Financial Services

By: Joel Pruis Part I – New Application Volume and the Business Banker: Generating small business or business banking applications may be one of the hottest topics in this segment at this time. Loan demand is down and the pool of qualified candidates seems to be down as well. Trust me, I am not going to jump on the easy bandwagon and state that the financial institutions have stopped pursuing small business loan applications. As I work across the country, I have yet to see a financial institution that is not actively pursuing small business loan applications. Loan growth is high on everyone’s priority and it will be for some time. But where have all the applicants gone? Based upon our data, the trend in application volume from 2006 to 2010 is as follows: Chart displays 2010 values: So at face value, we see that actually, overall applications are down (1,032 in 2006 to 982 in 2010) while the largest financial institutions in the study were actually up from 18,616 to 25,427. Furthermore the smallest financial institutions with assets less than $500 million showed a significant increase from 167 to 276. An increase of 65% from the 2006 levels! But before we get too excited, we need to look a little further. When we are talking about increasing application volume we are focusing on applications for new exposure or a new extension of credit and not renewals. The application count in the above chart includes renewals. So let’s take a look at the comparison of New Request Ratio between 2006 and 2010. Chart displays 2010 values: So using this data in combination with the total application count we get the following measurements of new application volume in actual numbers. So once we get under the numbers, we see that the gross application numbers truly don’t tell the whole story. In fact we could classify the change in new application volume as follows: So why did the credit unions and community banks do so well while the rest held steady or dropped significantly? The answer is based upon a few factors: In this blog we are going to focus on the first – Field Resources. The last two factors – Application Requirements and Underwriting Criteria – will be covered in the next two blogs. While they have a significant impact on the application volume and likely are the cause of the application volume shift from 2006 to 2010, each represents a significant discussion that cannot be covered as a mere sub topic. More to come on those two items. Field Resources pursuing Small Business Applications The Business Banker Focus. Focus. Focus. The success of the small business segment depends upon the focus of the field pursuing the applications. As we move up in the asset size of the financial institution we see more dedicated field resources to the Small Business/Business Banking segment. Whether these roles are called business bankers, small business development officers or business banking specialists, the common denominator is that they are dedicated to the small-business/ business banking space. Their goals depend on their performance in this segment and they cannot pursue other avenues to achieve their targets or goals. When we start to review the financial institutions in the less than $20B segment, the use of a dedicated business banker begins to diminish. Marketing segments and/or business development segmentation is blurred at best and the field resource is better characterized as a Commercial Lender or Commercial Relationship Manager. The Commercial Lender is tasked with addressing the business lending needs across a particular region. Goals are based upon total dollars generated and there is no restriction outside of the legal or in house lending limit of the specific financial institution. In this scenario, the notion of any focus on small business is left to the individual commercial lender. You will find some commercial lenders that truly enjoy and devote their efforts to the small business/business banking space. These individuals enjoy working with the smaller business for a variety of reasons such as the consultative approach (small businesses are hungry for advice while the larger businesses tend to get their advice elsewhere) or the ability to use one’s lending authority. Unfortunately while your financial institution may have such commercial lenders (one’s that are truly working solely in the small business or business banking segment) to change that individual’s title or formally commit them to working only in the small business/business banking segment is often perceived as a demotion. It is this perception that continues to hinder the progress of financial institutions with assets between $500 million and $20 billion from truly excelling in the small business/business banking space. Reality is that the best field resource to generate the small business/business banking application volume available to your financial institution is through the dedicated individual known as the Business Banker. Such an individual is capable of generate up to 250 applications (for the truly high performing) per year. Even if we scale this back to 150 applications in a given year for new credit volume at an average request of $106,929 (the lowest dollar of the individual peer groups), the business banker would be generating total application dollars of $16,039,350. If we imply a 50% approval/closure rate, the business banker would be able to generate a total of $8,019,675 in new credit exposure annually. Such exposure would have the potential of generating a net interest margin of $240,590 assuming a 3% NIM.   Not too bad.

By: Mike Horrocks Earlier this week, my wife and I were discussing the dinner plans for Thanksgiving.  The yams, cranberries, and pumpkin pies were purchased and the secret family recipes were pulled out of the cupboard.  Everything was ready…we thought.  Then the topic of the turkey was brought up.  In the buzz of work, family, kids, etc., both of us had forgotten to get the turkey.   We had each thought the other was covering this purchase and had scratched if off our respective lists.  Our Thanksgiving dinner was at risk!  This made me think of what best practices from our industry could be utilized if I was going to mitigate risks and pull off the perfect dinner.  So I pulled the page from the Basel Committee on Banking Supervision that defines operational risk as "the risk of loss resulting from inadequate or failed internal processes, people, systems or external events” and I have some suggestions that I think work for both your Thanksgiving dinner and for your existing loan portfolios. First, let’s cover “inadequate or failed processes”.  Clearly our shopping list process failed.   But how are your portfolio management processes?  Are they clearly documented and can they be implemented throughout the organization?  Your processes should be as well communicated and documented as the “Smashed Yam Bake” recipe or you may be at risk. Next, let focus on the “people and systems”.    People make mistakes – learn from them, correct them, and try to get the “systems” to make it so there are fewer mistakes.  For example, I don’t want the risk of letting the turkey cook too long, so I use a remote meat thermometer.  Ok, it is a little geeky; however the turkey has come out perfect every year.    What systems do you have in place to make your quarterly reviews of the portfolio more consistent and up to your standards?  Lastly, how do I mitigate those “external events”?  Odds are I will be able to still get a turkey tonight.  If not, I talked to a friend of mine who is a chef and I have the plans for a goose.   How flexible are your operations and how accessible are you to the subject matter experts that can get you out of those situations?  A solid risk management program takes into account unforeseen events and can make them into opportunities. So as the Horrocks family gathered in Norman Rockwell like fashion this Thanksgiving, a moment of thanks was given to the folks on the Basel committee.  Likewise in your next risk review, I hope you can give thanks for the minimized losses and mitigated risks.  Otherwise, we will have one thing very much in common…our goose will be cooked.

This first question in our five-part series on the FFIEC guidance and what it means Internet banking.  Check back each day this week for more Q&A on what you need to know and how to prepare for the January 2012 deadline. Question: What does “layered security” actually mean?   “Layered” security refers to the arrangement of fraud tools in a sequential fashion. A layered approach starts with the most simple, benign and unobtrusive methods of authentication and progresses toward more stringent controls as the activity unfolds and the risk increases. Consider a customer who logs onto an on-line banking session to execute a wire transfer of funds to another account. The layers of security applied to this activity might resemble: 1.       Layer One- Account log-in. Security = valid ID and Password must be provided 2.       Layer Two- Wire transfer request. Security= IP verification/confirmation that this PC has been used to access this account previously. 3.       Layer Three- Destination Account provided that has not been used to receive wire transfer funds in the past. Security= Knowledge Based Authentication Layered security provides an organization with the ability to handle simple customer requests with minimal security, and to strengthen security as risks dictate.  A layered approach enables the vast majority of low risk transactions to be completed without unnecessary interference while the high-risk transactions are sufficiently verified. _____________ Look for part two of our five-part series tomorrow. 

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.   

By: Mike Horrocks Have you ever been struck by a turtle or even better burnt by water skies that were on fire?  If you are like me, these are not accidents that I think will ever happen to me and I'm not concerned that my family doctor didn't do a rotation in medical school to specialize in treating them. On October 1, 2013, however, doctors and hospitals across the U.S. will have ability to identify, log, bill, and track those accidents and thousands of other very specific medical events.  In fact the list will jump from a current 18,000 medical codes to 140,000 medical codes.  Some people hail this as a great step toward the management of all types of medical conditions, whereas others view it as a introduction of noise in a medical system already over burdened.  What does this have to do with credit risk management you ask? When I look at the amount of financial and non-financial data that the credit industry has available to understand the risk of our consumer or business clients, I wonder where we are in the range of “take two aspirins and call me in the morning” to “[the accident] occurred inside a chicken coop” (code: Y9272).   Are we only identifying a risky consumer after they have defaulted on a loan?  Or are we trying to find a pattern in the consumer's purchases at a coffee house that would correlate with some other data point to indicate risk when the moon is full? The answer is somewhere in between and it will be different for each institution.  Let’s start with what is known to be predictable when it comes to monitoring our portfolios - data and analytics, coupled with portfolio risk monitoring to minimize risk exposure - and then expand that over time.  Click here for a recent case study that demonstrates this quite successfully with one of our clients. Next steps could include adding in analytics and/or triggers to identify certain risks more specifically. When it comes to risk, incorporating attributes or a solid set of triggers, for example, that will identify risk early on and can drill down to some of the specific events, combined with technology that streamlines portfolio management processes - whether you have an existing system in place or in search of a migration - will give you better insight to the risk profile of your consumers. Think about where your organization lies on the spectrum.    If you are already monitoring your portfolio with some of these solutions, consider what the next logical step to improve the process is - is it more data, or advanced analytics using that data, a combination of both, or perhaps it's a better system in place to monitoring the risk more closely. Wherever you are, don’t let your institution have the financial equivalent need for these new medical codes W2202XA, W2202XD, and W2202XS (injuries resulting from walking into a lamppost once, twice, and sequentially).

By: Kari Michel The way medical debts are treated in scores may change with the introduction of June 2011, Medical Debt Responsibility Act. The Medical Debt Responsibility Act would require the three national credit bureaus to expunge medical collection records of $2,500 or less from files within 45 days of their being paid or settled. The bill is co-sponsored by Representative Heath Shuler (D-N.C.), Don Manzullo (R-Ill.) and Ralph M. Hall (R-Texas). As a general rule, expunging predictive information is not in the best interest of consumers or credit granters -- both of which benefit when credit reports and scores are as accurate and predictive as possible. If any type of debt information proven to be predictive is expunged, consumers risk exposure to improper credit products as they may appear to be more financially equipped to handle new debt than they truly are. Medical debts are never taken into consideration by VantageScore® Solutions LLC if the debt reporting is known to be from a medical facility. When a medical debt is outsourced to a third-party collection agency, it is treated the same as other debts that are in collection. Collection accounts of lower than $250, or ones that have been settled, have less impact on a consumer’s VantageScore® credit score. With or without the medical debt in collection information, the VantageScore® credit score model remains highly predictive.

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 In my last post about the Dodd-Frank Act, I described the new regulatory bodies created by the Act. In this post, I will concentrate on how the Act will affect community banks. The Dodd-Frank Act is over 3,000 pages of proposed and final rules and regulations set forth by the Consumer Financial Protection Bureau (CFPB). For any bank, managing such a massive amount of regulations is a challenge, but for a median-size bank with fewer employees, it can be overwhelming. The Act has far reaching unintended consequences for community banks.  According to the American Bankers Association, there are five provisions that are particularly troubling for community banks: 1.       Risk retention 2.       Higher Capital Requirements and Narrower Qualifications for Capital 3.       SEC’s Municipal Advisors Rule 4.       Derivatives Rules 5.       Doubling Size of the Deposit Insurance Fund (DIF) In order meet new regulatory requirements, community banks will need to hire additional compliance staff to review the new rules and regulations, as well as to ensure they are implemented on schedule. This means the additional cost of outside lawyers, which will affect resources available to the bank for staff, and for its customers and the community. Community banks will also feel the burden of loosing interchange fee income. Small banks are exempt from the new rules; however, the market will follow the lowest priced product. Which will mean another loss of revenue for the banks. As you can see, community banks will greatly be affected by the Dodd-Frank Act. The increased regulations will mean a loss of revenues, increased oversight, additional out-side staffing (less resources) and reporting requirements. If you are a community bank, how do you plan on overcoming some of these obstacles?

By: John Straka Unsurprisingly, Washington deficit hawks have been eyeing the “sacred cows” of tax preferences for homeownership for some time now. Policymakers might even unwind or eliminate the mortgage interest deductions and capital-gains exemptions on home appreciation that have been in place in the U.S for many decades. There is an economic case to be made for doing this—more efficient resource allocation of capital, other countries have high ownership rates without such tax preferences, etc. But if you call or email or tweet Congress, and you choose this subject, my advice is to tell them that they should wait unti it’s 2005. In other words, now—or even the next few years most likely—is definitely not a good time at all to eliminate these housing tax preferences. We need to wait until it’s something like “2005”—when housing markets are much stronger again (hopefully) and state and local government finances are far from their relatively dire straits at present. If we don’t do this right, and insist on making big changes here now, then housing will take an immediate hit, and so will employment from both the housing sector and state and local governments (with further state and local service cutbacks also, due to budget shortfalls). The reason for this, of course, is that most homeowners today have not really benefited much, and won’t, from those well-established tax preferences. Why not? Because these preferences have been in place for so long now that the economic value (expected present discounted value) of these tax savings was long ago baked into the level of home prices that most homeowners paid when they bought their homes. Take the preferences away now, and the value of homes will immediately drop, and therefore so will property tax revenues collected by local governments across the U.S. This strategy will thus further bash the state- and-local sector in order to plump up some (we hope) our federal tax revenues by the value of the tax preferences. Housing will become a further drag on economic growth, and so will the resulting employment losses from both construction and local government services. As a result, it’s possible that on net the federal government may actually lose revenue from making this kind of change at precisely the wrong time. It may very well never be quite like “2005” again. But waiting for greater housing and local government strength to change long-standing housing tax preferences should make the macroeconomic impact smaller, less visible, and more easily absorbed.

A surprising occurrence is happening in the consumer credit markets. Bank card issuers are back in acquisition mode, enticing consumers with cash back, airline points and other incentives to get a share of their wallet. And while new account originations are nowhere near the levels seen in 2007, recent growth in new bank card accounts has been significant; 17.6% in Q1 2011 when compared to Q1 2010. So what is accounting for this resurgence in the credit card space while the economy is still trying to find its footing and credit is supposedly still difficult to come by for the average consumer? Whether good or bad, the economic crisis over the past few years appears to have improved consumers debt management behavior and card issuers have taken notice. Delinquency rates on bank cards are lower than at any time over the past five years and when compared to the start of 2009 when bank card delinquency was peaking; current performance has improved by over 40%. These figures have given bank card issuers the confidence to ease their underwriting standards and re-establish their acquisition strategies. What’s interesting however is the consumer segments that are driving this new growth. When analyzed by VantageScore, new credit card accounts are growing the fastest in the VantageScore D and F tiers with 46% and 53% increases year over year respectively. For comparison, VantageScore A and B tiers saw 5% and 1% increases during the same time period respectively.   And although VantageScore D and F represent less than 10% of new bank card origination volume ($ limits), it is still surprising to see such a disparity in growth rates between the risk categories. While this is a clear indication that card issuers are making credit more readily available for all consumer segments, it will be interesting to see if the debt management lessons learned over the past few years will stick and delinquency rates will continue to remain low. If these growth rates are any indication, the card issuers are counting on it.

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.

By: Kennis Wong On the surface, it’s not difficult to define existing account fraud. Obviously, it is fraud perpetrated against an existing account. But the way I see it, existing account fraud can be broken down into four types. The first type is account takeover fraud, which is what most organizations think as the de facto existing account fraud. This is when a real consumer using his or her own identity to open a legitimate account, but the account later on get taken over by an identity fraudster. The idea is that when the account was first established, it was created by the rightful person. But somewhere along the way, the account and identity information were compromised.  The fraudster uses the compromised information to engineer their way into the account. The second type is impersonation. Impersonation is somewhat similar to account takeover in the sense that it is also misusing the victim’s account. But the difference is that impersonation is more of a one or few times misuses of the account. Examples are a fraudulent use of a credit card or wire transfer. These are the obvious categories. But I think we should also think about these other categories. My definition of existing account fraud also includes this third type – identity fraud that was undetected during application. In other words, an account is established based on stolen identity.  Many organizations call this “new account fraud”, which I don’t have a problem with. But I think it’s really also existing account fraud, because –  is this existing account? The answer is yes. Is this fraud? Absolutely. It’s not that difficult, is it? Similarly, I am including first-party fraud in existing account fraud as well. A consumer can use his or her own identity to open an account, with an intention to default after the account is established. Example is bust out fraud. You see that this is an expanded definition of existing account fraud, because my focus is on detection. No matter at what point and how identity fraud comes in, it becomes an account in your organization, and that is where we need to discover the fraud. But at the end of the day, it’s not too important how to categorize or name the fraud - whether it's application fraud, existing account fraud, first party fraud or third party fraud, as long as organizations understand them enough and have a good way to detect them. Read more blog posts on existing account fraud.

By: Kari Michel The topic of strategic default has been a hot topic for the media as far back as 2009 and continues as this problem won’t really go away until home prices climb and stay there. Terry Stockman (not his real name) earns a handsome income, maintains a high credit score and owns several residential properties. They include the Southern California home where he has lived since 2007. Terry is now angling to buy the foreclosed home across the street. What’s so unusual about this? Terry hasn’t made a mortgage payment on his own home for more than six months. With prices now at 2003 levels, his house is worth only about one-half of what he paid for it. Although he isn’t paying his mortgage loan, Terry is current with his other debt payments.   Terry is a strategic defaulter — and he isn’t alone. By the end of 2008, a record  1 in 5 mortgages at least 60 days past due was a strategic default. Since 2008, strategic defaults have fallen below that percentage in every quarter through the second quarter of 2010, the most recent quarter for which figures are available. However, the percentages are still high: 16% in the last quarter of 2009 and 17% in the second quarter of last year. Get more details off of our 2011 Strategic Default Report What does this mean for lenders? Mortgage lenders need to be able to identify strategic defaulters in order to best employ their resources and set different strategies for consumers who have defaulted on their loans. Specifically designed indicators help lenders identify suspected strategic default behavior as early as possible and can be used to prioritize account management or collections workflow queues for better treatment strategies. They also can be used in prospecting and account acquisition strategies to better understand payment behavior prior to extending an offer. Here is a white paper I thought you might find helpful.