-based pricing is 80 percent statistics, but 20 percent art -- and competition is part of the artistic portion. Once you complete your profitability analysis (refer to 12/28/2009 posting), you will often need to massage the final interest rate to be applied to loan applications.  If the results of the analysis are that your interest rate needs to be 8.0 percent in your “A” tier to guarantee profitability, but your competition is only charging 6.0 percent, there could be a problem if you go to market with that pricing strategy.  You will probably experience most of your application volume coming to an end, especially those customers with low risk that can obtain the best rates of a lender.  Creativity is the approach you must take to become more competitive while still maintaining profitability.  It may be an approach of offering the 6.0 percent rate to the best 10 percent of your applicant base only, while charging slightly higher rates in your “D” and “E” tiers. Another option may be that you need to look internally at processing efficiencies to determine if there is a way to decrease the overall cost associated with the decision process.  Are there decision strategies in place that are creating a manual decision when more could be automated?  Pricing higher than the market rate can be detrimental to any organization, therefore it is imperative to apply an artistic approach while maintaining the integrity of the statistical analysis. Join us next week to continue this topic of pricing with competition which is, again, an important consideration when developing a risk-based pricing program.  

By: Ken Pruett I thought it might be helpful to give an example of a recent performance monitoring engagement to show just how the performance monitoring process can help.  The organization to which I'm referring has been using Knowledge Based Authentication for several years. They are issuing retail credit cards for their online channel. This is an area that usually experiences a higher rate of fraud.  The Knowledge Based Authentication product is used prior to credit being issued. The performance monitoring process involved the organization providing us with a sample of approximately 120,000 records of which some were good and some were bad.  Analysis showed that they had a 25 percent referral rate -- but they were concerned about the number of frauds they were catching.  They felt that too many frauds were getting through; they believed the fraud process was probably too lenient. Based on their input, we started a detailed analytic exercise with the intention, of course, to minimize fraud losses.  Our study found that, by changing several criteria items with the set-up, the organization was able to get the tool to be more in-line with expectations.  So, by lowering the pass rate by only 9 percent they increased their fraud find rate by 27 percent.  This was much more in-line with their goals for this process. In this situation, a score was being used, in combination with the organization's customer's ability to answer questions, to determine the overall accept or refer decision.  The change to the current set-up involved requiring customers to answer at least one more question in combination with certain scores.  Although the change was minor in nature, it yielded fairly significant results. Our next step in the engagement involved looking at the questions. Analysis showed that some questions should be eliminated due to poor performance.  They were not really separating fraud; so, removing them would be beneficial to the overall process.  We also determined that some questions performed very well.  We recommended that these questions should carry a higher weight in the overall decision process.  An example would be that a customer be required to answer only two questions correct for the higher weighted questions versus three of the lesser performing questions.  The key here is to help keep pass rates up while still preventing fraud.  Striking this delicate balance is the key objective. As you can see from this example, this is an ongoing process, but the value in that process is definitely worth the time and effort.

We've recently discussed management of risk, collections strategy, credit attributes, and the like for the bank card, telco, and real estate markets. This blog will provide insights into the trends of the automotive finance market as of third quarter 2009.  In terms of credit quality, the market has been relatively steady in year-over-year comparisons.  The subprime group saw the biggest change in risk distribution from 3Q08, with a -3.74 percent shift. Overall, balances have declined to just over $673 billion (- 4 percent).  In 3Q09, banks held the largest total of outstanding automotive balances of $241 billion (with captive auto next at $203 billion).  Credit unions had the largest increase from 3Q08 (with $5 billion) and the finance/other group had the largest decrease in balances (- $23 billion). How are automotive loans performing?  Total 30- and 60-day delinquencies are still on the rise, but the rate of increase of 30-day delinquencies appears to be slowing.   New originations are dominating in the Prime plus market (66 percent), up by 10 percent.  Lending criteria has tightened and, as a result, we see scores on both new and used vehicles continue to increase.  For new buyers, over 83 percent are Prime plus.  For used buyers, over 53 percent are Prime plus.  The average credit score changed from 762 in 3Q08 to 775 in 3Q09 -- up 13 points for new vehicles.  For used vehicles in the same time period: 670 to 684, up 14 points. Lastly, let’s take a look at how financing has changed from 3Q08 to 3Q09.  The financed amounts and monthly payments have dropped year-over-year as well as the average term and average rate. Source:  State of the Automotive Finance Market, Third Quarter 2009 by Melinda Zabritski, director of Automotive Credit at Experian and Experian-Oliver Wyman Market Intelligence Reports    

By: Tom Hannagan Apparently my last post on the role of risk management in the pricing of deposit services hit some nerve ends. That’s good. The industry needs its “nerve ends” tweaked after the dearth of effective risk management that contributed to the financial malaise of the last couple of years. Banks, or any business, can prosper by simply following their competitors’ marketing strategies and meeting or slightly undercutting their prices. The actions of competitors are an important piece of intelligence to consider, but not necessarily optimal for your bank to copy. One question is regarding the “how-to” behind risk-based pricing (RBP) of deposits. The answer has four parts. Let’s see. First, because of the importance and size of the deposit business (yes, it’s a line of business) as a funding source, one needs to isolate the interest rate risk. This is done by transfer pricing, or in a sense, crediting the deposit balances for their marginal value as an offset to borrowing funds. This transfer price has nothing to do with the earnings credit rate used in account analysis – that is a merchandising issue used to generate fee income. Fees, resulting from account analysis, when not waived, affect the profitability of deposit services, but are not a risk element. Two things are critical to the transfer of funding credit: 1) the assumptions regarding the duration, or reliability of the deposit balances and 2) the rate curve used to match the duration. Different types of deposit behave differently based on changes in rates paid. Checking account deposit funds tend to be very loyal or “sticky” - they don’t move around a lot (or easily) because of rate paid, if any. At the other extreme, time deposits tend to be very rate-sensitive and can move (in or out) for small incremental gains. Savings, money market and NOW accounts are in-between. Since deposits are an offset (ultimately) to marginal borrowing, just as loans might (ultimately) require marginal borrowing, we recommend using the same rate curve for both asset and liability transfer pricing. The money is the same thing on both sides of the balance sheet and the rate curve used to fund a loan or credit a deposit should be the same. We believe this will help, greatly, to isolate IRR. It is also seems more fair when explaining the concept to line management. Secondly, although there is essentially no credit risk associated with deposits, there is operational risk. Deposit make up most of the liability side of the balance sheet and therefore the lion’s share of institutional funding. Deposits are also a major source of operational expense. The mitigated operational risks such as physical security, backup processing arrangements, various kinds of insurance and catastrophe plans, are normal expenses of doing business and included in a bank’s financial statements. The costs need to be broken down by deposit category to get a picture of the risk-adjusted operating expenses. The third major consideration for analyzing risk-adjusted deposit profitability is its revenue contribution. Deposit-related fee income can be a very significant number and needs to be allocated to particular deposit category that generates this income. This is an important aspect of the return, along with the risk-adjusted funding value of the balances. It will vary substantially for various deposit types. Time deposits have essentially zero fee income, whereas checking accounts can produce significant revenues. The fourth major consideration is capital. There are unexpected losses associated with deposits that must be covered by risk-based capital – or equity. The unexpected losses include: unmitigated operational risks, any error in transfer pricing the market risk, and business or strategic risk. Although the unexpected losses associated with deposit products are substantially less than found in the lending products, they needs to be taken into account to have a fully risk-adjusted view. It is also necessary to be able to compare the risk-adjusted profit and profitability of such diverse services as found within banking. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization, on a risk-adjusted performance basis. Otherwise it is impossible to decide on the allocation of resources, including precious capital. Without this risk management view of deposits (just as with loans) it is impossible to price the services in a completely knowledgeable fashion. Good entity governance, asset and liability posturing, and competent line of business management, all require more and better risk-based profit considerations to be an important part of the intelligence used to optimally price deposits.      

Meat and potatoes Data are the meat and potatoes of fraud detection.  You can have the brightest and most capable statistical modeling team in the world.  But if they have crappy data, they will build crappy models.  Fraud prevention models, predictive scores, and decisioning strategies in general are only as good as the data upon which they are built. How do you measure data performance? If a key part of my fraud risk strategy deals with the ability to match a name with an address, for example, then I am going to be interested in overall coverage and match rate statistics.  I will want to know basic metrics like how many records I have in my database with name and address populated.  And how many addresses do I typically have for consumers?  Just one, or many?  I will want to know how often, on average, we are able to match a name with an address.  It doesn’t do much good to tell you your name and address don’t match when, in reality, they do. With any fraud product, I will definitely want to know how often we can locate the consumer in the first place.  If you send me a name, address, and social security number, what is the likelihood that I will be able to find that particular consumer in my database?  This process of finding a consumer based on certain input data (such as name and address) is called pinning.  If you have incomplete or stale data, your pin rate will undoubtedly suffer.  And my fraud tool isn’t much good if I don’t recognize many of the people you are sending me. Data need to be fresh.  Old and out-of-date information will hurt your strategies, often punishing good consumers.  Let’s say I moved one year ago, but your address data are two-years old, what are the chances that you are going to be able to match my name and address?  Stale data are yucky. Quality Data = WIN It is all too easy to focus on the more sexy aspects of fraud detection (such as predictive scoring, out of wallet questions, red flag rules, etc.) while ignoring the foundation upon which all of these strategies are built.  

By: Ken Pruett The use of Knowledge Based Authentication (KBA) or out of wallet questions continues to grow. For many companies, this solution is used as one of its primary means for fraud prevention.  The selection of the proper tool often involves a fairly significant due diligence process to evaluate various offerings before choosing the right partner and solution.  They just want to make sure they make the right choice. I am often surprised that a large percentage of customers just turn these tools on and never evaluate or even validate ongoing performance.  The use of performance monitoring is a way to make sure you are getting the most out of the product you are using for fraud prevention.  This exercise is really designed to take an analytical look at what you are doing today when it comes to Knowledge Based Authentication. There are a variety of benefits that most customers experience after undergoing this fraud analytics exercise.  The first is just to validate that the tool is working properly.  Some questions to ponder include: Are enough frauds being identified? Is the manual review rate in-line with what was expected?  In almost every case I have worked on as it relates to these engagements, there were areas that were not in-line with what the customer was hoping to achieve.  Many had no idea that they were not getting the expected results. Taking this one step further, changes can also be made to improve upon what is already in place.  For example, you can evaluate how well each question is performing.  The analysis can show you which questions are doing the best job at predicting fraud.  The use of better performing questions can allow you the ability to find more fraud while referring fewer applications for manual review.  This is a great way to optimize how you use the tool. In most organizations there is increased pressure to make sure that every dollar spent is bringing value to the organization.  Performance monitoring is a great way to show the value that your KBA tool is bringing to the organization.  The exercise can also be used to show how you are proactively managing your fraud prevention process.   You accomplish this by showing how well you are optimizing how you use the tool today while addressing emerging fraud trends. The key message is to continuously measure the performance of the KBA tool you are using.  An exercise like performance monitoring could provide you with great insight on a quarterly basis.  This will allow you to get the most out of your product and help you keep up with a variety of emerging fraud trends. Doing nothing is really not an option in today’s even changing environment.  

By: Amanda Roth The reality of risk-based pricing is that there is not one “end all be all” way of determining what pricing should be applied to your applicants.  The truth is that statistics will only get you so far.  It may get you 80 percent of the final answer, but to whom is 80 percent acceptable?  The other 20 percent must also be addressed. I am specifically referring to those factors that are outside of your control.  For example, does your competition’s pricing impact your ability to price loans?  Have you thought about how loyal customer discounts or incentives may contribute to the success or demise of your program?  Do you have a sensitive population that may have a significant reaction to any risk-base pricing changes?  These questions must be addressed for sound pricing and risk management. Over the next few weeks, we will look at each of these questions in more detail along with tips on how to apply them in your organization.  As the new year is often a time of reflection and change, I would encourage you to let me know what experiences you may be having in your own programs.  I would love to include your thoughts and ideas in this blog.  

By: Tom Hannagan This blog has often discussed many aspects of risk-adjusted pricing for loans. Loans, with their inherent credit risk, certainly deserve a lot of attention when it comes to risk management in banking. But, that doesn’t mean you should ignore the risk management implications found in the other product lines. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization. This would include the deposit services arena. Deposits make up roughly 65 percent to 75 percent of the liability side of the balance sheet for most financial institutions, representing the lion’s share of their funding source. This is a major source of operational expense and also represents most of the bank’s interest expense. The deposit activity has operational risk, and this large funding source plays a huge role in market risk – including both interest rate risk and liquidity risk. It stands to reason that such risks are considered when pricing deposit services. Unfortunately it is not always the case. Okay, to be honest, it’s too rarely the case. This raises serious entity governance questions. How can such a large operational undertaking, not withstanding the criticality of the funding implications, not be subjected to risk-based pricing considerations? We have seen warnings already that the current low interest rate environment will not last forever. When the economy improves and rates head upwards, banks need to understand the bottom line profit implications. Deposit rate sensitivity across the various deposit types is a huge portion of the impact on net interest income. Risk-based pricing of these services should be considered before committing to provide them. Even without the credit risk implications found on the loan side of the balance sheet, there is still plenty of operational and market risk impact that needs to be taken into account from the liability side. When risk management is not considered and mitigated as part of the day-to-day management of the deposit line of business, the bank is leaving these risks completely to chance. This unmitigated risk increases the portion of overall risk that is then considered to be “unexpected” in nature and thereby increases the equity capital required to support the bank.

By: Wendy Greenawalt Given the current volatile market conditions and rising unemployment rates, no industry is immune from delinquent accounts. However, recent reports have shown a shift in consumer trends and attitudes related to cellular phones. For many consumers, a cell phone is an essential tool for business and personal use, and staying connected is a very high priority. Given this, many consumers pay their cellular bill before other obligations, even if facing a poor bank credit risk. Even with this trend, cellular providers are not immune from delinquent accounts and determining the right course of action to take to improve collection rates. By applying optimization, technology for account collection decisions, cellular providers can ensure that all variables are considered given the multiple contact options available. Unlike other types of services, cellular providers have numerous options available in an attempt to collect on outstanding accounts.  This, however, poses other challenges because collectors must determine the ideal method and timing to attempt to collect while retaining the consumers that will be profitable in the long term.  Optimizing decisions can consider all contact methods such as text, inbound/outbound calls, disconnect, service limitation, timing and diversion of calls.  At the same time, providers are considering constraints such as likelihood of curing, historical consumer behavior, such as credit score trends, and resource costs/limitations.  Since the cellular industry is one of the most competitive businesses, it is imperative that it takes advantage of every tool that can improve optimizing decisions to drive revenue and retention.  An optimized strategy tree can be easily implemented into current collection processes and provide significant improvement over current processes.

By: Heather Grover In my previous entry, I covered how fraud prevention affected the operational side of new DDA account opening. To give a complete picture, we need to consider fraud best practices and their impact on the customer experience. As earlier mentioned, the branch continues to be a highly utilized channel and is the place for “customized service.” In addition, for retail banks that continue to be the consumer's first point of contact, fraud detection is paramount IF we should initiate a relationship with the consumer. Traditional thinking has been that DDA accounts are secured by deposits, so little risk management policy is applied. The reality is that the DDA account can be a fraud portal into the organization’s many products. Bank consolidations and lower application volumes are driving increased competition at the branch – increased demand exists to cross-sell consumers at the point of new account opening. As a result, banks are moving many fraud checks to the front end of the process: know your customer and Red Flag guideline checks are done sooner in the process in a consolidated and streamlined fashion. This is to minimize fraud losses and meet compliance in a single step, so that the process for new account holders are processed as quickly through the system as possible. Another recent trend is the streamlining of a two day batch fraud check process to provide account holders with an immediate and final decision. The casualty of a longer process could be a consumer who walks out of your branch with a checkbook in hand – only to be contacted the next day to tell that his/her account has been shut down. By addressing this process, not only will the customer experience be improved with  increased retention, but operational costs will also be reduced. Finally, relying on documentary evidence for ID verification can be viewed by some consumers as being onerous and lengthy. Use of knowledge based authentication can provide more robust authentication while giving assurance of the consumer’s identity. The key is to use a solution that can authenticate “thin file” consumers opening DDA accounts. This means your out of wallet questions need to rely on multiple data sources – not just credit. Interactive questions can give your account holders peace of mind that you are doing everything possible to protect their identity – which builds the customer relationship…and your brand.  

By: Heather Grover In past client and industry talks, I’ve discussed the increasing importance of retail branches to the growth strategy of the bank. Branches are the most utilized channel of the bank and they tend to be the primary tool for relationship expansion. Given the face-to-face nature, the branch historically has been viewed to be a relatively low-risk channel needing little (if any) identity verification – there are less uses of robust risk-based authentication or out of wallet questions. However, a now well-established fraud best practice is the process of doing proper identity verification and fraud prevention at the point of DDA account opening. In the current environment of declining credit application volumes and approval across the enterprise, there is an increased focus on organic growth through deposits.  Doing proper vetting during DDA account openings helps bring your retail process closer in line with the rest of your organization’s identity theft prevention program. It also provides assurance and confidence that the customer can now be cross-sold and up-sold to other products. A key industry challenge is that many of the current tools used in DDA are less mature than in other areas of the organization. We see few clients in retail that are using advanced fraud analytics or fraud models to minimize fraud – and even fewer clients are using them to automate manual processes - even though more than 90 percent of DDA accounts are opened manually. A relatively simple way to improve your branch operations is to streamline your existing ID verification and fraud prevention tool set: 1. Are you using separate tools to verify identity and minimize fraud? Many providers offer solutions that can do both, which can help minimize the number of steps required to process a new account; 2. Is the solution realtime? To the extent that you can provide your new account holders with an immediate and final decision, the less time and effort you’ll spend after they leave the branch finalizing the decision; 3. Does the solution provide detail data for manual review? This can help save valuable analyst time and provider costs by limiting the need to do additional searches. In my next post, we’ll discuss how fraud prevention in DDA impacts the customer experience.

By: Amanda Roth The final level of validation for your risk-based pricing program is to validate for profitability.  Not only will this analysis build on the two previous analyses, but it will factor in the cost of making a loan based on the risk associated with that applicant.  Many organizations do not complete this crucial step.  Therefore, they may have the applicants grouped together correctly, but still find themselves unprofitable. The premise of risk-based pricing is that we are pricing to cover the cost associated with an applicant.  If an applicant has a higher probability of delinquency, we can assume there will be additional collection costs, reporting costs, and servicing costs associated with keeping this applicant in good standing.  We must understand what these cost may be, though, before we can price accordingly.  Information of this type can be difficult to determine based on the resources available to your organization.  If you aren’t able to determine the exact amount of time and costs associated with the different loans at different risk levels, there are industry best practices that can be applied. Of primary importance is to factor in the cost to originate, service and terminate a loan based on varying risk levels.  This is the only true way to validate that your pricing program is working to provide profitability to your loan portfolio.  

--by Andrew Gulledge Intelligent use of features Question ordering: You want some degree of randomization in the questions that are included for each session. If a fraudster (posing as you) comes through Knowledge Based Authentication, for two or three sessions, wouldn’t you want them to answer new questions each time? At the same time, you want to try to use those questions that perform better more often. One way to achieve both is to group the questions into categories, and use a fixed category ordering (with the better-performing categories being higher up in the batting line up)—then, within each category, the question selection is randomized. This way, you can generally use the better questions more, but at the same time, make it difficult to come through Knowledge Based Authentication twice and get the same questions presented back to you. (You can also force all new questions in subsequent sessions, with a question exclusion strategy, but this can be restrictive and make the “failure to generate questions” rate spike.) Question weighting: Since we know some questions outperform others, both in terms of percentage correct and in terms of fraud separation, it is generally a good idea to weight the questions with points based on these performance metrics. Weighting can help to squeeze out some additional fraud detection from your Knowledge Based Authentication tool.  It also provides considerable flexibility in your decisioning (since it is no longer just “how many questions were answered correctly” but it is “what percentage of points were obtained”). Usage Limits: You should only allow a consumer to come through the Knowledge Based Authentication process a certain number of times before getting an auto-fail decision. This can take the form of x number of uses allowable within y number of hours/days/etc. Time out Limit: You should not allow fraudsters to research the questions in the middle of a Knowledge Based Authentication session. The real consumer should know the answers off the top of their heads. In a web environment, five minutes should be plenty of time to answer three to five questions. A call center environment should allow for more time since some people can be a bit chatty on the phone.  

By: Amanda Roth To refine your risk-based pricing another level, it is important to analyze where your tiers are set and determine if they are set appropriately.  (We find many of the regulators / examiners are looking for this next level of analysis.) This analysis begins with the results of the scoring model validation.  Not only will the distributions from that analysis determine if the score can predict between good and delinquent accounts, but it will also highlight which score ranges have similar delinquency rates, allowing you to group your tiers together appropriately.  After all, you do not want to have applicants with a 1 percent chance of delinquency priced the same as someone with an 8 percent chance of delinquency.  By reviewing the interval delinquency rates as well as the odds ratios, you should be able to determine where a significant enough difference occurs to warrant different pricing. You will increase the opportunity for portfolio profitability through this analysis, as you are reducing the likelihood that higher risk applicants are receiving lower pricing.  As expected, the overall risk management of the portfolio will increase when a proper risk-based pricing program is developed. In my next post we will look the final level of validation which does provide insight into pricing for profitability.  

By: Amanda Roth As discussed earlier, the validation of a risk based-pricing program can mean several different things. Let’s break these options down. The first option is to complete a validation of the scoring model being used to set the pricing for your program. This is the most basic validation of the program, and does not guarantee any insight on loan profitability expectations. A validation of this nature will help you to determine if the score being used is actually helping to determine the risk level of an applicant. This analysis is completed by using a snapshot of new booked loans received during a period of time usually 18–24 months prior to the current period. It is extremely important to view only the new booked loans taken during the time period and the score they received at the time of application. By maintaining this specific population only, you will ensure the analysis is truly indicative of the predictive nature of your score at the time you make the decision and apply the recommended risk-base pricing. By analyzing the distribution of good accounts vs. the delinquent accounts, you can determine if the score being used is truly able to separate these groups. Without acceptable separation, it would be difficult to make any decisions based on the score models, especially risk-based pricing. Although beneficial in determining whether you are using the appropriate scoring models for pricing, this analysis does not provide insight into whether your risk-based pricing program is set up correctly or not. Please join me next time to take a look at another option for this analysis.