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By: Staci Baker Just before the holidays, the Fed released proposed rules, which implement Sections 165 and 166 of the Dodd-Frank Act. According to The American Bankers Association, “The proposals cover such issues as risk-based capital requirements, leverage, resolution planning, concentration limits and the Fed’s plans to regulate large, interconnected financial institutions and nonbanks.” How will these rules affect you? One of the biggest concerns that I have been hearing from institutions is the affect that the proposed rules will have on profitability. Greater liquidity requirements, created by both the Dodd-Frank Act and Basel III Rules, put pressure on banks to re-evaluate which lending segments they will continue to participate in, as well as impact the funds available for lending to consumers.   What are you doing to proactively combat this? Within the Dodd-Frank Act is the Durbin Amendment, which regulates the interchange fee merchants are charged. As I noted in my prior blog detailing the fee cap associated with the Durbin Amendment, it’s clear that these new regulations in combination with previous rulings will continue to put downward pressures on bank profitability. With all of this to consider, how will banks modify their business models to maintain a healthy bottom line, while keeping customers happy? Over my next few blog posts, I will take a look at the Dodd-Frank Act’s affect on an institution’s profitability and highlight best practices to manage the impact to your organization.

As we kick off the new year, I thought I’d dedicate a few blog posts to cover what some of the consumer credit trends are pointing to for potential growth opportunities in 2012, specifically on new loan originations for bankcard, automotive and real estate lending. With the holiday season behind us (and if you’re anything like me, you have the credit card statements to prove it!), I thought I’d start off with bankcards for my first post of the year. Everyone’s an optimist at the start of a new year and bankcard issuers have a right to feel cautiously optimistic about 2012 based on the trends of last year.  In the second quarter of 2011, origination volumes grew to nearly $47B, up 28% from the same quarter a year earlier.  Actually, originations have been steadily growing since the middle of 2010 with increasing distribution across all VantageScore risk bands and an impressive 42% increase in A paper volume.  So, is bankcard the new power portfolio for growth in 2012? The broad origination risk distribution may signal the return of balance-carrying consumers (aka:  revolvers) from those that pay with credit cards, but pay off the balance every month (aka: transactors).  The tighter lending criteria imposed in recent years has improved portfolio performance significantly, but at the expense of interest fee profitability from revolver use.  This could change as more credit cards are put in the hands of a broader consumer risk base.  And as consumer confidence continues to grow, (it reached 64.5 in December, 10 points higher than November according to the Conference Board) , consumers in all risk categories will no doubt begin to leverage credit cards more heavily for continued discretionary spend, as highlighted in the most recent Experian – Oliver Wyman quarterly webinar. Of course, portfolio growth with the increased risk exposure requires a watchful eye on the delinquency performance of outstanding balances.  We continue to be at or near historic lows for delinquency, but did see a small uptick in early stage delinquencies in the third quarter of 2011. That being said, issuers appear to have a good pulse on the card-carrying consumer and are capitalizing on the improved payment behavior to maximize their risk/reward payoff.   So all-in-all, strong 2011 results and portfolio positioning has set the table for a promising 2012.  Add an improving economy to the mix and card issuers could shift from cautious to confident in their optimism for the new year.  

By: Joel Pruis The debate on what constitutes a small business application is probably second only to the ongoing debate around centralized vs. decentralized loan authority (but we will get to that topic in a couple of blogs later).  We have a couple of topics that need to be considered in this discussion, namely:      1.      When is an application an application?      2.     Do you process an incomplete application? When is an application an application? Any request by a small business with annual sales of $1,000,000 or less falls under Reg B.  As we all know because of this regulation we have to maintain proper records of when we received an application and when a decision on the application was made as well as communicated to the client.  To keep yourself out of trouble, I recommend that there be a small business application form (paper or electronic) and that you have clearly stated the information required for a completed application in your small business application procedures.  The form removes ambiguities in the application process and helps with the compliance documentation. One thing is for certain – when you request a personal credit bureau on the small business owner(s)/guarantor(s) and you currently do not have any credit exposure to the individual(s) – you have received an application and to this there is no debate. Bottom line is that you need to define your application and do so using objective criteria.  Subjective criteria leaves room for interpretation and individual interpretation leaves doubt in the compliance area. Information requirements Whether or not you use a generic or custom small business scorecard or no scorecard at all, there are some baseline data segments that are important to collect on the small business applicant: Requested amount and purpose for the funds Collateral (if necessary based upon the product terms and conditions) General demographics on the business Name and location Business Entity type (corporation, llc, partnership, etc.) Product and/or service provided Length of time in business Current banking relationship General demographics on the owners/guarantors Names and addresses Current banking relationship Length of time with the business External data reports on the business and/or guarantors Business Report Personal Credit Bureau on the owners/guarantors Financial Statements (??) – we’ll talk about that in part II of this post. The demographics and the existing banking relationship are likely not causing any issues with anyone and the requested amount and use of funds is elementary to the process.  Probably the greatest debate is around the collection of financial information and we are going to save that debate for the next post. The non-financial information noted above provides sufficient data to pull personal credit bureaus on the owners/guarantors and the business bureau on the actual borrower.  We have even noted some additional data informing us the length of time the business has been in existence and where the banking relationship is currently held for both the business and the owners.  But what additional information should be requested or should I say required? We have to remember that the application is not only to support the ability to render a decision but also supports the ability to document the loan and maybe even serve as a portion of the loan documentation.  We need to consider the following: How standardized are the products we offer? Do we allow for customization of collateral to be offered? Do we have standard loan/fee pricing? Is automatic debit for the loan payments required?  Optional? Not available? Are personal guarantees required?  Optional? We again go back to the 80/20 rule.  Product standardization is beneficial and optimal when we have high volumes and low dollars.  The smaller the dollar size of the request/relationship the more standardized we need to have our products and as a result our application can be more streamlined.  When we do not negotiate rate, we do not need to have a space to note requested rate.  When we do not negotiate on personal guarantees we always require the personal financial information be collected on all owners of the business (some exceptions for very small ownership interests).  Auto-debit for the loan payments means we always need to have some form of a DDA account with our institution.  I think you get the point that for the highest volume of applications we standardize and thus streamline the process through the removal of ambiguity. Do you process an incomplete application? The most common argument for processing an incomplete application is that if we know we are going to decline the application based upon information on the personal credit bureau, why go through the effort of collecting and spreading the financial information.  Two significant factors make this argument moot: customer satisfaction and fair lending regulation. Customer satisfaction This is based upon the ease of doing business with the financial institution.  More specifically the number of contact points or information requests that are required during the process.  Ideally the number of contact points that are required once the applicant has decided to make a financing request should be minimal the information requirements clearly communicated up front and fully collected prior to rendering a decision.  The idea that a quick no is preferable to submitting a full application actually is working to make the declination process more efficient than the actual approval process.  So in other words we are making the process more efficient and palatable for those clients we do NOT consider acceptable versus those clients that ARE acceptable.  Secondly, if we accept and process incomplete applications, we are actually mis-prioritizing the application volume.  Incomplete applications should never be processed ahead of completed packages yet under the quick no objective, the incomplete application is processed ahead of completed applications simply based upon date and time of submission.  Consequently we are actually incenting and fostering the submission of incomplete applications by our lenders.  Bluntly this is a backward approach that only serves to make the life of the relationship manager more efficient and not the client. Fair lending regulation This perspective poses a potential issue when it comes to consistency.  In my 10 years working with hundreds of financial institutions, only a very small minority of times have I encountered a financial institution that is willing to state with absolute certainty that a particular characteristic will cause an application to e declined 100% of the time.  As a result, I wish to present this scenario: Applicant A provides an incomplete application (missing financial statements, for example).  {C}Application is processed in an incomplete status with personal and business bureaus pulled. Personal credit bureau has blemishes which causes the financial institution to decline the application Process is complete Applicant B provides a completed application package with financial statements Application is processed with personal and business bureaus pulled, financial statements spread and analysis performed Personal credit bureau has the same blemishes as Applicant A Financial performance prompts the underwriter or lender to pursue an explanation of why the blemishes occurred and the response is acceptable to the lender/underwriter. Assuming Applicant A had similar financial performance, we have a case of inconsistency due to a portion of the information that we “state” is required for an application to be complete yet was not received prior to rendering the decision.  Bottom line the approach causes doubt with respect to inconsistent treatment and we need to avoid any potential doubt in the minds of our regulators. Let’s go back to the question of financial statements.  Check back Thursday for my follow-up post, or part II, where we’ll cover the topic in greater detail. 

With the most recent guidance newly issued by the Federal Financial Institutions Examination Council (FFIEC) there is renewed conversation about knowledge based authentication. I think this is a good thing.  It brings back into the forefront some of the things we have discussed for a while, like the difference between secret questions and dynamic knowledge based authentication, or the importance of risk based authentication. What does the new FFIEC guidance say about KBA?  Acknowledging that many institutions use challenge questions, the FFIEC guidance highlights that the implementation of challenge questions can greatly impact efficacy of its usefulness. Chances are you already know this.  Of greater importance, though, is the fact that the FFIEC guidelines caution on the use of less sophisticated systems and information that can be easily guessed or obtained from an Internet search, given the amount of information available.    As mentioned above, the FFIEC guidelines call for questions that “do not rely on information that is often publicly available,” recommending instead a broad range of data assets on which to base questions.  This is an area knowledge based authentication users should review carefully.  At this point in time it is perfectly appropriate to ask, “Does my KBA provider rely on data that is publicly sourced”  If you aren’t sure, ask for and review data sources.  At a minimum, you want to look for the following in your KBA provider:     ·         Questions!  Diverse questions from broad data categories, including credit and noncredit assets ·         Consumer question performance as one of the elements within an overall risk-based decisioning policy ·         Robust performance monitoring.  Monitor against established key performance indicators and do it often ·         Create a process to rotate questions and adjust access parameters and velocity limits.  Keep fraudsters guessing! ·         Use the resources that are available to you.  Experian has compiled information that you might find helpful: www.experian.com/ffiec Finally, I think the release of the new FFIEC guidelines may have made some people wonder if this is the end of KBA.  I think the answer is a resounding “No.”  Not only do the FFIEC guidelines support the continued use of knowledge based authentication, recent research suggests that KBA is the authentication tool identified as most effective by consumers.  Where I would draw caution is when research doesn’t distinguish between “secret questions” and dynamic knowledge based authentication, which we all know is very different.   

Consumer credit card debt has dipped to levels not seen since 2006 and the memory of pre-recession spending habits continues to get hazier with each passing day. In May, revolving credit card balances totaled over $790 billion, down $180 billion from mid-2008 peak levels. Debit and Prepaid volume accounted for 44% or nearly half of all plastic spending, growing substantially from 35% in 2005 and 23% a decade ago. Although month-to-month tracking suggests some noise in the trends as illustrated by the slight uptick in credit card debt from April to May, the changes we are seeing are not at all temporary. What we are experiencing is a combination of many factors including the aftermath impacts of recession tightening, changes in the level of comfort for financing non-essential purchases, the “new boomer” population entering the workforce in greater numbers and the diligent efforts to improve the general household wallet composition by Gen Xers. How do card issuers shift existing strategies? Baby boomers are entering that comfortable stage of life where incomes are higher and expenses are beginning to trail off as the last child is put through college and mortgage payments are predominantly applied toward principle. This group worries more about retirement investments and depressed home values and as such, they demand high value for their spending. Rewards based credit continues to resonate well with this group. Thirty years ago, baby boomers watched as their parents used cash, money orders and teller checks to manage finances but today’s population has access to many more options and are highly educated. As such, this group demands value for their business and a constant review of competitive offerings and development of new, relevant rewards products are needed to sustain market share. The younger generation is focused on technology. Debit and prepaid products accessible through mobile apps are more widely accepted for this group unlike ten to fifteen years ago when multiple credit cards with four figure credit limits each were provided to college students in large scale. Today’s new boomer is educated on the risks of using credit, while at the same time, parents are apt to absorb more of their children’s monthly expenses. Servicing this segment's needs, while helping them to establish a solid credit history, will result in long-term penetration in a growing segment. Recent CARD Act and subsequent amendments have taken a bite out of revenue previously used to offset increased risk and related costs that allowed card issuers to service the near-prime sector. However, we are seeing a trend of new lenders getting in to the credit card game while existing issuers start to slowly evaluate the next tier. After six quarters of consistent credit card delinquency declines, we are seeing slow signs of relief. The average VantageScore for new card originations increased by 8 points from the end of 2008 into early 2010 driven by credit tightening actions and has started to slowly come back down in recent months.   What next? What all of this means is that card issuers have to be more sophisticated with risk management and marketing practices. The ability to define segments through the use of alternate data sources and access channels is critical to ongoing capture of market share and profitable usage. First, the segmentation will need to identify the “who” and the “what.” Who wants what products, how much credit is a consumer eligible for and what rate, terms and rewards structure will be required to achieve desired profit and risk levels, particularly as the economy continues to teeter between further downturn and, at best, slow growth. By incorporating new modeling and data intelligence techniques, we are helping sophisticated lenders cherry pick the non-super prime prospects and offering guidance on aligning products that best balance risk and reward dynamics for each group. If done right, card issuers will continue to service a diverse universe of segments and generate profitable growth.

As I’m sure you are aware, the Federal Financial Institutions Examination Council (FFIEC) recently released its, "Supplement to Authentication in an Internet Banking Environment" guiding financial institutions to mitigate risk using a variety of processes and technologies as part of a multi-layered approach. In light of this updated mandate, businesses need to move beyond simple challenge and response questions to more complex out-of-wallet authentication.  Additionally, those incorporating device identification should look to more sophisticated technologies well beyond traditional IP address verification alone. Recently, I contribute to an article on how these new guidelines might affect your institution.  Check it out here, in full:  http://ffiec.bankinfosecurity.com/articles.php?art_id=3932 For more on what the FFIEC guidelines mean to you, check out these resources - which also gives you access to a recent Webinar.

The following article was originally posted on August 15, 2011 by Mike Myers on the Experian Business Credit Blog. Last time we talked about how credit policies are like a plant grown from a seed. They need regular review and attention just like the plants in your garden to really bloom. A credit policy is simply a consistent guideline to follow when decisioning accounts, reviewing accounts, collecting and setting terms. Opening accounts is just the first step. Here are a couple of key items to consider in reviewing  accounts: How many of your approved accounts are paying you late? What is their average days beyond terms? How much credit have they been extended? What attributes of these late paying accounts can predict future payment behavior? I recently worked with a client to create an automated credit policy that consistently reviews accounts based on predictive credit attributes, public records and exception rules using the batch account review decisioning tools within BusinessIQ. The credit team now feels like they are proactively managing their accounts instead of just reacting to them.   A solid credit policy not only focuses on opening accounts, but also on regular account review which can help you reduce your overall risk.

By: Staci Baker The Durbin Amendment, according to Wikipedia, gave the Federal Reserve the power to regulate debit card interchange fees. The amendment, which will have a profound impact on banks, merchants and anyone who holds a debit card will take effect on October 1, 2011 rather than the originally announced July 21, 2011, which will allow banks additional time to implement the new regulations. The Durbin Amendment states that card networks, such as Visa and Mastercard, will include an interchange fee of 21 cents per transaction, and must allow debit cards to be processed on at least two independent networks. This will cost banks roughly $9.4 billion annually according to CardHub.com. As stipulated in the Amendment, institutions with less than $10 billion in assets are exempt from the cap. In preparation for the Durbin Amendment, several banks have begun to impose new fees on checking accounts, end reward programs, raise minimum balance requirements and have threatened to cap transaction amounts for debit card transactions at $50 to $100 in order to recoup some of the earnings they are expected to lose. These new regulations will be a blow to already hurting consumers as their out of wallet expenses keep increasing. As you can see, The Durbin Amendment, which is meant to help consumers, will instead have the cost from the loss of interchange fees passed along in other forms. And, the loss of revenue will greatly impact the bottom line of banking institutions. Who will be the bigger winner with this new amendment - the consumer, merchants or the banks? Will banks be able to lower the cost of credit to an amount that will entice consumers away from their debit cards and to use their credit cards again? I think it is still far too soon to tell. But, I think over the next few months, we will see consumers use payment methods in a new way as both consumers and banks come to a middle ground that will minimize risk levels for all parties. Consumers will still need to shop and bankers will still need their tools utilized. What are you doing to prepare for The Durbin Amendment?

Lately there has been a lot of press about breaches and hacking of user credentials.  I thought it might be a good time to pause and distinguish between authentication credentials and identity elements. Identity elements are generally those bits of meta data related to an individual.  Things like: name, address, date of birth, Social Security Number, height, eye color, etc.  Identity elements are typically used as one part of the authentication process to verify an individual’s identity.  Credentials are typically the keys to a system that are granted after someone’s identity elements have been authenticated.  Credentials then stand in place of the identity elements and are used to access systems. When credentials are compromised, there is risk of account takeover by fraudsters with mal intent.  That’s why it’s a good idea to layer-in risk based authentication techniques along with credential access for all businesses.  But for financial institutions, the case is clear: a multi-layered approach is a necessity.  You only need to review the FFIEC Guidance of Authentication in an Internet Banking Environment to confirm this fact.  Boiled down to its essence, the latest guidance issued by the FFIEC is rather simple. Essentially it’s asking U.S. financial institutions to mitigate risk using a variety of processes and technologies, employed in a layered approach. More specifically, it asks those businesses to move beyond simple device identification — such as IP address checks, static cookies and challenge questions derived from customer enrollment information — to more complex device intelligence and more complex out-of-wallet identity verification procedures. In the world of online security, experience is critical.  Layered together, Experian’s authentication capabilities (including device intelligence from 41st Parameter, out-of-wallet questions and analytics) offers a more comprehensive approach to meeting and exceeding the FFIEC’s most recent guidance. More importantly, they offer the most effective and efficient means to mitigating risk in online environments, ensuring a positive customer experience and have been market-tested in the most challenging financial services applications.

For communications companies, acquiring new accounts is an ongoing challenge. However, it is critical to remember that managing new and existing accounts – and their respective risks – is of tremendous importance. A holistic view of the entire customer lifecycle is something every communications organization can benefit from. The following article was originally posted by Mike Myers on the Experian Business Credit blog. Most of us are pretty familiar with credit reports and scores, but how many of you are aware of the additional tools available to help you manage the entire credit risk lifecycle? I talk to credit managers everyday and as we’re all trying to do more with less, it’s easy to forget that opening accounts is just the first step. Managing risk on these accounts is as critical, if not more so, than opening them. While others may choose to “ship and chase”, you don’t need to. Proactive alert/monitoring services, regular portfolio scoring and segmentation are key components that a successful credit department needs to employ in the constant battle against “bad” accounts. Use these tools to proactively adjust credit terms and limits, both positively and negatively. Inevitably some accounts will go bad, but using collection research tools for skip tracing and targeting services for debt collection will put you first in line for collections. A journey of 1,000 miles begins with a single step; we have tools that can help you with that journey and all can be accessed online.

While the majority of your customers may be consumers, most telecommunications companies also work with a number of business accounts. Understanding business credit scores — and what attributes have the most impact on them — can go a long way in helping you identify good customers as well as better manage risk. The following article was originally posted by Peter Bolin on the Experian Business Credit blog. There are a number of factors that impact business credit risk scores. Keep in mind that most risk models are built using multivariate statistical methods that not only look at each attribute, but also look for the interaction between the attributes. However, there are three general factors that will impact a business score. Recency: How recently has the business been delinquent? Events that have happened recently tend to be most predictive of business behavior in the near future. For example being days beyond credit terms (DBT) in the past 30, 60, and 90 days will tend to negatively impact, on average, a business’s credit score versus those that are current. Frequency: How frequently is the business delinquent or applying for credit? If a business has multiple beyond terms events then the algorithm will reflect this behavior and will tend to impact the score to the low side. In addition, if a business is frequently applying for credit (called inquires) then this will also negatively impact the score. Monetary/Usage: How large is the debt burden? Businesses that carry large balances in relation to credit limits tend to be more risky than those that carry lower balances in relation to credit limits. This is called the utilization ratio or balance-to-limit ratio. As the debt burden increases interest payments also grow placing more stress on cash flows. This tends to negatively impact a business’ risk score. Please comment on this post to let me know of specific topics you want to hear more about.

The next time a consumer asks about his or her credit score, consider it an opportunity. Recent changes to the Risk-Based Pricing (RBP) rule may provide new opportunities to strengthen relationships by educating consumers about what their credit scores mean, how they’re used, and how they can be improved. For many lenders and other businesses, this could be the first time they’ve had a chance to speak directly and openly with customers about their credit scores. The RBP rule is intended to improve financial literacy As we’ve discussed, the Risk-Based Pricing Rule was instituted in response to policymaker concerns that consumers were not being sufficiently informed of the impact that credit reports can have on their annual percentage rate (APR). Now, when a lender makes a credit decision based on a consumer credit report and does not offer the best possible rate, or denies credit, the RBP Rule requires lenders to notify the customer about the decision – through either an explanation of the rate offered or disclosing a credit score. New requirements take effect on July 21 RBP compliance is changing following recent passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Companies will now be required to provide all customers with a credit score within a Risk Based Pricing Notice, along with educational material. The new requirement is effective July 21, 2011. This is also the date when the new Bureau of Consumer Financial Protection (CFPB) is set to be fully operational. How to prepare for consumer questions about credit scores Experian offers a number of resources to help lenders answer consumer questions. Online resources, including the Ask Experian column and our extensive Credit Education section, provide fundamental information to help consumers better understand credit scores and credit reports. The Experian Credit Score Basics booklet, plus more than 20 other educational documents, are available electronically and formatted for easy printing and distribution. All documents, PowerPoint presentations, virtual seminars and education videos are available on a free mini-disk. Customized training and education is available The Experian Public Education team can also provide customized, live Internet-based training and education for our clients’ employees to help them effectively answer customer questions about credit reports and credit scores. For a free mini-disk or more information about training events, please contact Rod Griffin, Experian’s Director of Public Education, at 1 (972) 390-3528, or email clientcorner@experian.com. Take a moment to check out our Risk-Based Pricing microsite, too. Note: While Experian is happy to provide our observations related to the new Risk-Based Pricing Rule, please work with your own legal counsel to ensure that you comply with your obligations under the rule.

Managing commercial credit in today’s economy can be a real challenge. For telecommunications companies, pulling a report can be helpful in deciding whether or not to offer service to a consumer. But pulling credit reports alone is simply not effective to perform true, proactive portfolio management. The following article was originally posted by Minnie Blanco on the Experian Business Credit blog. If you make decisions just by pulling credit reports, you may want to think about how you can manage your accounts proactively. Pulling a report is helpful in deciding whether you should offer credit to a business. But, consider these basic steps when looking for any negative trends: Develop a policy for how you’d handle accounts that are current, delinquent, bankrupt, etc. Segment your portfolio by those accounts who pay within a particular range of time or who fall within a particular category, i.e. Current 1-30 days, 31-60, 61-90, 91 plus or filed bankruptcy. Review your accounts and apply your company policy to that particular segment.     By applying steps 1 -3, you’ll be able to proactively identify good candidates for increased credit limits, as well as those you’ll need to pay closer attention to because they may be headed for delinquency or collections. BusinessIQ allows you to easily pull reports, segment accounts and submit them for account review. It’s easy-to-use…plus, the Portfolio Module is free! Here’s a demo on the application. Look for future blog posts from me where I’ll write more about managing your portfolio. And, feel free to comment and let me know if there are specific topics you want to hear about.

Well, actually, it isn’t. The better question to ask is when to use knowledge based authentication (KBA). I know I have written before about using it as part of a risk based authentication approach to fraud account management, but I am often asked what I mean by that statement. So, I thought it might be a good idea to provide a few more details and give some examples. Basically, what I mean is this: risk segmentation based on binary verification is unwise. Binary verification can occur based on identity elements, or it can occur based on pass/fail performance from out of wallet questions, but the fact remains that the primary decisioning strategy is relying on a condition with two outcomes – verified or not verified, pass or fail – and that is unwise. When we recommend a risk based authentication approach, the view is more broadly based. We advocate using analytics and weighting many factors, including those identity elements and knowledge based authentication performance as part of an overall decision, rather than an as end-all decision. If you take this kind of approach, when might you want to use this kind of approach? The answer to that is just about any time a transaction contains a level of risk, understanding that each organization will have a unique definition and tolerance for “risk”. It could be an origination or account opening scenario, when you do not yet have a relationship with a consumer. It could be in an account management setting, when you have a relationship with the consumer and know their expected behavior (and therefore anything outside of expected behavior is risk). It could be in transactional settings where there is an exchange of money or information belonging to the consumer. All of these are appropriate uses for KBA as part of a risk based approach.

By: Kristan Frend Imagine you’re on the #1 ranked relay swim team at the World Championships and you’re leading off. You finish your leg of the race with the team in first place. As your third teammate approaches the wall, your team is in first by a full body length. You’re on pace to set a new world record. Yet the anchor of your team is nowhere to be found, ultimately resulting in your team being disqualified.   If only your fourth teammate would have made it to the blocks in time…. When you take a step back and look at your fraud risk management solutions, do you ever feel like you have all of the tools and processes available yet feel like the anchor is missing? Perhaps it’s time to reexamine your internal resources. You may have an assembly of sophisticated and robust online fraud detection tools from vendors, but you may be missing a critical piece if you’re not also effectively leveraging internal data. Through our work with clients, we’re found that it is not uncommon for organizations to manage the customer relationship through different departments or silos within the organization.   All too often there is less than optimal coordination between these functional areas in taking advantage of their own internal negative data to combat application fraud. Additionally some organizations may have negative internal data but do not incorporate the check within their verification or risk based authentication tool, creating multiple steps and operational inefficiencies. One of the ways to overcome some of these issues is by incorporating internal negative data within an automated front-end check.  Once loss data is loaded into a historical database, the next time that name, phone, address, driver’s license or SSN reappears on a new application, the data element is immediately identified as one associated with a previous loss. The negative data is securely stored for only your organization’s use and is not shared with users outside of your organization.