Industries

I recently attended a conference where Credit Union managers spoke of the many changes facing their industry in the wake of the real estate crisis and economic decline that has impacted the US economy over the past couple of years.  As these managers weighed in on the issues facing their businesses today, several themes began to emerge – tighter lending standards & risk management practices, increased regulatory scrutiny, and increased competition resulting in tighter margins for their portfolios. Across these issues, another major development was discussed – increased Credit Union mergers and acquisitions. As I considered the challenges facing these lenders, and the increase in M&A activity, it occurred to me that these lenders might have a common bond with an unexpected group –American family farms.  Overall, Credit Unions are facing the challenge of adding significant fixed costs (more sophisticated lending platforms & risk management processes) all the while dealing with increased competition from lenders like large banks and captive automotive lenders.  This challenge is not unlike the challenges faced by the family farm over the past few decades – small volume operators having to absorb significant fixed costs from innovation & increased corporate competition, without the benefit of scale to spread these costs over to maintain healthy lending margins. Without the benefit of scale, the family farm basically disappeared as large commercial operators acquired less-efficient (and less profitable) operators. Are Credit Unions entering into a similar period of competitive disadvantage? It appears that the Credit Union model will have to adjust in the very near future to remain viable. With high infrastructure expectations, many credit unions will have to develop improved decisioning strategies, become more proficient in assessing credit risk –implementing risk-based pricing models, and executing more efficient operational processes in order to sustain themselves when the challenges of regulation and infrastructure favor economies of scale. Otherwise, they are facing an uphill challenge, just as the family farm did (and does); to compete and survive in a market that favors the high-volume lender.

Well, in my last blog, I was half right and half wrong.  I said that individual trade associations and advocacy groups would continue to seek relief from Red Flag Rules ‘coverage’ and resultant FTC enforcement.  That was right.  I also said that I thought the June 1 enforcement date would ‘stick’.  That was wrong. Said FTC Chairman Jon Leibowitz, “Congress needs to fix the unintended consequences of the legislation establishing the Red Flag Rule – and to fix this problem quickly. We appreciate the efforts of Congressmen Barney Frank and John Adler for getting a clarifying measure passed in the House, and hope action in the Senate will be swift.  As an agency we’re charged with enforcing the law, and endless extensions delay enforcement.” I think the key words here are ‘unintended consequences’.  It seems to me that the unintended consequences of the Red Flag Rules reach far beyond just which industries are covered or not covered (healthcare, legal firms, retailers, etc).  Certainly, the fight was always going to be brought on by non-financial institutions that generally may not have had a robust identity authentication practice in place as a general baseline practice.  What continues to be lost on the FTC is the fact that here we are a few years down the road, and I still hear so much confusion from our clients as to what they have to do when a Red Flag compliance condition is detected.  It’s easy to be critical in hindsight, yes, but I must argue that if a bit more collaboration with large institutions and authentication service providers in all markets had occurred, creating a more detailed and unambiguous Rule, we may have seen the original enforcement date (or at least one of the first or second postponement dates) ‘stick’. At the end of the day, the idea of mandating effective and market defined identity theft protection programs makes a lot of sense.  A bit more intelligence gathering on the front end of drafting the Rule may, however, have saved time and energy in the long run.  Here’s hoping that December 31st ‘sticks’…I’m done predicting.  

By: Kristan Frend I recently gave a presentation on small business fraud at the annual National Association of Credit Managers (NACM) Credit Congress.  Following the session, several B2B credit professionals shared recent fraud issues   The attendees confirmed what we’ve been hearing from our customers: fraudsters are shifting from consumer to business/commercial fraud and they’re stepping up their game. One of the schemes mentioned by an attendee included fraudsters obtaining parcel provider’s tracking numbers to reroute shipments meant for their B2B customer.  The perpetrator calls the business’s call center, impersonates the legitimate business customer to place an order, obtains the tracking number, and then calls back with the tracking number to request that the shipment be rerouted. Often the new shipping location is a residential address where an individual has been recruited for a work-at-home employment opportunity.   The individual is instructed to sign for deliveries and then reship merchandise to a freight company within the country or directly to destinations outside the United States.  The fraud is uncovered once the legitimate B2B customer receives an invoice for goods which they never ordered or received. I encourage you to take a look at your business’s policies and procedures on handling change of address shipment  requests.  What tools do you employ to verify the individual making the request? Are you verifying who the new address belongs to?  You may also want to ask your parcel provider about account setting options available for when your employees submit reroute requests.  While a shipping reroute request isn’t always indicative of fraud, I recommend you assess your fraud risk and consider whether your fraud-related business processes need refining. Keep an eye out here for postings on these topics: known fraud, bust out fraud, and how best to minimize fraud loss.        

By: Staci Baker As more people have become underwater on their mortgage, the decision to stay or not stay in their home has evolved to consider a number of influences that impact consumer credit decisions.  Research is revealing that much of an individual’s decision to meet his credit obligations is based on his trust in the economy, moral obligation, and his attitude about delinquency and the effect it will have on his credit score. Recent findings suggest that moral obligation keeps the majority of homeowners from walking away from their homes.  According to the 2009 Fannie Mae National Housing Survey (i) – “Nearly nine in ten Americans (88%), including seven in ten who are delinquent on their own mortgages, do not believe it is acceptable for people to stop making payments on an underwater mortgage, while 8% believe it is acceptable.”  It appears that there is a sense of owning up to one’s responsibilities; having signed a contract and the presumed stigma of walking away from that obligation. Maintaining strong creditworthiness by continuing to make payments on an underwater mortgage is motivation to sustain mortgage payments.  “Approximately 74% of homeowners believe it is very important to maintain good credit and this can be a factor in encouraging them not to walk away (ii).”  Once a homeowner defaults on their mortgage, their credit score can drop 150 to 250 points (iii), and the cost of credit in the future becomes much higher via increased interest rates once credit scores trend down. Although consumers expect to keep investing in the housing market (70% said buying a home continues to be one of the safest investments available (iv)) they will surely continue optimizing decisions that consider both the moral and credit implications of their decisions. i     December, 2009, Fannie Mae National Housing Survey ii  4/30/10, Financial Trust Index at 23% While Strategic Defaults Continue to Rise, The Chicago Booth/Kellogg School Financial Trust Index iii  http://www.creditcards.com/credit-card-news/mortgage-default-credit-scores-1270.php iv  December, 2009, Fannie Mae National Housing Survey    

By: Kari Michel The Federal Reserve’s decision to permit card issuers to use income estimation models to meet the Accountability, Responsibility, and Disclosure (CARD) Act requirements to assess a borrower’s ability to repay a loan makes good sense. But are income estimation models useful for anything other than supporting compliance with this new regulation? Yes; in fact these types of models offer many advantages and uses for the financial industry. They provide a range of benefits including better fraud mitigation, stronger risk management, and responsible provision of credit. Using income estimation models to understand your customers’ complete financial picture is valuable in all phases of the customer lifecycle, including: • Loan Origination – use as a best practice for determining income capacity • Prospecting – target customers within a specific income range • Acquisitions – set line assignments for approved customers • Account Management – assess repayment ability before approving line increases • Collections – optimize valuation and recovery efforts One of the key benefits of income estimation models is they validate consumer income in real time and can be easily integrated into current processes to reduce expensive manual verification procedures and increase your ROI. But not all scoring models are created equal. When considering an income estimation model, it’s important to consider the source of the income data upon which the model was developed. The best models rely on verified income data and cover all income sources, including wages, rent, alimony, and Social Security. To lean more about how income estimation models can help with risk management strategies, please join the following webinar: Ability to pay:  Going beyond the Credit CARD on June 8, 2010. http://www.bulldogsolutions.net/ExperianConsumerInfo/EXC1001/frmRegistration.aspx?bdls=24143    

Well, here we are about two weeks from the Federal Trade Commission’s June 1, 2010 Red Flags Rule enforcement date.  While this date has been a bit of a moving target for the past year or so, I believe this one will stick.  It appears that the new reality is one in which individual trade associations and advocacy groups will, one by one, seek relief from enforcement and related penalties post-June 1.  Here’s why I say that: The American Bar Association has already file suit against the FTC, and in October, 2009, The U.S. District Court for the District of Columbia ruled that the Red Flags Rule is not applicable to attorneys engaged in the practice of law.  While an appeal of this case is still pending, in mid-March, the U.S. District Court for the District of Columbia issued another order declaring that the FTC should postpone enforcement of the Red Flags Rule “with respect to members of the American Institute of Certified Public Accountants” engaged in practice for 90 days after the U.S. Court of Appeals for the District of Columbia renders an opinion in the American Bar Association’s case against the FTC.” Slippery slope here.  Is this what we can expect for the foreseeable future? A rather ambiguous guideline that leaves openings for specific categories of “covered entities” to seek exemption?  The seemingly innocuous element to the definition of “creditor” that includes “businesses or organizations that regularly defer payment for goods or services or provide goods or services and bill customers later” is causing havoc among peripheral industries like healthcare and other professional services. Those of you in banking are locked in for sure, but it ought to be an interesting year as the outliers fight to make sense of it all while they figure out what their identity theft prevention programs should or shouldn’t be.  

By: Kari Michel Credit quality deteriorated across the credit spectrum during the recession that began in December, 2007. As the recession winds down, lenders must start strategically assessing credit risk and target creditworthy consumer segments for lending opportunities, while avoiding those segments where consumer credit quality could continue to slip. Studies and analyses by VantageScore® Solutions, LLC demonstrate that there are more than 60 million creditworthy borrowers in the United States - 7 million of whom cannot be identified using standard scoring models. Leveraging methods using the VantageScore® credit score in conjunction with consumer credit behaviors can effectively identify profitable opportunities and segments that require increased risk mitigation thus optimizing decisions. VantageScore Solutions examined how consumers credit scores changed over a 12 month period.  The study focused on three areas of consumer behavior: Stable:  consumers that stay within the same credit tier for one year Improving:  consumers that move to a higher credit tier in any quarter and remain at a high credit tier for the remainder of the timeframe Deteriorating: consumers that move to a lower credit tier in any quarter and remain at a lower credit tier for the remainder of the timeframe Through a segmentation approach, using the three credit behaviors above and credit quality tiers, emerges a clearer picture into profitable segments for acquisitions and existing account management strategies. Download the white paper, “Finding creditworthy consumers in a changing economic climate”, for more information on finding creditworthy consumers from VantageScore Solutions. Lenders can use a similar segmentation analysis on their own population to identify pockets of opportunity to move beyond recession-based management strategies and intelligently re-enter into the world of originations and maximize portfolio profitability.

By: Wendy Greenawalt The auto industry has been hit hard by this Great Recession. Recently, some good news has emerged from the captive lenders, and the industry is beginning to rebound from the business challenges they have faced in the last few years.  As such, many lenders are looking for ways to improve risk management and strategically grow their portfolio as the US economy begins to recover. Due to the economic decline, the pool of qualified consumers has shrunk, and competition for the best consumers has significantly increased. As a result, approval terms at the consumer level need to be more robust to increase loan origination and booking rates of new consumers. Leveraging optimized decisions is a way lenders can address regional pricing pressure to improve conversion rates within specific geographies. Specifically, lenders can perform a deep analysis of specific competitors such as captives, credit unions and banks to determine if approved loans are being lost to specific competitor segments. Once the analysis is complete, auto lenders can leverage optimization software to create robust pricing, loan amount and term account strategies to effectively compete within specific geographic regions and grow profitable portfolio segments. Optimization software utilizes a mathematical decisioning approach to identify the ideal consumer level decision to maximize organizational goals while considering defined constraints. The consumer level decisions can then be converted into a decision tree that can be deployed into current decisioning strategies to improve profitability and meet key business objectives over time.  

By: Staci Baker With the shift in the economy, it has become increasingly more difficult to gauge -- in advance -- what a consumer is going to do when it comes to buying an automobile.  However, there are tools available that allow auto lenders to gain insight into auto loans/leases that were approved but did not book, and for assessing credit risk of their consumers.  By gaining competitive insight and improving  risk management, an auto lender is able to positively impact loan origination strategies by determining the proper loan or lease term, what the finance offer should be and proactively address each unique market and risk segment. As the economy starts to rebound, the auto industry needs to take a more proactive approach in the way its members acquire business; the days of business-as-usual are gone.  All factors except the length of the loan being the same, if one auto dealer is extending 60-month loans per its norm and the dealer down the road is extending 72-month loans, a consumer may choose the longer loan period to help conserve cash for other items. This is one scenario for which auto dealers could leverage Experian’s Auto Prospect Intelligence(SM).  By performing a thorough analysis of approved loans that booked with other auto lenders, and their corresponding terms, auto lenders will receive a clear picture of who they are losing their loans to.  This information will allow an organization to compare account terms within specific peer group or institution type (captive/banks/credit union) and address discrepancies by creating more robust pricing structures and enhanced loan terms, which will result in strategic portfolio growth.    

Since 2007, when the housing and credit crises started to unfold, we’ve seen unemployment rates continue to rise (9.7% in March 2010 *)  with very few indicators that they will return to levels that indicate a healthy economy any time soon. I’ve also found myself reading about the hardship and challenge that people are facing in today’s economy, and the question of creditworthiness keeps coming into my mind, especially as it relates to employment, or the lack thereof, by a consumer. Specifically, I can’t help but sense that there is a segment of the unemployed that will soon possess a better risk profile than someone who has remained employed throughout this crisis. In times of consistent economic performance, the static state does not create the broad range of unique circumstances that comes when sharp growth or decline occurs. For instance, the occurrence of strategic default is one circumstance where the capacity to pay has not been harmed, but the borrower defaults on the commitment anyway. Strategic defaults are rare in a stable market. In contrast, many unemployed individuals who have encountered unfortunate circumstances and are now out of work may have repayment issues today, but do possess highly desirable character traits (willingness to pay) that enhance their long-term desirability as a borrower. Although the use of credit score trends, credit risk modeling and credit attributes are essential in assessing the risk within these different borrowers, I think new risk models and lending policies will need to adjust to account for the growing number of individuals who might be exceptions to current policies. Will character start to account for more than a steady job? Perhaps. This change in lending policy, may in turn, allow lenders to uncover new and untapped opportunities for growth in segments they wouldn’t traditionally serve. *  Source: US Department of Labor. http://www.bls.gov/bls/unemployment.htm

A common request for information we receive pertains to shifts in credit score trends. While broader changes in consumer migration are well documented – increases in foreclosure and default have negatively impacted consumer scores for a group of consumers – little analysis exists on the more granular changes between the score tiers. For this blog, I conducted a brief analysis on consumers who held at least one mortgage, and viewed the changes in their score tier distributions over the past three years to see if there was more that could be learned from a closer look. I found the findings to be quite interesting. As you can see by the chart below, the shifts within different VantageScore® credit score tiers shows two major phases. Firstly, the changes from 2007 to 2008 reflect the decline in the number of consumers in VantageScore® credit score tiers B, C, and D, and the increase in the number of consumers in VantageScore® credit score tier F. This is consistent with the housing crisis and economic issues at that time. Also notable at this time is the increase in VantageScore® credit score tier A proportions. Loan origination trends show that lenders continued to supply credit to these consumers in this period, and the increase in number of consumers considered ‘super prime’ grew. The second phase occurs between 2008 and 2010, where there is a period of stabilization for many of the middle-tier consumers, but a dramatic decline in the number of previously-growing super-prime consumers. The chart shows the decline in proportion of this high-scoring tier and the resulting growth of the next highest tier, which inherited many of the downward-shifting consumers. I find this analysis intriguing since it tends to highlight the recent patterns within the super-prime and prime consumer and adds some new perspective to the management of risk across the score ranges, not just the problematic subprime population that has garnered so much attention. As for the true causes of this change – is unemployment, or declining housing prices are to blame? Obviously, a deeper study into the changes at the top of the score range is necessary to assess the true credit risk, but what is clear is that changes are not consistent across the score spectrum and further analyses must consider the uniqueness of each consumer.

By: Wendy Greenawalt Optimization has become somewhat of a buzzword lately being used to solve all sorts of problems. This got me thinking about what optimizing decisions really means to me? In pondering the question, I decided to start at the beginning and really think about what optimization really stands for. For me, it is an unbiased mathematical way to determine the most advantageous solution to a problem given all the options and variables. At its simplest form, optimization is a tool, which synthesizes data and can be applied to everyday problems such as determining the best route to take when running errands. Everyone is pressed for time these days and finding a few extra minutes or dollars left in our bank account at the end of the month is appealing. The first step to determine my ideal route was to identify the different route options, including toll-roads, factoring the total miles driven, travel time and cost associated with each option. In addition, I incorporated limitations such as required stops, avoid main street, don’t visit the grocery store before lunch and must be back home as quickly as possible. Optimization is a way to take all of these limitations and objectives and simultaneously compare all possible combinations and outcomes to determine the ideal option to maximize a goal, which in this case was to be home as quickly as possible. While this is by its nature a very simple example, optimizing decisions can be applied to home and business in very imaginative and effective means. Business is catching on and optimization is finding its way into more and more businesses to save time and money, which will provide a competitive advantage. I encourage all of you to think about optimization in a new way and explore the opportunities where it can be applied to provide improvements over business-as-usual as well as to improve your quality of life.  

I received a call on my cell phone the other day. It was my bank calling because a transaction outside of my normal behavior pattern tripped a flag in their fraud models. “Hello!" said the friendly, automated voice, “I’m calling from [bank name] and we need to talk to you about some unusual transaction activity on your account, but before we do, I need to make sure Monica Bellflower has answered the phone. We need to ask you a few questions for security reasons to protect your account. Please hold on a moment.”  At this point, the IVR (Interactive Voice Response) system invoked a Knowledge Based Authentication session that the IVR controlled. The IVR, not a call center representative, asked me the Knowledge Based Authentication questions and confirmed the answers with me. When the session was completed, I had been authenticated, and the friendly, automated voice thanked me before launching into the list of transactions to be reviewed. Only when I questioned the transaction was I transferred, immediately – with no hold time, to a human fraud account management specialist. The entire process was seamless and as smooth as butter. Using IVR technology is not new, but using IVR to control a Knowledge Based Authentication session is one way of controlling operational expenses. An example of this is reducing the number of humans that are required, while increasing the ROI made in both the Knowledge Based Authentication tool and the IVR solution.  From a risk management standpoint, the use of decisioning strategies and fraud models allows for the objective review of a customer’s transactions, while employing fraud best practices. After all, an IVR never hinted at an answer or helped a customer pass Knowledge Based Authentication, and an IVR didn't get hired in a call center for the purpose of committing fraud. These technologies lend themselves well, to fraud alerts and identity theft prevention programs, and also to account management activities. Experian has successfully integrated Knowledge Based Authentication with IVR as part of relationship management and/or risk management solutions.  To learn more, visit the Experian website at: https://www.experian.com/decision-analytics/fraud-detection.html?cat1=fraud-management&cat2=detect-and-reduce-fraud).  Trust me, Knowledge Based Authentication with IVR is only the beginning. However, the rest will have to wait; right now my high-tech, automated refrigerator is calling to tell me I'm out of butter.

By: Ken Pruett I want to touch a bit on some of the third party fraud scenarios that are often top of mind with our customers: identity theft; synthetic identities; and account takeover. Identity Theft Identity theft usually occurs during the acquisition stage of the customer life cycle. Simply put, identity theft is the use of stolen identity information to fraudulently open up a new account.  These accounts do not have to be just credit card related. For example, there are instances of people using others identities to open up wireless phone and utilities accounts Recent fraud trends show this type of fraud is on the rise again after a decrease over the past several years.  A recent Experian study found that people who have better credit scores are more likely to have their identity stolen than those with very poor credit scores. It does seem logical that fraudsters would likely opt to steal an identity from someone with higher credit limits and available purchasing power.  This type of fraud gets the majority of media attention because it is the consumer who is often the victim (as opposed to a major corporation). Fraud changes over time and recent findings show that looking at data from a historical perspective is a good way to help prevent identity theft.  For example, if you see a phone number being used by multiple parties, this could be an indicator of a fraud ring in action.  Using these types of data elements can make your fraud models much more predictive and reduce your fraud referral rates. Synthetic Identities Synthetic Identities are another acquisition fraud problem.  It is similar to identity theft, but the information used is fictitious in nature.  The fraud perpetrator may be taking pieces of information from a variety of parties to create a new identity.  Trade lines may be purchased from companies who act as middle men between good consumers with good credit and perpetrators who creating new identities.   This strategy allows the fraud perpetrator to quickly create a fictitious identity that looks like a real person with an active and good credit history. Most of the trade lines will be for authorized users only.  The perpetrator opens up a variety of accounts in a short period of time using the trade lines. When creditors try to collect, they can’t find the account owners because they never existed.  As Heather Grover mentioned in her blog, this fraud has leveled off in some areas and even decreased in others, but is probably still worth keeping an eye on.  One concern on which to focus especially is that these identities are sometimes used for bust out fraud. The best approach to predicting this type of fraud is using strong fraud models that incorporate a variety of non-credit and credit variables in the model development process.  These models look beyond the basic validation and verification of identity elements (such as name, address, and social security number), by leveraging additional attributes associated with a holistic identity -- such as inconsistent use of those identity elements. Account Takeover Another type of fraud that occurs during the account management period of the customer life cycle is account takeover fraud.  This type of fraud occurs when an individual uses a variety of methods to take over an account of another individual. This may be accomplished by changing online passwords, changing an address or even adding themselves as an authorized user to a credit card. Some customers have tools in place to try to prevent this, but social networking sites are making it easier to obtain personal information for many consumers.  For example, a person may have been asked to provide the answer to a challenge question such as the name of their high school as a means to properly identify them before gaining access to a banking account.  Today, this piece of information is often readily available on social networking sites making it easier for the fraud perpetrators to defeat these types of tools. It may be more useful to use out of wallet, or knowledge-based authentication and challenge tools that dynamically generate questions based on credit or public record data to avoid this type of fraud.  

By: Wendy Greenawalt In my last few blogs, I have discussed how optimization can be leveraged to make improved decisions across an organization while considering the impact that opimizing decisions have to organizational profits, costs or other business metrics. In this entry, I would like to discuss how optimization is used to improve decisions at the point of acquisition, while minimizing costs. Determining the right account terms at inception is increasingly important due to recent regulatory legislation such as the Credit Card Act.  Doing so plays a role in assessing credit risk, relationship managment, and increasing out of wallet share. These regulations have established guidelines specific to consumer age, verification of income, teaser rates and interest rate increases. Complying with these regulations will require changes to existing processes and creation of new toolsets to ensure organizations adhere to the guidelines. These new regulations will not only increase the costs associated with obtaining new customers, but also the long term revenue and value as changes in account terms will have to be carefully considered. The cost of on-boarding and servicing individual accounts continues to escalate while internal resources remain flat. Due to this, organizations of all sizes are looking for ways to improve efficiency and decisions while minimizing costs. Optimizing decisions is an ideal solution to this problem. Optimized strategy trees (trees that optimize decisioning strategies) can be easily implemented into current processes to ensure lending decisions adhere to organizational revenue, growth or cost objectives as well as regulatory requirements.  Optimized strategy trees enable organizations to create executable strategies that provide on-going decisions based upon optimization conducted at a consumer level. Optimized strategy trees outperform manually created trees as they are created utilizing sophisticated mathematical analysis and ensure organizational objectives are adhered to. In addition, an organization can quantify the expected ROI of decisioning strategies and provide validation in strategies – before implementation. This type of data is not available without the use of a sophisticated optimization software application.  By implementing optimized strategy trees, organizations can minimize the volume of accounts that must be manually reviewed, which results in lower resource costs. In addition, account terms are determined based on organizational priorities leading to increased revenue, retention and profitability.