Financial Services
Accuracy matters. It matters in dart throwing, math calculations, and now more than ever, in data reporting. The Consumer Financial Protection Bureau (CFPB) issued a bulletin on Feb. 3 warning banks and credit unions that if they fail to meet accuracy obligations when reporting negative account histories to credit reporting companies, the result could be bureau action. As noted in the Fair Credit Reporting Act (FCRA) section 623, data furnishers have an obligation to ensure the accuracy of the information furnished to a Credit Reporting Agency (CRA). Violation of these rules presents a variety of risks, and the regulatory agencies have enforced harsh consequences. Avoiding penalties is certainly a strong incentive for data furnishers to implement a formal compliance management system and data quality program. But there are additional benefits to ensuring accuracy – most notably keeping customers happy and loyal, and maintaining a reputable brand in the marketplace. Today’s consumers increasingly understand the impact of credit scoring and data reporting, and recognize a poor credit score can impact their lives in major ways. Credit is tied to so many milestone financial moments. Securing mortgage loans, auto loans, obtaining low-interest rate interest credit cards and securing private student loans can all be derailed with an unfavorable and inaccurate credit report. Not to mention credit reports can influence one’s eligibility for rental housing, setting premiums for auto and homeowners insurance in some states, or determining whether to hire an applicant for a job. To properly serve customers who simply expect a fair and accurate representation of their financial history, data furnishers must be able to guarantee the credibility of their reported data. Those organizations that cannot ensure accuracy put their reputation at risk and may lose a customer’s trust and business. “Consumers should not be sidelined out of the basic banking services they need because of the flaws and limitations in a murky system,” Cordray said in the bulletin. “People deserve to have more options for access to lower-risk deposit accounts that can better fit their needs.” The CFPB has handled more than 105,000 credit-reporting complaints in its short history, making credit reporting the third most-complained-about consumer issue. By far the most common types of credit-reporting issues identified by consumers is incorrect information on credit report (77 percent).* Certainly these mistakes are not made intentionally. But speak to a consumer battling an inaccuracy, especially someone in the midst of applying for credit for a specific need, and frustrations can soar quickly. All lenders are advised to maintain a full 360-degree view of data reporting, from raw data submissions to the consumer credit profile. Better data input equals fewer inaccuracies. Additionally, there are comprehensive reporting solutions available to assess the accuracy of consumer credit data. The regulatory environment will without a doubt continue to be a hot topic in the media, fueled by announcements such as these by the CFPB, so lenders should take note and identify processes to ensure complete and utter accuracy. It matters in so many ways, so it’s best to make data reporting a priority now, if it’s not already. Source: CFPB August 2015 Monthly Complaint Report
Providing the essentials to credit risk managers
Basically, a blockchain is a permissionless, distributed database that maintains a growing list of records in a linear, chronological ledger.
Data Privacy Day reminds consumers to protect their privacy online — and for organizations to ensure they are vigilant in their fight against fraud.
Who will take the coveted Super Bowl title in 2016? Now that we’re down to the final two teams, the commentary will heighten. Sportscasters, analysts, former athletes, co-workers ... even your local barista has an opinion. Will it be Peyton Manning's Denver Broncos or the rising Carolina Panthers? Millions will make predictions in the coming weeks, but a little research can go a long way in delivering meaningful insights. How have the teams been trending over the season? Are there injuries? Who is favored and what’s the spread? Which quarterback is leading in pass completions, passing yards, touchdowns, etc.? Who has been on this stage before, ready to embrace the spotlight and epic media frenzy? The world of sports is filled with stats resulting from historical data. And when you think about it, the world of credit could be treated similarly. Over the past several years, there has been much hype about “credit invisibles” and the need to “score more.” A traditional pull will likely leave many “no-file” and “thin-file” consumers out, so it’s in a lender’s best interest to leverage alternative scoring models to uncover more. But it’s also important to remember a score is just a snapshot, a mere moment in time. How did a consumer arrive to that particular score pulled on any given day? Has their score been trending up or down? Has an individual been paying off debt at a rapid pace or slipping further behind? Two individuals could have the exact same score, but likely arrived to that place differently. The backstory is good to know – in sports and in the world of credit. Trended data can be attached to balances, credit limits, minimum payment due, actual payment and date of payment. By assessing these areas on a consumer file for 24 months, more insights are delivered and lenders can take note of behavior patterns to assist with risk assessment, marketing and share-of-wallet analysis. For example, looking closer at those consumers with five trades or more, Experian trended data reveals: 27% are revolvers, carrying balances each month 27% are transactors, paying off large portions, or all of their balances 9% are rate surfers, who tend to frequently transfer balances to credit cards with 0% or low introductory rates. Now these consumers can be viewed beyond a score. Suddenly, lenders can look within or outside their portfolio to understand how consumers use credit, what to offer them, and assess overall profitability. In short, trended data provides a more detailed view of a borrower’s historical credit performance, and that richness makes for a more informed decision. Without a doubt, there is power in the score – and being able to score more – but when it comes time to place your bets, the trended data matters, adding a whole new dimension to an individual’s credit score. Place your wagers accordingly. As for who will win Super Bowl 2016? I haven’t a clue. I’m more into the commercials. And I hear Coldplay is on for the half-time show. If you’re betting, best of luck, and do your homework.
What will 2016 hold for our market and the economy in terms of demand deposit accounts
The new year has started, the champagne bottles recycled. Bye-bye holidays, hello tax season. In fact, many individuals who are expecting tax refunds are filing early to capture those refunds as soon as possible. After all, a refund equates to so many possibilities – paying down debt, starting a much-needed home improvement project or perhaps trading up for a new vehicle. So what does that mean for lenders? As consumers pocket tax refunds, the likelihood of their ability to make payments increases. By the end of February 2014, more than 48 million tax refunds had been issued according to the IRS – an increase of 5.6 percent compared to the same time the previous year. As of Feb. 28, the average refund in 2014 was $3,034, up 3 percent compared to the average refund amount for the same time in 2013. To capitalize on this time period, introducing collection triggers can assist lenders with how to manage and collect within their portfolios. Aggressively paying down a bankcard, doubling down on a mortgage payment or wiping out a HELOC signal to the lender a change in positive behavior, but without a trigger attached, it can be hard to pinpoint which customers are shifting from their status quo payments. Experian actually offers around 100 collection triggers, but lenders do not need all to seek out the predictive insights they require. A “top 20” list has been created, featuring the highest percentages in lift rates, and population hit rates. Experian has done extensive analysis to determine the top-performing collection triggers. Among the top 15 to 20 triggers, the trigger hit rate ranged from 2 to 8 percent on an average client’s total portfolio, taking into consideration liquidation rates, average percent of payment lifts, lift in liquidation rates over the baseline liquidation, percent of overall portfolio that triggered, percent of overall portfolio that triggered only on the top-selected triggers, and percent of volume by trigger on the total customers that had a trigger hit. With that said, it is essential to implement the right strategy that includes a good mixture of the top-performing triggers. The key is diversifying and balancing trigger selection and setting triggers up during opportune times. Tax season is one of those times. Some of the top-ranked triggers include: Closed-Zero Balance Triggers: This is when a consumer’s account is reported as closed after being delinquent for a certain number of days. Specifically, the closed-zero balance trigger after being delinquent for 120 days has the highest percent of payment lift over an average payment that you would receive from a customer (at a 710 percent lift rate). These triggers are good indicators the consumer is showing positive improvement, thus having a higher likelihood for collections. Paid Triggers: This is when a consumer’s account is reported as paid after being delinquent, in collections, etc. Five of the top 20 triggers are paid triggers. These triggers have good coverage and a good balance between high lift rates (100 percent to 500 percent) and percent of the triggered population. These triggers are also good indicators the consumer is showing positive improvement, thus having a higher likelihood for collections. Inquiry Triggers: This is when a consumer is applying for an auto loan, mortgage loan, etc. The lift rates for these triggers are lowest within the Top 20, but on the other hand, these triggers have the highest hit rates (up to a 33 percent hit rate). These triggers are good indicators consumers are seeking to open additional lines of credit. Home Equity Loan Triggers: These triggers indicate the credit available on a consumer’s home equity loan. They are specifically enticing to collectors due to the fact that home equity lines of credit are usually larger than your average credit on your bank card. The larger the line of credit, the more you are able to potentially collect. To learn more about collection triggers, visit https://www.experian.com/consumer-information/debt-collection.html
What is the true fraud cost? We must be vigilant and keep our acceptable fraud rate at zero
As thought leaders in every industry make predictions for what 2016 will bring, I’m guessing there will be a few constants. New couples will marry. Some couples, sadly, will divorce. Young and old will move – some into first homes – others downsizing or making moves cross-country for work. And waves of individuals will clamor to the latest devices – a new iPhone7, perhaps. The Apple rumors are already flying. Yes, no big surprises, right? But, do you know what all of these very standard life events have in common? These transitions often result in shifts in consumer data, sometimes making people more difficult to track and contact. New last names, new addresses, new phone numbers. Suddenly, the consumer data that companies and lenders have on file are dated, and when it comes time to reach out to these individuals, it’s a challenge to connect. But that is just the beginning. The Federal Communications Commission (FCC) is increasing its efforts to register consumer complaints and taking aggressive actions to stop companies from making unsolicited phone calls. And the penalties are steep. Fines per individual infraction can be anywhere from $500 to $1,500. Companies have been delivered hefty penalties in the thousands, and in some cases millions, of dollars, over the past few years. All have questions and are seeking to understand how they must adjust their policies and call practices. Now those multiple attempts to call and find a consumer can cost you – big time. No more “shotgun” approaches to identifying and using phones. It’s simply too risky. The Telephone Consumer Protection Act (TCPA), enforced by the FCC, has been around since 1991, but regulations have been closely scrutinized over the past year since the FCC announced a new ruling last summer to clarify hot topics. In their July paper, they aim to communicate the definition of an “auto-dialer,” consent-to-call rules, how to address the reassignment of cell phone numbers, and the new requirement for “one call” without liability. In short, the Declaratory Ruling has opened the door to even greater liability under the TCPA, leaving companies who place outbound customer calls at-risk for compliance violations. Some are projecting the TCPA rules will continue to become even more expansive in 2016, so companies must really assess their call strategies and put best practices in place to increase right-party contact rates. Suggestions include: Identify landline and cell phones for TCPA compliance with dialer campaigns Focus on right- and wrong-party contact to improve customer service Score phones or apply cut-off scores based on the confidence of the number or match Scrub often for updated or verified information Establish a process to identify ported phones Determine when and how often you dial cell phones Provide consumers user-friendly mechanisms– such as texting “STOP” or “UNSUBSCRIBE” – to opt-out of receiving TCPA-covered communications. Review the policies and practices of third-party vendors to ensure they are not sending communications violating the TCPA With the huge advancements in mobile technology and the ever-changing digital landscape, it’s challenging to keep up, but regulators are cracking down on violations, and a slew of lawyers are ready to file on behalf of unhappy consumers dialed one-too-many times. Beyond a best-practice review, tools and systems are available to identify the right number for those moving and changing consumers. And I’m sure we can all agree, those life events will continue to happen in 2016. Marriages, divorces, moves, new devices. They’re coming. As a result, it’s necessary to track the resulting changes to consumer data. Only then will you have a shot at avoiding negative customer experiences and fines.
The numbers are staggering: more than $1.2 trillion in outstanding student loan debt, 40 million borrowers, and an average balance of $29,000. With Millennials exiting college and buried in debt, it’s no surprise they are postponing marriage, having babies, home purchases and other major life events. While the student loan issue has been looming for years, the magnitude is now taking center stage. All of the 2016 presidential contenders have an opinion, and many are starting to propose solutions – some going as far as to call for “debt-free college.” The issue has also caught the eye of the Consumer Financial Protection Bureau (CFPB). In its 2014 report, the CFPB stated one in four recent college graduates is either unemployed or underemployed. They also stated when faced with the inability to repay their debt, students lack payment options and are unclear as to how to resolve their debt. There is a bright spot. Experian reported new findings stating that among adults 18 to 34 years of age, the average credit score of those who had at least one open student loan account was 640, 20 points higher than others in their age group. So, if paid in a timely manner, student loans can help younger people establish a decent credit history before they go on to buy things like homes and cars. Still, education is key. Today, only 24 U.S. states require some form of financial literacy to be included in their high school course work, with only four states (Utah, Montana, Tennessee and Virginia) devoting a full semester to a personal finance course. Education is needed before students start diving into the student loan scene, and also after they graduate, to ensure they understand their repayment options and obligations. The CFPB is calling on all parties (universities, colleges, private lenders, advocates, policy makers and even family members) to get involved. Providing financial education, financial literacy, repayment options, deferral methods and income calculators are all needed to tackle this growing problem. The Great Recession and slow recovery brought home the importance of a college degree in today’s economy for many Americans. Bachelor’s degree recipients fared much better than their counterparts who only finished high school. The question becomes how to fund it, and make sure students who rely on loans understand the finances attached to this milestone investment. Learn more about Experian’s student debt trends and credit education in The Increasing Need for Consumer Credit Education: A Review of Student Debt.
Businesses must be vigilant and apply comprehensive, data-driven customer intelligence to thwart breaches and the malicious use of breached information.
Experian data shows consumers are more confident managing their credit since the recession. The Q3 2015 Experian Market Intelligence Brief was released today featuring data that highlights consumer credit card debt has now reached its highest level since Q4 2009. Credit card debt levels reached $650 billion in Q3 2015, the highest it has been since Q4 2009 when it was $667 billion. Credit card delinquency rates on outstanding balances 60 or more days past due have decreased 71 percent during the same time period. Combining those indicators with the national unemployment rate dropping 50 percent during the same span illustrates a positive economic outlook on credit card trends among lenders and consumers. “Overall credit card limits have increased 102 percent since Q4 2009 with $82 billion originated in Q3 2015,” said Kelly Kent, vice president of Experian Decision Analytics. “The increase in limits from lenders and the steady climb in credit card debt combined with exceptional delinquency rates signals greater confidence among consumers as they are showing more assurance in managing their credit since the recession. We expect to see credit card debt increase in Q4 based on historical seasonal trends driven by the holiday shopping season especially with the early positive holiday sales as a sign.” The Q3 2015 Experian Market Intelligence Brief report is now available.
The financial services industry continues to face mounting pressures to meet the highest standards of data reporting and accuracy. New regulations and mandates are introduced regularly, impacting the way companies do business. And a more credit-educated consumer base is seeking insights into their own credit data, providing a separate second of eyes that demand accuracy. Not only has the Fair Credit Reporting Act (FCRA) set requirements on dispute investigation and response, but the Consumer Financial Protection Bureau (CFPB) is also paying close attention. Recent announcements indicate the CFPB wants more information about the credit eco-system to gain more data about consumer disputes. According to the CFPB, it’s a joint problem – “the NCRAA’s, data furnishers, public record providers, and consumers all play roles which affect the accuracy of the information with credit reports.” And it’s not just the big banks that are being targeted with fines. The CFPB has made it clear it will also direct attention to certain nonbanks and financial products. In today’s data-driven environment, there are roughly 12,000-plus data furnishers, resulting in more than one billion pieces of information being updated on a monthly basis. Over 220 million consumers have some form of credit information attached to them, and transactional data is flowing all the time. Fail to update and a furnisher will quickly see flaws in their reporting. In fact, a recent study revealed an estimated 2.1% of contact info goes bad if unattended for more than one month. Clearly, achieving data quality is an ongoing investment for any organization, but companies often lack a clean plan. Some data furnishers fail to report, or elect to report to just one bureau, even though providing better data will result in a more complete and accurate credit profile. So how do you tackle the challenge of data quality? Organizations should consider implementing these six steps: Review data governance. Correct errors in data submissions. Complete an audit of data submissions. Evaluate disputes and resolutions. Compare data to peers and the industry. Review existing policies and processes. Follow these steps and your organization will earn a reputation among both regulators and consumers for clean, credible data. Plus, the investment in better data will reduce the need to resolve future disputes and fines. To learn more about meeting your FCRA responsibilities and best practices around data quality, check out our on-demand webinar or data integrity services site.
It’s official. Millennials have surpassed Baby Boomers in population size, according to the US Census. And while they are quick to adopt the “selfie” and all things social, they have been slow to embrace the world of credit. Sure, there’s been increased regulation over the past decade, and coming into adulthood in the midst of the Great Recession hasn’t helped. But don’t count Millennials out of the credit game just yet. A deeper, more segmented view of this digital-dependent generation shows a very diverse population with plenty of opportunity for lenders. Plus, their sheer size in numbers and $200 billion in annual buying power demand financial institutions evolve to accommodate this massive market. As Gen Y comes of age, there is growing evidence they are open to building and growing their personal credit history. But if financial institutions wish to capture the attention and business of this demographic, they must adapt, leveraging deeper segmentation insights with more effective prospecting strategies to reach them. Experian's data reveals key trends in terms of how this generation is utilizing credit, tips and tools to find the most credit-ready individuals, and strategies to grow the thin-file Millennials as they come of age. “Given the significance millennials play in financial services and the credit marketplace, it is crucial to understand this influential consumer segment and how they use credit as a tool,” said Michele Raneri, vice president of analytics and business development. “While this generation may not look like they are on the right track financially, it’s important to keep in mind that credit scores are built on credit experiences, and while this generation has been slower to use credit, they have plenty of opportunities to build a positive credit history.” To learn more about Millennials and credit, visit Experian.com/millennials.
To improve the customer experience during the busy holiday shopping season many businesses loosen their fraud criteria.