By: Tom Hannagan An article in American Banker* today discusses how many community banks are now discouraging new deposit gathering. We have seen many headlines in the past couple of years about how banks are not lending. Loan origination has been trending downward for many months. Now, they aren’t seeking deposits either. You would think this is the ultimate way to lower risk, but that’s not necessarily so. There are many different reasons why banks have or may be reducing their balance sheets. Tighter credit standards, and relatively low loan demand are chief among them. This is largely a reaction, on the part of banks and borrowers, to the economic contraction and painfully slow recovery. The softness in real estate is still a large overhanging problem – for consumers, businesses, governments and the banks. Banks are still working on loss provisioning in an attempt to deal with the embedded credit risk from the last recession. Even though they may be shrinking, or very slowly growing their loan portfolio, all of the forward risk management considerations are still there. That is true for the lending business and for managing the overall balance sheet. Most apparent among all these considerations is that the entire existing loan portfolio is steadily coming up for renewal consideration. That is as much of an opportunity for reconsidering a loan’s risk and return characteristics as is considering a new loan. It is also an opportunity to review the relationship management strategy, including the value of other relationship services or the time to sell new services to that client. All these sales situations involve risk and return considerations. Not least among them are the deposit services – existing and potential – associated with the relationship. The main point in the American Banker article was that banks can have trouble putting new deposit funds to work profitably. That makes sense. Deposits involve operating risk and operating costs. The costs include both fixed and variable costs. There are four or five major types of deposits. Each of them has very different operating cost profiles, balance behavior and levels of interest expense. They also involve market risk in that their loyalty or likely duration varies. So, it is important to take both the risk and return factors of new/renewed loans into account AND to take the risk and return factors of new/existing deposit balances into account as part of ongoing relationship management – and the bank’s resulting balance sheet direction. This is a lot to consider. A good risk-based profitability regimen is as critical as ever. *American Banker, Tuesday, July 27, 2010. In Cash Glut, Banks Try to Discourage New Deposits. By, Paul Davis
By: Wendy Greenawalt The final provisions included in The Credit Card Act will go into effect on August 22, 2010. Most lenders began preparing for these changes some time ago, and may have already begun adhering to the guidelines. However, I would like to talk about the provisions included and discuss the implications they will have on credit card lenders. The first provision is the implementation of penalty fee guidelines. This clause prohibits card issuers from charging fees that exceed the consumer’s violation of the account terms. For example, if a consumer’s minimum monthly payment on a credit card account was $15, and the lender charges a $39 late fee, this would be considered excessive as the penalty is greater than the consumers’ obligation on that account. Going forward, the maximum fee a lender could charge in this example would be $15 or equal to the consumers obligation. In addition to late fee limitations, lenders can no longer charge multiple penalty fees based on a single late payment, other account term violations or fees for account inactivity. These limitations will have a dramatic impact on portfolio profitability, and lenders will need to account for this with all accounts going forward. The second major provision mandates that if a lender increased a consumer’s annual interest rate after January 1, 2009 due to credit risk, market conditions, or other factors, then the lender must maintain reasonable methodologies and perform account reviews no less than every 6 months. If during the account review, the credit risk, market conditions or other factors that resulted in the interest rate increase have changed, the lender must adjust the interest rate down if warranted. This provision only affects interest rate increases and does not supply specific terms on the amount of the interest rate reduction required; so lenders must assess this independently to determine their individual compliance requirements on covered accounts. The Credit Card Act was a measure to create better policies for consumers related to credit card accounts and overall will provide greater visibility and fair account practices for all consumers. However, The Credit Card Act places more pressure on lenders to find other revenue streams to make up for revenue that was previously received when accounts were not paid by the due date, fees and additional interest rate income were generated. Over the next few years, lenders will have to find ways to make up this shortcoming and generate revenue through acquisition strategies and/or new business channels in order to maintain a profitable portfolio. http://www.federalreserve.gov/newsevents/press/bcreg/20100303a.htm
In “An ounce of prevention is worth a pound of cure” Kristan Frend touched on the vulnerabilities faced by members of our Armed Services. That post made me think about recent fraud trends. Over the course of this spring and summer, I attended a few conferences and at one of these events something a bit disturbing occurred – a staff member for one of the exhibitors was victimized during the event. The individual’s wallet, containing cash and credit cards, was stolen along with the person’s passport and the victim didn’t realize it until they received their wake-up call the next morning. The few people who heard about it wondered “How could this happen at an event of industry professionals?” The answer is simple. Even industry professionals are every-day consumers, vulnerable to attack. As part of our Knowledge Based Authentication practice, Experian engages in blind focus group interviews with “every-day consumers” facilitated by an independent consulting group on Experian’s behalf. What we learn during those sessions informs our best practices for many of the fraud products and guides our process for new question generation in Knowledge Based Authentication. It is also an eye-opening experience. Through our research we have learned that participant consumers are now more aware and accepting of Knowledge Based Authentication than in past years. Knowledge Based Authentication has become a bellwether, consumers expect it. They also expect organizations they deal with to have an Identity Theft Prevention Program – and the ability to recognize when something “just isn’t right” about a situation. However, few participants cited a comprehensive strategy to protect themselves against identity theft, and even fewer actually demonstrated a commitment to follow a strategy, even when they had one. During open and honest conversation in a relaxed setting, participants revealed their true behavior. Many admitted they still use the same password for all their accounts, write their passwords down, and keep copies of their passwords in easily accessible places, such as a purse or a wallet, a desk drawer or an online application. The bottom line is this: Most people will attempt to do what they think they should to protect themselves from identity theft, including shredding or tearing up mail offers, selectively using credit cards and/or monitoring their garbage. However, if the process is too cumbersome or if it requires that they remember too much, they will default to old habits. As Kristan pointed out, thieves may increasingly rely on computer attacks to gather data, but many still resort to low-tech methods like dumpster diving, mail tampering, and purse and wallet theft to obtain privacy sensitive information. When that purse or wallet contains not only personally identifiable information, but also account passwords, the risk levels are significantly higher. Cyber attacks are a threat, but a consumer’s own behavior may be just as risky. As for the victim in this story… a very sharp desk clerk at a neighboring hotel thought it strange that someone was checking-in for a number of days without a reservation at full rate and without luggage, which started the ball rolling and led to the perpetrator being caught and the victim getting everything back except for some cash that had been spent at a coffee merchant. Clearly, this close call didn’t turn-out as badly as it could have.
US interest rates are at historically low levels, and while many Americans are taking advantage of the low interest rates and refinancing their mortgages, a great deal more are struggling to find jobs, and unable to take advantage of the rate- friendly lending environment. This market however, continues to be complex as lenders try to competitively price products while balancing dynamic consumer risk levels, multiple product options and minimize the cost of acquisition. Due to this, lenders need to implement advanced risk-based pricing strategies that will balance the uncertain risk profiles of consumers while closely monitoring long-term profitability as re-pricing may not be an option given recent regulatory guidelines. Risk-based pricing has been a hot topic recently with the Credit Card Act and Risk-Based Pricing Rule regulation and pending deadline. For lenders who have not performed a new applicant scorecard validation or detailed portfolio analysis in the last few years now is the time to review pricing strategies and portfolio mix. This analysis will aid in maintaining an acceptable risk level as the portfolio evolves with new consumers and risk tiers while ensuring short and long-term profitability and on-going regulatory compliance. At its core, risk-based pricing is a methodology that is used to determine the what interest rate should be charged to a consumer based on the inherent risk and profitability present within a defined pricing tier. By utilizing risk-based pricing, organizations can ensure the overall portfolio is profitable while providing competitive rates to each unique portfolio segment. Consistent review and strategy modification is crucial to success in today’s lending environment. Competition for the lowest risk consumers will continue to increase as qualified candidate pools shrink given the slow economic recovery. By reviewing your portfolio on a regular basis and monitoring portfolio pricing strategies closely an organization can achieve portfolio growth and revenue objectives while monitoring population stability, portfolio performance and future losses.
By: Kristan Frend Last week I came across a news article that said the NYPD arrested 26 people who allegedly took at least $5 million from stealing identities. What I found most disturbing was that criminals allegedly affected more than 200 soldiers, including many of whom were unaware of what was happening, since they were serving overseas. To help reduce the risk of identity theft and minimize fraud losses, all three major credit bureaus provide Active- Duty Alerts, which allow deployed soldiers to have their credit frozen while they are overseas. While these fraud alerts, coupled with financial institutions implementing identity theft programs, can help prevent identity theft losses, what is being done to reduce the risk of military personnel data being exposed and stolen? As social security numbers play a key role in identity theft, I was surprised and disturbed to learn that government issued military ID cards include the card holder’s social security number in full on the front. This creates an obvious security vulnerability to the card holder. Especially considering that the military ID card must be shown in a number of situations, such as getting on and off base, medical care, picking up prescriptions, entering a base shopping exchange, mess hall, etc. There are many situations where the service member encounters people in positions that were once filled by military personnel but are now filled by civilians, who may not have the same code of honor toward others in the military community. While it’s true that thieves are increasingly using computer hacking, phishing, malware, spyware and key stroke loggers to gather SSNs, thieves still resort to low-tech methods like dumpster diving, mail tampering, and purse and wallet theft to obtain privacy sensitive information. The need to show ID so often and the fact that it contains all of their pertinent data, puts service members at particular risk when they may be in harm’s way, focused more on missions than money missing from their bank account. The good news is that the Department of Defense launched a Social Security Number reduction initiative consisting of a phased removal of SSNs. Phase one, removal of dependent SSNs from ID cards is underway. Phase two, removal of printed SSNs from all cards has been placed on hold indefinitely, and phase three, removal of SSNs embedded in barcodes will begin in 2012. My point is not to be critical of the use of SSNs; I think we all can agree that the use of SSNs have become an integral part of our culture. However, we should look to see that organizations carefully balance the value of how SSNs are used with the vulnerabilities that its use creates. The old adage “an ounce of prevention is worth a pound of cure” could never be truer than with identity theft. The easiest way to minimize fraud is to avoid it by not giving criminals the opportunity to perpetrate identity theft against individuals.
By: Kennis Wong Several weeks ago, I attended and presented at Experian’s sold-out annual conference, Vision, in Phoenix, Arizona. One of the guest speakers was Malcolm Gladwell, best-selling author of The Tipping Point, Blink, Outliers and What the Dog Saw: And Other Adventures. Since I've read three of his four books, I could be considered a fan. And yes, his hair did look as wild in person as it appears in the pictures on the insides of his book covers. But that was not why I was so impressed by his speech. The real reason was that his topic was so relevant to how Experian Decision Analytics delivers value to our clients. Gladwell spent the whole hour addressing the difference between “puzzle” and “mystery”, providing abundant examples for both. The puzzle-versus-mystery topic was from one of his articles in The New Yorker. To solve a puzzle, one or more pieces of information are needed. The source of the problem is that insufficient data is available to have a conclusive answer to the question. An example would be finding Osama Bin Laden’s whereabouts. We simply do not have enough information to locate him, and we need more intelligence. On the other hand, a mystery is not solved by simply gathering more information. It is a matter of making sense out of a massive amount of data available, using analysis and judgment. Enron’s creative accounting was an example of a mystery. All the information was out in the open. Pages and pages of SEC filings and annual reports were there for anyone who was willing and able to analyze them. All that was needed to solve the mystery was to make sense out of the data. In the Fraud and Identity Solutions team, we satisfy clients’ needs by providing solutions for both puzzles and mysteries to fend off fraudsters. Besides the core credit bureau data, we have demographic data, fraud consortium data, past application data, automotive data and much more. We also have strategic partnerships to deliver demand deposit account, cell phone, and device data. All these data sources ensure that our clients get the data they need to piece the puzzle together. Our consulting and analytics, on the other hand, help clients to solve mysteries. Looking at individual pieces of disparate data is inefficient and provides little or no value. That’s why our numerous scoring solutions combine the available data in a way that is most predictive of various fraud outcomes. For example, our Precise ID Score and Fraud Shield Score Plus predict first- and third-party fraud; our BustOut Score predicts the likelihood of bust outs; our Never Pay score predicts the likelihood of a consumer never making a payment. As more data are available, we incorporate them into existing or new models if it increases the effectiveness of the models. So we have both the puzzle and mystery grounds covered. A note to Malcolm Gladwell: Great job at Vision! If you write a book about this topic, I’ll definitely buy it.
By: Kari Michel Credit risk models are used by almost every lender, and there are many choices to choose from including custom or generic models. With so many choices how do you know what is best for your portfolio? Custom models provide the strongest risk prediction and are developed using an organization’s own data. For many organizations, custom models may not be an option due to the size of the portfolio (may be too small), lack of data including not enough bads, time constraints, and/or lack of resources. If a custom model is not an option for your organization, generic bureau scoring models are a very powerful alternative for predicting risk. But how can you understand if your current scoring model is the best option for you? You may be using a generic model today and you hear about a new generic model, for example the VantageScore® credit score. How do you determine if the new model is more predictive than your current model for your portfolio? The best way to understand if the new model is more predictive is to do a head-to-head comparison – a validation. A validation requires a sample of accounts from your portfolio including performance flags. An archive is pulled from the credit reporting agency and both scores are calculated from the same time period and a performance chart is created to show the comparison. There are two key performance metrics that are used to determine the strength of the model. The KS (Komogorov-Smirnov) is a statistical term that measures the maximum difference between the bad and good cumulative score distribution. The KS range is from 0% to 100%, with the higher the KS the stronger the model. The second measurement uses the bad capture rate in the bottom 5%, 10% or 15% of the score range. A stronger model will provide better risk prediction and allow an organization to make better risk decisions. Overall, when stronger scoring models are used, organizations will be best prepared to decrease their bad rates and have a more profitable portfolio.
With the upcoming changes to overdraft fee policies coming to the banking industry July 1st, courtesy of the Federal Reserve, banks and credit unions are re-examining the revenue growth opportunities through their new account opening process. We frequently hear from our fraud risk and operations client partners that when there is a push for revenue growth, fraud detection gets de-prioritized as a trade off to bringing in more new customers. A DDA-friendly risk based authentication approach may offer some compromise to this seemingly “one for one” exchange. Here are some quick revenue-friendly, risk-averse practices being seen in the branches, call centers, and online channels of Experian clients: • Drive referrals to knowledge based authentication (KBA), negative record checks (account abuse, fraud records) or both off of an upfront fraud score, such as the Precise ID(SM) for Account Opening score. Segmenting based on risk is cost efficient and promotes an improved customer experience. • Bolster the fraud defenses of your online channel by raising the “pass” or “accept” threshold. The lower acquisition costs for this online account opening are tempting but this is also the venue most exploited by fraudsters. Some incremental manual reviews should work out as a small price to pay to catch the higher prevalence of fraud. • Cross sell and up sell with confidence based on more comprehensive authentication. By applying appropriate risk based authentication strategies, more products can be offered and exposure is reduced because you know you are dealing with the true consumer.
I often provide fraud analyses to clients, whereby they identify fraudsters that have somehow gotten through the system. We then go in and see what kinds of conditions exist in the fraudulent population that exist to a much lesser degree in the overall population. We typically do this with indicators, flags, match codes, and other conditions that we have available on the Experian end of things. But that is not to say there aren't things on your side of the fence that could be effective indicators of fraud risk as well! One simple example could be geography. If 50% of your known frauds are coming from a state that only sees 5% of your overall population, then that state sounds like a great indicator of fraud risk! What action you take based on this knowledge is up to you (and, I suppose, government regulation). One option would be to route the risky customers through a more onerous authentication procedure. For example, they might have to come into a branch in person to validate their identity. Geography is certainly not the only potential indicator of fraud risk. Be creative! There might be previously untapped indicators of fraud risk lurking in your customer databases. Do not limit yourself to intuition either. Oftentimes the best indicators of fraud risk that I find are counterintuitive. Just compare the percentage of time a condition occurs in your fraud population to the percentage of time it occurs in the overall population. It might be that you have a fraud ring that is leaving some telltale fingerprint on their behavior--one that is actionable in ways that will jumpstart your fraud prevention practices and minimize fraud losses!
In case you’ve never heard of it, a Babel fish is a small translator; that allows a carrier to understand anything said in any form of language. Alta Vista popularized the name but I believe Douglas Adams, author of The Hitchhiker’s Guide to the Galaxy, should be given credit for coining the term. So, what does a Babel fish have to do with Knowledge Based Authentication? Knowledge Based Authentication is always about the data – I have said this before. There is one universal truth: data doesn’t lie. However, that doesn’t mean it is easy to understand what the data is saying. It is a bit like a foreign language. You may have taken classes, and you can read the language or carry on a passable conversation, but that doesn’t mean it’s a good idea to enter into a contract – at least, not without an attorney who speaks the language, or your very own Babel fish. Setting up the best Knowledge Based Authentication configuration for risk management of your line of business can sometimes seem like that contract in a foreign language. There are many decisions to be made and the number of questions to present and which questions to ask is often the easy part. To truly get the most out of fraud models, it is necessary to consider where the score cuts that will be used with your Knowledge Based Authentication session will be set and what methodology will be used to invoke the Knowledge Based Authentication session: objective score performance, manual review and decision, etc. It is also important to consider the “kind of fraud” you might be seeing. This is where it is helpful to have your very own Babel fish – one designed specifically for fraud trends, fraud data, fraud models and Knowledge Based Authentication. If your vendor doesn’t offer you a Babel fish, ask for one. Yours could have one of many titles, but you will know this person when you speak with them, for their level of understanding of not only your business but, more importantly, your data and what it means. Sometimes the Babel fish will work in Consulting, sometimes in Product Management, sometimes in Analytics – the important thing is that there are fraud-specific experts available to you. Think about that for a minute. Business today is a delicate balance between customer experience/relationship management and risk management. If your vendor can’t offer you a Babel fish, tell them you have fish to fry – elsewhere.
By: Staci Baker With the increase in consumer behaviors such as ‘strategic default’, it has become increasingly difficult during the past few years for lenders to determine who the most creditworthy consumers are – defining consumers with the lowest credit risk. If you define risk as ‘the likelihood of [a consumer] becoming 90 days or more past due’, the findings are alarming. From June 2007 to June 2009, Super Prime consumers (those scoring 900 or higher) in the U.S. have gone from an average VantageScore® credit score* of 945 to 918, which increased their risk level from approx. 0.12% to 0.62% - an increase of 417% for this highly sought after population! Prime and near prime risk levels increased by 400% and 96% respectively. Whereas subprime consumers with few choices (stay subprime or improve their score), saw a slight decrease in risk, 8% - increasing their average VantageScore® credit score from 578 to 599. So how do lenders determine who to lend to, when the risk level for all credit tiers increases, or remain risky? In today’s dynamic economy, lenders need tools that will give them an edge, and allow them to identify consumer trends quickly. Incorporating analytic tools, like Premier Attributes, into lender’s origination models, will allow them to pinpoint specific consumer behavior, and provide segmentation through predefined attribute sets that are industry specific and target profitable accounts to improve acquisition strategies. As risk levels change, maintaining profitability becomes more difficult due to shrinking eligible consumer pools. By adding credit attributes, assessing credit risk both within an organization and for new accounts will be simplified and allow for more targeted prospects, thus maximizing prospecting strategies across the customer lifecycle and helping to increase profitability. * VantageScore®, LLC, May, 2010, “Finding Creditworthy Consumers in a Changing Economic Climate”
We've blogged about fraud alerts, fraud analytics, fraud models and fraud best practices. Sometimes, though, we delude ourselves into thinking that fraud prevention strategies we put into place today will be equally effective over time. Unfortunately, when a rat finds a dead-end in a previously-learned maze, it just keeps hunting for an exit. Fraudsters are no different. Ideally we want to seal off all the exits, and teach the rats to go and do something productive with their lives, but sadly that is not always the case. We also don't want to let too many good consumers get stuck either, so we cannot get too trigger-happy with our fraud best practices. Fraud behavior is dynamic, not static. Fraudsters learn and adapt to the feedback they receive through trial and error. That means when you plug a hole in your system today, there will be an increased push to seek out other holes tomorrow. This underscores the importance of keeping a close eye on your fraudsters' behavior trends. But there must be some theoretical breaking point where the fraudsters simply give up trying--at least with your company. This behavioral extinction may be idealistic in the general sense, but is nonetheless a worthy goal as related to your business. One of the best things you can do to prevent fraud is to gain a reputation amongst the fraudsters of, "Don't even try, it's not even worth it." And even if you don't succeed in getting them to stop trying altogether, it's still satisfying to know you are lowering their ROI while improving yours
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.