Consumer sentiment can help automotive marketers create a more human connection with consumers.
Experian recently released its Q1 2020 Market Trends report, which provides insights about the vehicles on the road and the most popular vehicle segments.
Experian’s Chris Ryan and Bobbie Paul recently re-joined David Mattei from Aite to discuss how emerging fraud trends and changes in consumer behavior will have long-term impacts on businesses. Chris, Bobbie, and David have combined experience of more than 60 years in the world of fraud prevention. In this discussion, they bring that experience to bear as they review how businesses should revise their long-term fraud strategy in response to COVID-19 and the subsequent economic shifts, including: The requirements to authenticate a digital customer Businesses’ technology challenges Differentiating between first party and third party fraud The importance of businesses’ technology investment How to build a roadmap for the next 90 days and beyond Experian · Make Your Fraud Plan Recession-Ready: Your 90 Day and Beyond Plan
Pre COVID-19, operations functions for retailers and financial institutions had not typically consisted of a remote (stay at home) workforce. Some organizations were better prepared than others, but there is a firm belief that retail and banking have changed for good as a result of the pandemic and resulting economic and workforce shifts. Market trends and implications When stay at home orders were issued, non-essential brick and mortar businesses closed unexpectedly. What were retailers to do with no traffic coming through the doors at their physical locations? The impact on big-box retailers like Best Buy, Dick’s Sporting goods, Sears, JCPenney, Nike, Starbucks, Macy’s, Neiman Marcus, Nordstrom, Kohl’s to name a few, has been unprecedented; some have had to shut their doors for good. Over the past several months global retail has seen e-commerce sales grow over 81% compared to the same period last year, according to Card Not Present. Some sectors have seen triple-digit growth year over year. Most online retailers have been ill-prepared to handle this increase in transactional volume in such a short amount of time, which has resulted in rapid fraud loss increases. A recent white paper from Aite Group reported that prior to COVID-19, a large financial institution forecasted an 8% decrease in fraud for 2020, but has since revised the projection to increase 10-15%. What does this all mean? Bad actors are taking advantage of the pandemic to exploit the online retail channel. The increased remote channel usage—online, mobile, and contact centers in particular—continues to be an area where retailers are exposed. Account takeover, through phishing and relaxed call center controls, is rising as well. Increases in phishing attacks are leading to compromised and stolen identities and synthetic identity fraud. Account takeover (ATO) fraud has increased 347% since 2019 according to PYMNTS.com. A recent survey found more than a quarter of merchants (27%) admit that they don’t have measures to prevent ATO. 24% of merchants can’t identify an ATO during a purchase. 14% of merchants say they are not even aware that an ATO has occurred unless a customer contacts them. When criminals use these compromised accounts to make fraudulent purchases, the merchant loses revenue and the value of the goods. They can also suffer from damage to brand reputation and a loss of customer confidence. A lack of account security can have lasting effects as 65% of customers surveyed say they would likely stop buying from a merchant if their account was compromised, according to that same Card Not Present study. So how can retailers start to identify bad actors with malicious intent? This will be a constant struggle for retailers. Rather than a one size fits all solution, retailers must move toward a strategy that is nimble and dynamic and can address multiple areas of exposure. A fraudster could easily slip by one verification method—for instance with a stolen credential—only to be foiled by a secondary authentication tactic like device identity. A layered fraud strategy continues to be the industry best practice, where both passive and active authentication methods are leveraged to frustrate fraudsters without applying undue friction to “good” consumers. The layered solution should also utilize device risk, identity verification and fraud analytics, with tailoring to each businesses’ needs, risk tolerance, and customer profiles. Learn more about how to build a layered fraud strategy today. Learn more
Every few months we hear in the news about a fraud ring that has been busted here in the U.S. or in another part of the world. In May, I read about a fraud ring based in Georgia and Louisiana that bought 13,000 stolen identities of children who were on the Louisiana Medicaid program and billed the government for services not rendered. This group defrauded the Medicaid program of more than $500,000. This is just one of many stories that we hear about fraud rings, and given the rapidly changing economic environment, now is the time for businesses to think about how to protect against fraud rings. There are a number of challenges that organizations may have when it comes to sharing trends and collaborations, understanding the ways to tie fraud rings together, creating treatments for identifying fraud rings and ways to store and catalogue fraud ring experiences so they can be easily recognized. The trouble with identifying fraud rings It’s important to understand the challenges that organizations have because they see the fraud rings through their own internal lens. Here are a few of the top things businesses should work on: Think like a fraudster. This will help businesses become more creative in their approach to fraud prevention. Facilitate internal collaboration. Share with in-organization partners. Sometimes this can be difficult due to organizational structure. Promote external collaboration. Intel-sharing groups are a great way for businesses to network within their industries and learn about the fraud that others are seeing. An organization that I’ve worked with in the past is the National Cyber Forensic and Training Alliance (NCFTA). Putting the pieces together How do businesses identify a fraud ring? There are three steps to get started. The first is reviewing and understanding the data. Fraudsters are lazy and want to replicate the process over and over again, and because of this there is always some piece of information that is repeated. It could be a name, an email address, device fingerprint, or similar. The second step is tying the fraud ring together. This is done by creating rules to help identify the trends. Having rules in place to identify fraud rings allows businesses to easily pull stats together for their leadership. Lastly, applying an acronym or name to the particular fraud ring and adding comments to the cases associated with a particular ring will help with post-investigation analysis. Learning from the past Before I became a consultant, I remember identifying a fraud ring that was submitting events with the same language pack and where the device fingerprint was staying consistent. Those events were being referred out for review and marked with the same note. At a post-mortem review, I was able to talk to the fraud ring we had seen, and it was easy to pull all events associated with this fraud ring because my team had marked the events with the same comments. Another fraud ring example happened a few years ago. A client called me and said that they were under a fraud attack and this fraud ring was rotating the email handle. I reviewed the data and came up with a rule to catch this activity. Fraud rings will use email handle rotation to help them keep track of accounts that are opened or what emails they used in the past. By coupling the email handle rotation with an email verification service like Emailage, this insight could be very telling. I would assume that when fraud rings use email handle rotation these emails are new and have just been created. These are just a few of the many fraud rings that I’ve encountered over the course of my career and I’m sure there will be a lot more in the years to come. The best advice I can give to anyone that reads this post is to understand the data that you are reviewing, look for anomalies within the data, ask questions and test your theories by running queries on the data that you’re reviewing. I would love to hear about the different fraud rings that you’ve encountered over your career. Stay safe. Contact us
Experian’s own Chris Ryan and Bobbie Paul recently joined David Mattei from Aite to discuss the latest research and insights into emerging fraud schemes and how businesses can combat them in light of COVID-19 and the resulting economic changes. Between them, Chris, Bobbie, and David have more than 60 years of experience in the world of fraud prevention. Listen in as they discuss how businesses can shape their fraud prevention plan in the short term, including: The impacts of the health crisis and physical distancing The rise of e-commerce and consumer digital engagement Changes in criminal activity Fraud attack vectors 2020 fraud loss projections Critical next steps for the 30-60 day time frame Experian · Make Your Fraud Plan Recession-Ready: 2020 Fraud Trends
To combat the growing threat of synthetic identity fraud, Experian recently announced the launch of Sure ProfileTM, a revolutionary change to the credit profile that gives lenders peace of mind with Experian’s commitment to share in losses that result from an identity we’ve assured. “Experian has always been a leader in combatting fraud, and with Sure Profile, we’re proud to deliver an industry-first fraud offering integrated into the credit profile that mitigates lender losses while protecting millions of consumers’ identities,” said Robert Boxberger, President of Decision Analytics, Experian North America. Synthetic identity fraud is expected to drive $48 billion in annual online payment fraud losses by 2023. Between opportunistic fraudsters and a lack of a unified definition for synthetic identity theft it can be nearly impossible to detect—and therefore prevent—this type of fraud. This breakthrough solution provides a composite history of a consumer’s identification, public record, and credit information and determines the risk of synthetic fraud associated with that consumer. It’s not just a fraud tool, it’s a comprehensive credit profile that utilizes premium data so lenders can make positive credit decisions. Sure Profile leverages the capabilities of the Experian Ascend Identity PlatformTM and uses Experian’s industry-leading data assets and data quality to drive advanced analytics that set a higher level of protection for lenders. It’s powered by newly-developed machine learning and AI models. And it offers a streamlined approach to define and detect synthetic identities early in the originations process. Most importantly, Sure Profile differentiates between real people and potentially risky applicants so lenders can increase application approvals with greater assurance and less risk. “Experian can confidently define and help detect synthetic fraud. That's why we can help stop it,” said Craig Boundy, CEO of Experian North America. “Experian stands behind our data with assurance given to our clients. It’s better for lenders and it’s better for consumers.” Sure Profile is a complement to our robust set of identity protection and fraud management capabilities, which are designed to address fraud and identity challenges including account openings, account takeovers, e-commerce fraud and more. This first-of-its kind profile is the future of underwriting and portfolio protection and it’s here now. Read press release Learn More About Sure Profile
The economic impact of the COVID-19 health crisis is ever-evolving and requires great flexibility and planning from lenders. Shannon Lois, Experian’s Senior Vice President, Analytics, Consulting and Operations, discusses what lenders can expect and next steps to take. Q: Though COVID-19 is catalyzing a sharp economic slowdown, many experts expect it to be temporary and liken it more to a global natural disaster than the prior financial crisis. What are your reactions? SL: There is still debate as to whether we will have a U-shaped or a V-shaped recession and its probable severity and longevity. Regardless, we are in a recession caused by a health pandemic with uncertainty of what it will mean for our global economy and without a clear view as to when it will end. The sooner we can contain the virus the more it will help to curtail the size of the recession. The unemployment rates and the consumer lack of confidence in the future will continue to contract spending which in turn will continue to propagate the recession. Our ability to limit COVID-19 over the coming months will have a direct impact in the economy, although the effects will probably linger on for six or more months. Q: From an economic perspective, what are the current trends we’re seeing? SL: Unemployment has skyrocketed and every business sector has been impacted although with different degrees of severity. In particular, tourism/hospitality, airlines, automotive, consumer products and retail have suffered. Consumers’ financial status varies and will continue to fluctuate, and credit conditions tighten while welfare payments increase. The government programs that have started will help, but they’re not enough to counter a prolonged recession. As some states seek to reopen and others extend their shelter in place orders, we will continue to see economic changes, with different sectors bouncing back or dipping further depending on their geographic location. Q: How does the economic slowdown compare to what we may have expected previously? SL: This recession is different than anything we have encountered previously not only because of the health concerns and implication of our population but because of the uncertainty of it all. As an example, social distancing has significantly and immediately impacted consumer demand but overall it is their low confidence in the future that will cause a continuous drop in discretionary and non-discretionary spending. Not only do we have challenges on the demand side, we also are seeing the same on the supply side with no automotive manufacturing occurring in the USA, and international oil flooding the market causing negative impact on domestic oil and the broad energy market. Q: How do the unemployment and liquidity challenges come into play? SL: The unemployment rate has already jumped to a record high. Most consumers are facing liquidity and affordability challenges and businesses do not have enough cash reserves to sustain them. Consumer activity has shifted drastically across all channels while lenders are exercising more caution. If this is a V-shaped recession (and hopefully it will be), then most activity is bound to spring back quickly in Q3. With companies safeguarding some jobs and the help of governments’ supplemental programs, businesses will restore supply and consumer demand will get a kick start. Q: What is the smartest next play for financial institutions? SL: The path forward requires several steps. First, understand your customers, existing and new. Refine your policies with the right information around your customers’ financial situations and extend programs (forbearance and loan payment forgiveness) as needed under the right guidelines. It’s also important to use refreshed data to lend to consumers and businesses who need it now more than ever, with the proper policies and fraud checks in place. Finally, increase your agility to operate effectively and dynamically with automation, interactive communication and self-serving digital tools. Experian is committed to helping lenders throughout these uncertain times. For more resources, visit our Look Ahead 2020 Resource Hub. Learn more About Our Expert Shannon Lois, Senior Vice President, Analytics, Consulting and Operations, Decision Analytics Shannon and her team of analysts, scientists, credit, fraud and marketing risk management experts provide results-driven consulting services and state-of-the-art advanced analytics, science and data products to clients in a wide range of businesses, including banking, auto, credit, utility, marketing and finance. Prior to her current role, she founded the Advisory Services practice at Experian, driving to actionable and proven solutions for our clients’ most pressing business problems.
This week, Experian released a new version of our CrossCore® digital identity and fraud risk platform, adding new tools and functionality to help businesses quickly respond to today’s emerging fraud threats. The ability to confidently recognize your customers and safeguard their digital transactions is becoming an increasing challenge for businesses. Fraud threats are already rising across the globe as fraudsters take advantage of the global health crisis and rapidly shifting economic conditions. CrossCore combines risk-based authentication, identity proofing and fraud detection into a single cloud platform, which means businesses can more quickly respond to an ever-changing environment. And with flexible decisioning orchestration and advanced analytics, businesses can make real-time risk decisions throughout the customer lifecycle. “Now more than ever, businesses need to lean on capabilities and technology that will allow them to rapidly respond in these challenging times, increase identity confidence in every transaction, and provide a safe and convenient experience for customers,” said E.K. Koh, Experian’s Senior Vice President of Global Identity & Fraud Solutions in a recent press release. “This new CrossCore release enables businesses to easily leverage best-in-class, pre-integrated identity and fraud services through simple self-service.” This new version of CrossCore features a cloud architecture, modern user interface, progressive risk assessments, faster response times, self-service workflow configuration, and a transactional volume reporting dashboard. These enhancements give you a simpler way to manage how backing applications are utilized, allow you to analyze key performance indicators in near real-time, and empower you to catch more fraud faster - without impacting the customer experience. “Recent Aite Group research shows that many banks have seen digital channel usage increase 250% in the wake of the pandemic, so ensuring a seamless and safe customer experience is more important than ever,” said Julie Conroy, Research Director at Aite Group. “Platforms such as CrossCore that can enable businesses to nimbly respond to changing patterns of customer behavior as well as rapidly evolving attack tactics are more important than ever, as financial services firms work to balance fraud mitigation with the customer experience.” CrossCore is the first identity and fraud platform that enables you to connect, access, and orchestrate decisions across multiple solutions. With the newest version, Experian enhances your ability to consolidate numerous fraud risk signals into a single, holistic assessment to improve operational processes, stay ahead of fraudsters, and protect your customers. Read Press Release Learn More About CrossCore
One of the most difficult parts of combating fraud is the ability to distinguish between the variety of fraud types. To properly manage your fraud efforts, you need to be able to differentiate between first party fraud and third party fraud so you can determine the best treatment. After all, if you’re treating first party fraud as though it’s third party fraud, the customer you’re contacting for verification will give whatever information they need to in order to continue their criminal actions. So how do you verify each type of fraud without adding additional overhead or increasing the friction experienced by your customers? Combating Fraud During an Economic Downturn Particularly in times of economic uncertainty, the ability to detect and identify individual fraud types allows you to work to prevent them in the future. Through proper identification, you can also apply the correct treatments to maximize the effectiveness of your fraud response teams, since the treatment for first and third party fraud is different. During the economic upswing, first party fraud was a secondary concern. Businesses were easing friction to help continue growth. Now, the same customers that businesses thought would drive growth are hurting and unable to help offset the losses caused by bad actors. Now is the time to revisit existing fraud prevention and mitigation strategies to ensure that fraud is properly identified, and the correct treatments are applied. Introducing Precise ID® Model Suite Experian’s Precise ID Model Suite combines identity analytics with advanced fraud risk models to: Protect the entire customer journey again fraud – across account opening, login, maintenance and transactions Distinguish first-party, third-party, and synthetic identity fraud to determine the best next action Enable agility during changing market conditions Maintain regulatory compliance (including: KYC, CIP, GLBA, FCRA, FFIEC, PATRIOT Act, FACTA, and more) Improve overall fraud management strategies and reduce losses Precise ID Model Suite allows you to detect and distinguish types of fraud with a single call – enabling your business to maximize efficiency and eliminate redundancy across your fraud prevention teams. By accurately recognizing risk, and in particular, recognizing that first party fraud is in fact a type of fraud distinct from credit risk, you’re able to protect your portfolio and your customers. Learn more
Essential personnel and organizations are working tirelessly to deliver food and other resources, not to mention, protecting the health and safety of those around us. These vehicles still require proper maintenance and care to ensure they run smoothly. That’s where the automotive industry can help.
This is the next article in our series about how to handle the economic downturn – this time focusing on how to prevent fraud in the new economic environment. We tapped two new experts—Chris Ryan, Market Lead, Fraud and Identity and Tischa Agnessi, Go-to-Market Lead, Decisioning Software—to share their thoughts on how to keep fraud out of your portfolio while continuing to lend. Q: What new fraud trends do you expect during the economic downturn? CR: Perhaps unsurprisingly, we tend to see high volumes of fraud during economic downturn periods. First, we anticipate an uptick in third-party fraud, specifically account takeover or ATO. It’ll be driven by the need for first-time users to be forced online. In particular, the less tech-savvy crowd is vulnerable to phishing attacks, social engineering schemes, using out-of-date software, or landing on a spoofed page. Resources to investigate these types of fraud are already strained as more and more requests come through the top of the funnel to approve new accounts. In fact, according to Javelin Strategy & Research’s 2020 Identity Fraud Study, account takeover fraud and scams will increase at a time when consumers are feeling financial stress from the global health and economic crisis. It is too early to predict how much higher the fraud rates will go; however, criminals become more active during times of economic hardships. We also expect that first party fraud (including synthetic identity fraud) will trend upwards as a result of the deliberate abuse of credit extensions and additional financing options offered by financial services companies. Forced to rely on credit for everyday expenses, some legitimate borrowers may take out loans without any intention of repaying them – which will impact businesses’ bottom lines. Additionally, some individuals may opportunistically look to escape personal credit issues that arise during an economic downturn. The line between behaviors of stressed consumers and fraudsters will blur, making it more difficult to tell who is a criminal and who is an otherwise good consumer that is dealing with financial pressure. Businesses should anticipate an increase in synthetic identity fraud from opportunistic fraudsters looking to take advantage initial financing offers and the cushions offered to consumers as part of the stimulus package. These criminals will use the economic upset as a way to disguise the fact that they’re building up funds before busting out. Q: With payment stress on the rise for consumers, how can lenders manage credit risk and prevent fraud? TA: Businesses wrestle daily with problems created by the coronavirus pandemic and are proactively reaching out to consumers and other businesses with fresh ideas on initial credit relief, and federal credit aid. These efforts are just a start – now is the time to put your recession readiness plan and digital transformation strategies into place and find solutions that will help your organization and your customers beyond immediate needs. The faceless consumer is no longer a fraction of the volume of how organizations interact with their customers, it is now part of the new normal. Businesses need to seek out top-of-line fraud and identity solutions help protect themselves as they are forced to manage higher digital traffic volumes and address the tough questions around: How to identify and authenticate faceless consumers and their devices How to best prevent an overwhelming number of fraud tactics, including first party fraud, account takeover, synthetic identity, bust out, and more. As time passes and the economic crisis evolves, we will all adapt to yet another new normal. Organizations should be data-driven in their approach to this rapidly changing credit crisis and leverage modern technology to identify financially stressed consumers with early-warning indicators, predict future customer behavior, and respond quickly to change as they deliver the best treatment at the right time based on customer-specific activities. Whether it’s preparing portfolio risk assessment, reviewing debt management, collections, and recovery processes, or ramping up your fraud and identity verification services, Experian can help your organization prepare for another new normal. Experian is continuing to monitor the updates around the coronavirus outbreak and its widespread impact on both consumers and businesses. We will continue to share industry-leading insights to help financial institutions differentiate legitimate consumers from fraudsters and protect their business and customers. Learn more About Our Experts [avatar user="ChrisRyan" /] Chris Ryan, Market Lead, Fraud and Identity Chris has over 20 years of experience in fraud prevention and uses this knowledge to identify the most critical fraud issues facing individuals and businesses in North America, and he guides Experian’s application of technology to mitigate fraud risk. [avatar user="tischa.agnessi" /] Tischa Agnessi, Go-to-Market Lead, Decisioning Software Tischa joined Experian in June of 2018 and is responsible for the go to market strategy for North America’s decisioning software solutions. Her responsibilities include delivering compelling propositions that are unique and aligned to markets, market problems, and buyer and user personas. She is also responsible for use cases that span the PowerCurve® software suite as well as application platforms, such as Decisioning as a ServiceSM and Experian®One.
The response to the coronavirus (COVID-19) health crisis requires a brand-new mindset from businesses across the country. As part of our recently launched Q&A perspective series, Jim Bander, Market Lead of Analytics and Optimization and Kathleen Peters, Senior Vice President of Fraud and Identity, provided insight into how businesses can work to mitigate fraud and portfolio risk. Q: How can financial institutions mitigate fraud risk while monitoring portfolios? JB: The most important shift in portfolio monitoring is the view of the customer, because it’s very different during times of crisis than it is during expansionary periods. Financial institutions need to take a holistic view of their customers and use additional credit dimensions to understand consumers’ reactions to stress. While many businesses were preparing for a recession, the economic downturn caused by the coronavirus has already surpassed the stress-testing that most businesses performed. To help mitigate the increased risk, businesses need to understand how their stress testing was performed in the past and run new stress tests to understand how financially sound their institution is. KP: Most businesses—and particularly financial institutions—have suspended or relaxed many of their usual risk mitigation tools and strategies, in an effort to help support customers during this time of uncertainty. Many financial institutions are offering debt and late fee forgiveness, credit extensions, and more to help consumers bridge the financial gaps caused by the economic downturn. Unfortunately, the same actions that help consumers can hamstring fraud prevention efforts because they impact the usual risk indicators. To weather this storm, financial institutions need to pivot from standard risk mitigation strategies to more targeted fraud and identity strategies. Q: How can financial institutions’ exposure to risk be managed? JB: Financial institutions are trying to extend as much credit as is reasonably possible—per government guidelines—but when the first stage of this crisis passes, they need to be prepared to deal with the consequences. Specifically, which borrowers will actually repay their loans. Financial institutions should monitor consumer health and use proactive outreach to offer assistance while keeping a finger on the pulse of their customers’ financial health. For the foreseeable future, the focus will be on extending credit, not collecting on debt, but now is the time to start preparing for the economic aftermath. Consumer health monitoring is key, and it must include a strategy to differentiate credit abusers and other fraudsters from overall good consumers who are just financially stressed. KP: As financial institutions work to get all of their customers set up with online and mobile banking and account access, there’s an influx of new requests that all require consumer authentication, device identification, and sometimes even underwriting. All of this puts pressure on already strained resources which means increased fraud risk. To manage this risk, businesses need to balance customer experience—particularly minimizing friction—with vigilance against fraudsters and reputational risk. It will require a robust and flexible fraud strategy that utilizes automated tools as much as possible to free up personnel to follow up on the riskiest users and transactions. Experian is closely monitoring the updates around the coronavirus outbreak and its widespread impact on both consumers and businesses. We will continue to share industry-leading insights to help financial institutions manage their portfolios and protect against losses. Learn more About Our Experts: [avatar user="jim.bander" /] Jim Bander, Market Lead, Analytics and Optimization, Experian Decision Analytics, North America Jim joined Experian in April 2018 and is responsible for solutions and value propositions applying analytics for financial institutions and other Experian business-to-business clients throughout North America. He has over 20 years of analytics, software, engineering and risk management experience across a variety of industries and disciplines. Jim has applied decision science to many industries, including banking, transportation and the public sector. [avatar user="kathleen.peters" /] Kathleen Peters, Vice President, Fraud and Identity, Experian Decision Analytics, North America Kathleen joined Experian in 2013 to lead business development and international sales for the recently acquired 41st Parameter business in San Jose, Calif. She went on to lead product management for Experian’s fraud and identity group within the global Decision Analytics organization, launching Experian’s CrossCore® platform in 2016, a groundbreaking and award-winning new offering for the fraud and identity market. The last two years, Kathleen has been named a “Top 100 Influencer in Identity” by One World Identity (OWI), an exclusive list that annually recognizes influencers and leaders from across the globe, showcasing a who’s who of people to know in the identity space.
Article written by Alex Lintner, Experian's Group President of Consumer Information Services and Sandy Anderson, Experian's Senior Vice President of Client and Sales Operations Many consumers are facing financial stress due to unemployment and other hardships related to the COVID-19 pandemic. Not surprisingly, data scientists at Experian are looking into how consumers’ credit scores may be impacted during the COVID-19 national emergency period as financial institutions and credit bureaus follow guidance from financial regulators and law established in Section 4021 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In a nutshell, Experian finds that if consumers contact their lenders and are granted an accommodation, such as a payment holiday or forbearance, and lenders report the accommodation accordingly, consumer scores will not be materially affected negatively. It’s not just Experian’s findings, but also those of the major credit scoring companies, FICO® and VantageScore®. FICO has reported that if a lender provides an accommodation and payments are reported on time consistent with the CARES Act, consumers will not be negatively impacted by late payments related to COVID-19. VantageScore® has also addressed this issue and stated that its models are designed to mitigate the impact of missed payments from COVID-19. At the same time, if as predicted, lenders tighten underwriting standards following 11 consecutive years of economic growth, access to credit for some consumers may be curtailed notwithstanding their score because their ability to repay the loan may be diminished. Regulatory guidance and law provide a robust response Recently, the Federal Reserve, along with the federal and state banking regulators, issued a statement encouraging mortgage servicers to work with struggling homeowners affected by the COVID-19 national emergency by allowing borrowers to defer mortgage payments up to 180-days or longer. The Federal Deposit Insurance Corporation stated that financial institutions should “take prudent steps to assist customers and communities affected by COVID-19.” The Office of the Comptroller of the Currency, which regulates nationally chartered banks, encouraged banks to offer consumers payment accommodations to avoid delinquencies and negative credit bureau reporting. This regulatory guidance was backed by Congress in passing the CARES Act, which requires any payment accommodations to be reported to a credit bureau as “current.” The Consumer Financial Protection Bureau, which has oversight of all financial service providers, reinforced the regulatory obligation in the CARES Act. In a statement, the Bureau said “the continuation of reporting such accurate payment information produces substantial benefits for consumers, users of consumer reports and the economy as a whole.” Moreover, the consumer reporting industry has a history of successful coordination during emergency circumstances, like COVID-19, and we’ve provided the support necessary for lenders to report accurately and consistent with regulatory guidance. For example, when a consumer faces hardship, a lender can add a code that indicates a customer or borrower has been “affected by natural or declared disaster.” If a lender uses this or a similar code, a notification about the disaster or other event will appear in the credit report with the trade line for the customer’s account and will remain on the trade line until the lender removes it. As a result, the presence of the code will not negatively impact the consumer credit score. However, other factors may impact a consumer’s score, such as an increase in a consumer’s utilization of their credit lines, which is a likely scenario during a period of financial stress. Suppression or Deletion of late payments will hurt, not help, credit scores In response to the nationwide impact of COVID-19, some lawmakers have suggested that lenders should not report missed payments or that credit bureaus should delete them. The presumption is that these actions would hold consumers harmless during the crisis caused by this pandemic. However, these good intentions end up having a detrimental impact on the whole credit ecosystem as consumer credit information is no longer accurately reflecting consumers’ specific situation. This makes it difficult for lenders to assess risk and for consumers to obtain appropriately priced credit. Ultimately, the best way to help is a consumer-specific solution, meaning one in which a lender reaches an accommodation with each affected individual, and accurately reflects that person’s unique situation when reporting to credit bureaus. When a consumer misses a payment, the information doesn’t end up on a credit report immediately. Most payments are monthly, so a consumer’s payment history with a financial institution is updated on a similar timeline. If, for example, a lender was required to suppress reporting for three months during the COVID-19 national emergency, the result would be no data flowing onto a credit report for three months. A credit report would therefore show monthly payments and then three months of no updates. The same would be true if a credit reporting agency were required to suppress or delete payment information. The lack of data, due to suppression or deletion, means that lenders would be blinded when making credit decisions, for example to increase a credit limit to an existing customer or to grant a new line of credit to a prospective customer. When faced with a blind spot, and unable to assess the real risk of a consumer’s credit history, the prudential tendency would be to raise the cost of credit, or to decrease the availability of credit, to cover the risk that cannot be measured. This could effectively end granting of credit to new customers, further stifling economic recovery and consumer financial health at a time when it’s needed most. Beyond the direct impact on consumers, suppression or deletion of credit information could directly affect the safety and soundness of the nation’s consumer and small business lending system. With missing data, lenders and their regulators would be flying blind as to the accurate information about a consumer’s risk and could result in unknowingly holding loan portfolios with heightened risk for loss. Too many unexpected losses threaten the balance of the financial system and could further seize credit markets. Experian is committed to helping consumers manage their credit and working with lenders on how best to report consumer-specific solutions. To learn more about what consumers can do to manage credit during the COVID-19 national emergency, we’ve provided resources on our website. For individuals looking to explore options their lenders may offer, we’ve included links to many of the companies and update them continuously. With good public policy and consumer-specific solutions, consumers can continue to build credit and help our economy grow.
This is the final part of a three part series of blog posts highlighting key focus areas for your response to the COVID-19 health crisis: Risk, Operations, Consumer Behavior, and Reporting and Compliance. For more information and the latest resources, please visit Look Ahead 2020, Experian’s COVID-19 resource center with the latest news and tools for our business partners as well as links to consumer resources and a risk simulator. To read the first post, click here. To read the second post, click here. Consumer Behavior Changes Consumers will be hit hard by the economic fallout from the virus. They’ll need to manage available credit and monthly income to bridge the gap when many people are faced with lost wages, tips and the ability to work. Often, the only way to monitor these short-term risks is with trended credit attributes, from both traditional and alternative data sources. These attributes were developed to provide additional insights into how consumer credit usage is trending over time. Is their debt and spending increasing? Have their credit lines been reduced? Have they historically been a transactor but have now started revolving balances? Could the account be a synthetic identity, set up for intentional misuse of credit? The most predictive attributes available in these times can transform how you can identify and respond to risk. Reporting and Compliance The regulatory environment is continuing to shift. There are continuous changes to compliance in the digital space for emerging channels and applications. There will be impacts to credit reporting and processes that may echo the response from other major natural disasters. The good news is that the framework developed for Comprehensive Capital Analysis and Review (CCAR) stress testing can be used to run scenarios and understand impacts. Although bank capital is very strong, additional regulation, such as the Current Expected Credit Losses (CECL), with all the latest shifts around compliance, may continue to increase the pressure on financial institutions. Having an adaptable process to forecast and stress-test scenarios to adjust capital requirements, especially in light of government fiscal and monetary stimulus measures, will be at the core of managing financial stability during a period of changes. Conclusion We need to brace for the pending recession after the longest economic expansion in our lifetimes. These are the times where organizations may struggle to survive or thrive in the face of adversity. This is the time to act on your strategic plan, lean on your strategic partners, and leverage industry leading data and capabilities to soften the landing and thrive in the next phase of growth. Let’s prepare and get through this, together. Learn More