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By: Amanda Roth The reality of risk-based pricing is that there is not one “end all be all” way of determining what pricing should be applied to your applicants.  The truth is that statistics will only get you so far.  It may get you 80 percent of the final answer, but to whom is 80 percent acceptable?  The other 20 percent must also be addressed. I am specifically referring to those factors that are outside of your control.  For example, does your competition’s pricing impact your ability to price loans?  Have you thought about how loyal customer discounts or incentives may contribute to the success or demise of your program?  Do you have a sensitive population that may have a significant reaction to any risk-base pricing changes?  These questions must be addressed for sound pricing and risk management. Over the next few weeks, we will look at each of these questions in more detail along with tips on how to apply them in your organization.  As the new year is often a time of reflection and change, I would encourage you to let me know what experiences you may be having in your own programs.  I would love to include your thoughts and ideas in this blog.  

I’ve recently been hearing a lot about how bankcard lenders are reacting to changes in legislation, and recent statistics clearly show that lenders have reduced bankcard acquisitions as they retune acquisition and account management strategies for their bankcard portfolios. At this point, there appears to be a wide-scale reset of how lenders approach the market, and one of the main questions that needs to be answered pertains to market-entry timing: Should a lender be the first to re-enter the market in a significant manner, or is it better to wait, and see how things develop before executing new credit strategies? I will dedicate my next two blogs to defining these approaches and discussing them with regard to the current bankcard market. Based on common academic frameworks, today’s lenders have the option of choosing one of the following two routes: becoming a first-mover, or choosing to take the role of a secondary or late mover. Each of these roles possess certain advantages and also corresponding risks that will dictate their strategic choices: The first-mover advantage is defined as “A sometimes insurmountable advantage gained by the first significant company to move into a new market.” (1)  Although often confused with being the first-to-market, first-mover advantage is more commonly considered for firms that first substantially enter the market. The belief is that the first mover stands to gain competitive advantages through technology, economies of scale and other avenues that result from this entry strategy. In the case of the bankcard market, current trends suggest that segments of subprime and deep-subprime consumers are currently underserved, and thus I would consider the first lender to target these customers with significant resources to have ‘first-mover’ characteristics. The second-mover to a market can also have certain advantages: the second-mover can review and assess the decisions of the first-mover and develops a strategy to take advantage of opportunities not seized by the first-mover. As well, it can learn from the mistakes of the first-mover and respond, without having to incur the cost of experiential learning and possessing superior market intelligence. So, being a first-mover and second-mover can each have its advantages and pitfalls. In my next contribution, I’ll address these issues as they pertain to lenders considering their loan origination strategies for the bankcard market. (1) http://www.marketingterms.com/dictionary/first_mover_advtanage  

In a previous blog, we shared ideas for expanding the “gain” to create a successful ROI to adopt new fraud best practices  to improve.  In this post, we’ll look more closely at the “cost” side of the ROI equation. The cost of the investment- The costs of fraud analytics and tools that support fraud best practices go beyond the fees charged by the solution provider.  While the marketplace is aware of these costs, they often aren’t considered by the solution providers.  Achieving consensus on an ROI to move forward with new technology requires both parties to account for these costs.  A more robust ROI should these areas: • Labor costs- If a tool increases fraud referral rates, those costs must be taken into account. • Integration costs- Many organizations have strict requirements for recovering integration costs.  This can place an additional burden on a successful ROI. • Contractual obligations- As customers look to reduce the cost of other tools, they must be mindful of any obligations to use those tools. • Opportunity costs- Organizations do need to account for the potential impact of their fraud best practices on good customers.  Barring a true champion/challenger evaluation, a good way to do this is to remain as neutral as possible with respect to the total number of fraud alerts that are generated using new fraud tools compared to the legacy process As you can see, the challenge of creating a compelling ROI can be much more complicated than the basic equation suggests.  It is critical in many industries to begin exploring ways to augment the ROI equation.  This will ensure that our industries evolve and thrive without becoming complacent or unable to stay on top of dynamic fraud trends.  

By: Heather Grover In my previous entry, I covered how fraud prevention affected the operational side of new DDA account opening. To give a complete picture, we need to consider fraud best practices and their impact on the customer experience. As earlier mentioned, the branch continues to be a highly utilized channel and is the place for “customized service.” In addition, for retail banks that continue to be the consumer's first point of contact, fraud detection is paramount IF we should initiate a relationship with the consumer. Traditional thinking has been that DDA accounts are secured by deposits, so little risk management policy is applied. The reality is that the DDA account can be a fraud portal into the organization’s many products. Bank consolidations and lower application volumes are driving increased competition at the branch – increased demand exists to cross-sell consumers at the point of new account opening. As a result, banks are moving many fraud checks to the front end of the process: know your customer and Red Flag guideline checks are done sooner in the process in a consolidated and streamlined fashion. This is to minimize fraud losses and meet compliance in a single step, so that the process for new account holders are processed as quickly through the system as possible. Another recent trend is the streamlining of a two day batch fraud check process to provide account holders with an immediate and final decision. The casualty of a longer process could be a consumer who walks out of your branch with a checkbook in hand – only to be contacted the next day to tell that his/her account has been shut down. By addressing this process, not only will the customer experience be improved with  increased retention, but operational costs will also be reduced. Finally, relying on documentary evidence for ID verification can be viewed by some consumers as being onerous and lengthy. Use of knowledge based authentication can provide more robust authentication while giving assurance of the consumer’s identity. The key is to use a solution that can authenticate “thin file” consumers opening DDA accounts. This means your out of wallet questions need to rely on multiple data sources – not just credit. Interactive questions can give your account holders peace of mind that you are doing everything possible to protect their identity – which builds the customer relationship…and your brand.  

By: Heather Grover In past client and industry talks, I’ve discussed the increasing importance of retail branches to the growth strategy of the bank. Branches are the most utilized channel of the bank and they tend to be the primary tool for relationship expansion. Given the face-to-face nature, the branch historically has been viewed to be a relatively low-risk channel needing little (if any) identity verification – there are less uses of robust risk-based authentication or out of wallet questions. However, a now well-established fraud best practice is the process of doing proper identity verification and fraud prevention at the point of DDA account opening. In the current environment of declining credit application volumes and approval across the enterprise, there is an increased focus on organic growth through deposits.  Doing proper vetting during DDA account openings helps bring your retail process closer in line with the rest of your organization’s identity theft prevention program. It also provides assurance and confidence that the customer can now be cross-sold and up-sold to other products. A key industry challenge is that many of the current tools used in DDA are less mature than in other areas of the organization. We see few clients in retail that are using advanced fraud analytics or fraud models to minimize fraud – and even fewer clients are using them to automate manual processes - even though more than 90 percent of DDA accounts are opened manually. A relatively simple way to improve your branch operations is to streamline your existing ID verification and fraud prevention tool set: 1. Are you using separate tools to verify identity and minimize fraud? Many providers offer solutions that can do both, which can help minimize the number of steps required to process a new account; 2. Is the solution realtime? To the extent that you can provide your new account holders with an immediate and final decision, the less time and effort you’ll spend after they leave the branch finalizing the decision; 3. Does the solution provide detail data for manual review? This can help save valuable analyst time and provider costs by limiting the need to do additional searches. In my next post, we’ll discuss how fraud prevention in DDA impacts the customer experience.

By: Amanda Roth The final level of validation for your risk-based pricing program is to validate for profitability.  Not only will this analysis build on the two previous analyses, but it will factor in the cost of making a loan based on the risk associated with that applicant.  Many organizations do not complete this crucial step.  Therefore, they may have the applicants grouped together correctly, but still find themselves unprofitable. The premise of risk-based pricing is that we are pricing to cover the cost associated with an applicant.  If an applicant has a higher probability of delinquency, we can assume there will be additional collection costs, reporting costs, and servicing costs associated with keeping this applicant in good standing.  We must understand what these cost may be, though, before we can price accordingly.  Information of this type can be difficult to determine based on the resources available to your organization.  If you aren’t able to determine the exact amount of time and costs associated with the different loans at different risk levels, there are industry best practices that can be applied. Of primary importance is to factor in the cost to originate, service and terminate a loan based on varying risk levels.  This is the only true way to validate that your pricing program is working to provide profitability to your loan portfolio.  

By: Amanda Roth To refine your risk-based pricing another level, it is important to analyze where your tiers are set and determine if they are set appropriately.  (We find many of the regulators / examiners are looking for this next level of analysis.) This analysis begins with the results of the scoring model validation.  Not only will the distributions from that analysis determine if the score can predict between good and delinquent accounts, but it will also highlight which score ranges have similar delinquency rates, allowing you to group your tiers together appropriately.  After all, you do not want to have applicants with a 1 percent chance of delinquency priced the same as someone with an 8 percent chance of delinquency.  By reviewing the interval delinquency rates as well as the odds ratios, you should be able to determine where a significant enough difference occurs to warrant different pricing. You will increase the opportunity for portfolio profitability through this analysis, as you are reducing the likelihood that higher risk applicants are receiving lower pricing.  As expected, the overall risk management of the portfolio will increase when a proper risk-based pricing program is developed. In my next post we will look the final level of validation which does provide insight into pricing for profitability.  

By: Amanda Roth As discussed earlier, the validation of a risk based-pricing program can mean several different things. Let’s break these options down. The first option is to complete a validation of the scoring model being used to set the pricing for your program. This is the most basic validation of the program, and does not guarantee any insight on loan profitability expectations. A validation of this nature will help you to determine if the score being used is actually helping to determine the risk level of an applicant. This analysis is completed by using a snapshot of new booked loans received during a period of time usually 18–24 months prior to the current period. It is extremely important to view only the new booked loans taken during the time period and the score they received at the time of application. By maintaining this specific population only, you will ensure the analysis is truly indicative of the predictive nature of your score at the time you make the decision and apply the recommended risk-base pricing. By analyzing the distribution of good accounts vs. the delinquent accounts, you can determine if the score being used is truly able to separate these groups. Without acceptable separation, it would be difficult to make any decisions based on the score models, especially risk-based pricing. Although beneficial in determining whether you are using the appropriate scoring models for pricing, this analysis does not provide insight into whether your risk-based pricing program is set up correctly or not. Please join me next time to take a look at another option for this analysis.

In a recent presentation conducted by The Tower Group, “2010 Top 10 Business Drivers, Strategic Responses, and IT Initiatives in Bank Cards,” the conversation covered many of the challenges facing the credit card business in 2010.  When discussing the shift from “what it was," to “what it is now” for many issues in the card industry, one specific point caught my attention – the perception of unused credit lines – and the change in approach from lenders encouraging balance load-up to the perception that unused credit lines now represent unknown vulnerability to lenders. Using market intelligence assets at Experian, I thought I would take a closer look at some of the corresponding data credit score profile trends to see what color I could add to this insight. Here is what I found: • Total unused bankcard limits have decreased by $750 billion from Q3 2008 to Q3 2009 • By risk segment, the largest decline in unused limits has been within the VantageScore® credit score A consumer – the super prime consumer – where unused limits have dropped by $420 billion • More than 82 percent of unused limits reside with VantageScore® credit score A and B consumers – the super-prime and prime consumer segments So what does this mean to risk management today? If you subscribe to the approach that unused limits now represent unknown vulnerability, then this exposure does not reside with traditional “risky” consumers, rather it resides with consumers usually considered to be the least risky. So this is good news, right? Well, maybe not. Vintage analysis of recent credit trends shows that vulnerability within the top score tiers might represent more risk than one would suspect. Delinquency trends for VantageScore® credit score A and B consumers within recent vintages (2006 through 2008) show deteriorating rates of delinquency from each year’s vintage to the next. Despite a shift in loan origination volumes towards this group, the performance of recent prime and super-prime originations shows deterioration and underperformance against historical patterns. If The Tower Group’s read on the market is correct, and unused credit now represents vulnerability and not opportunity, it would be wise for lenders to reconsider where and how yesterday’s opportunity has become today’s risk.  

--by Andrew Gulledge General configuration issues Question selection- In addition to choosing questions that generally have a high percentage correct and fraud separation, consider any questions that would clearly not be a fit to your consumer population. Don’t get too trigger-happy, however, or you’ll have a spike in your “failure to generate questions” rate. Number of questions- Many people use three or four out-of-wallet questions in a Knowledge Based Authentication session, but some use more or less than that, based on their business needs. In general, more questions will provide a stricter authentication session, but might detract from the customer experience. They may also create longer handling times in a call center environment. Furthermore, it is harder to generate a lot of questions for some consumers, including thin-file types. Fewer Knowledge Based Authentication questions can be less invasive for the consumer, but limits the fraud detection value of the KBA process. Multiple choice- One advantage of this answer format is that it relies on recognition memory rather than recall memory, which is easier for the consumer. Another advantage is that it generally prevents complications associated with minor numerical errors, typos, date formatting errors and text scrubbing requirements. A disadvantage of multiple-choice, however, is that it can make educated guessing (and potentially gaming) easier for fraudsters. Fill in the blank- This is a good fit for some KBA questions, but less so with others. A simple numeric answer works well with fill in the blank (some small variance can be allowed where appropriate), but longer text strings can present complications. While undoubtedly difficult for a fraudster to guess, for example, most consumers would not know the full, official and (correct spelling) of the name to which they pay their monthly auto payment. Numeric fill in the blank questions are also good candidates for KBA in an IVR environment, where consumers can use their phone’s keypad to enter the answers.  

--by Andrew Gulledge Where does Knowledge Based Authentication fit into my decisioning strategy? Knowledge Based Authentication can fit into various parts of your authentication process. Some folks choose to put every consumer through KBA, while others only send their riskier transactions through the out-of-wallet questions. Some people use Knowledge Based Authentication to feed a manual review process, while others use a KBA failure as a hard-decline. Uses for KBA are as sundry and varied as the questions themselves. Decision Matrix- As discussed by prior bloggers, a well-engineered fraud score can provide considerable lift to any fraud risk strategy. When possible, it is a good idea to combine both score and questions into the decisioning process. This can be done with a matrixed approach—where you are more lenient on the questions if the applicant has a good fraud score, and more lenient on the score if the applicant did well on the questions. In a decision matrix, a set decision code is placed within various cells, based on fraud risk. Decision Overrides- These provide a nice complement to your standard fraud decisioning strategy. Different fraud solution vendors provide different indicators or flags with which decisioning rules can be created. For example, you might decide to fail a consumer who provides a social security number that is recorded as deceased. These rules can help to provide additional lift to the standard decisioning strategy, whether it is in addition to Knowledge Based Authentication questions alone, questions and score, etc. The overrides can be along the lines of both auto-pass and auto-fail.  

In my last blog, I discussed the basic concept of a maturation curve, as illustrated below: Exhibit 1 In Exhibit 1, we examine different vintages beginning with those loans originated by year during Q2 2002 through Q2 2008. The purpose of the vintage analysis is to identify those vintages that have a steeper slope towards delinquency, which is also known as delinquency maturation curve. The X-axis represents a timeline in months, from month of origination.  Furthermore, the Y-axis represents the 90+ delinquency rate expressed as a percentage of balances in the portfolio.  Those vintage analyses that have a steeper slope have reached a normalized level of delinquency sooner, and could in fact, have a trend line suggesting that they overshoot the expected delinquency rate for the portfolio based upon credit quality standards. So how can you use a maturation curve as a useful portfolio management tool? As a consultant, I spend a lot of time with clients trying to understand issues, such as why their charge-offs are higher than plan (budget).  I also investigate whether the reason for the excess credit costs are related to collections effectiveness, collections strategy, collections efficiency, credit quality or a poorly conceived budget. I recall one such engagement, where different functional teams within the client’s organization were pointing fingers at each other because their budget evaporated. One look at their maturation curves and I had the answers I needed. I noticed that two vintages per year had maturation curves that were pointed due north, with a much steeper curve than all other months of the year. Why would only two months or vintages of originations each year be so different than all other vintage analyses in terms of performance? I went back to my career experiences in banking, where I worked for a large regional bank that ran marketing solicitations several times yearly. Each of these programs was targeted to prospects that, in most instances, were out-of-market, or in other words, outside of the bank’s branch footprint. Bingo! I got it! The client was soliciting new customers out of his market, and was likely getting adverse selection. While he targeted the “right” customers – those with credit scores and credit attributes within an acceptable range, the best of that targeted group was not interested in accepting their offer, because they did not do business with my client, and would prefer to do business with an in-market player. Meanwhile, the lower grade prospects were accepting the offers, because it was a better deal than they could get in-market. The result was adverse selection...and what I was staring at was the "smoking gun" I’d been looking for with these two-a-year vintages (vintage analysis) that reached the moon in terms of delinquency. That’s the value of building a maturation curve analysis – to identify specific vintages that have characteristics that are more adverse than others.  I also use the information to target those adverse populations and track the performance of specific treatment strategies aimed at containing losses on those segments. You might use this to identify which originations vintages of your home equity portfolio are most likely to migrate to higher levels of delinquency; then use credit bureau attributes to identify specific borrowers for an early lifecycle treatment strategy. As that beer commercial says – “brilliant!”  

--by Jeff Bernstein In the current economic environment, many lenders and issuers across the globe are struggling to manage the volume of caseloads coming into collections. The challenge is that as these new collection cases come into collections in early phases of delinquency, the borrower is already in distress, and the opportunity to have a good outcome is diminished. One of the real “hot” items on the list of emerging best practices and innovating changes in collections is the concept of early lifecycle treatment strategy. Essentially, what we are referring to is the treatment of current and non-delinquent borrowers who are exhibiting higher risk characteristics.  There are also those who are at-risk of future default at higher levels than average. The challenge is how to identify these customers for early intervention and triage in the collections strategy process. One often-overlooked tool is the use of maturation curves to identify vintages within a portfolio that is performing worse than average. A maturation curve identifies how long from origination until a vintage or segment of the portfolio reaches a normalized rate of delinquency. Let’s assume that you are launching a new credit product into the marketplace. You begin to book new loans under the program in the current month. Beyond that month, you monitor all new loans that were originated/booked during that initial time frame which we can identify as a “vintage” of the portfolio. Each month’s originations are a separate vintage or vintage analysis, and we can track the performance of each vintage over time. How many months will it take before the “portfolio” of loans booked in that initial month reach a normal level of delinquency based on these criteria: the credit quality of the portfolio and its borrowers, typical collections servicing, delinquency reporting standards, and factor of time?  The answer would certainly depend upon the aforementioned factors, and could be graphed as follows:   Exhibit 1        In Exhibit 1, we examine different vintages beginning with those loans originated during Q2 2002, and by year Q2 2008. The purpose of the analysis is to identify those vintages that have a steeper slope towards delinquency, which is also known as a delinquency maturation curve.  The X-axis represents a timeline in months, from month of origination.  Furthermore,, the Y-axis represents the 90+ delinquency rate expressed as a percentage of balances in the portfolio. Those vintages that have a steeper slope have reached a normalized level of delinquency sooner, and could in fact, have a trend line suggesting that they overshoot the expected delinquency rate for the portfolio based upon credit quality standards. So how do we use the maturation curve as a tool? In my next blog, I will discuss how to use maturation curves to identify trends across various portfolios.  I will also examine differentiate collections issues from originations or lifecycle risk management opportunities.    

--by Andrew Gulledge Definition and examples Knowledge Based Authentication (KBA) is when you ask a consumer questions to which only they should know the answer. It is designed to prevent identity theft and other kinds of third-party fraud. Examples of Knowledge Based Authentication (also known as out-of-wallet) questions include “What is your monthly car payment?:" or “What are the last four digits of your cell number?”   KBA -- and associated fraud analytics -- are an important part of your fraud best practices strategies. What makes a good KBA question? High percentage correct A good Knowledge Based Authentication question will be easy to answer for the real consumer. Thus we tend to shy away from questions for which a high percentage of consumers give the wrong answer. Using too many of these questions will contribute to false positives in your authentication process (i.e., failing a good consumer). False positives can be costly to a business, either by losing a good customer outright or by overloading your manual review queue (putting pressure on call centers, mailers, etc.). High fraud separation It is appropriate to make an exception, however, if a question with a low percentage correct tends to show good fraud detection.  (After all, most people use a handful of KBA questions during an authentication session, so you can leave a little room for error.) Look at the fraudsters who successfully get through your authentication process and see which questions they got right and which they got wrong. The Knowledge Based Authentication questions that are your best fraud detectors will have a lower percentage correct in your fraud population, compared to the overall population. This difference is called fraud separation, and is a measure of the question’s capacity to catch the bad guys. High question generability A good Knowledge Based Authentication question will also be generable for a high percentage of consumers. It’s admirable to beat your chest and say your KBA tool offers 150 different questions. But it’s a much better idea to generate a full (and diverse) question set for over 99 percent of your consumers. Some KBA vendors tout a high number of questions, but some of these can only be generated for one or two percent of the population (if that). And, while it’s nice to be able to ask for a consumer’s SCUBA certification number, this kind of question is not likely to have much effect on your overall production.    

By: Tom Hannagan Understanding RORAC and RAROC I was hoping someone would ask about these risk management terms…and someone did. The obvious answer is that the “A” and the “O” are reversed. But, there’s more to it than that. First, let’s see how the acronyms were derived. RORAC is Return on Risk-Adjusted Capital. RAROC is Risk-Adjusted Return on Capital. Both of these five-letter abbreviations are a step up from ROE. This is natural, I suppose, since ROE, meaning Return on Equity of course, is merely a three-letter profitability ratio. A serious breakthrough in risk management and profit performance measurement will have to move up to at least six initials in its abbreviation. Nonetheless, ROE is the jumping-off point towards both RORAC and RAROC. ROE is generally Net Income divided by Equity, and ROE has many advantages over Return on Assets (ROA), which is Net Income divided by Average Assets. I promise, really, no more new acronyms in this post. The calculations themselves are pretty easy. ROA tends to tell us how effectively an organization is generating general ledger earnings on its base of assets.  This used to be the most popular way of comparing banks to each other and for banks to monitor their own performance from period to period. Many bank executives in the U.S. still prefer to use ROA, although this tends to be those at smaller banks. ROE tends to tell us how effectively an organization is taking advantage of its base of equity, or risk-based capital. This has gained in popularity for several reasons and has become the preferred measure at medium and larger U.S. banks, and all international banks. One huge reason for the growing popularity of ROE is simply that it is not asset-dependent. ROE can be applied to any line of business or any product. You must have “assets” for ROA, since one cannot divide by zero. Hopefully your Equity account is always greater than zero. If not, well, lets just say it’s too late to read about this general topic. The flexibility of basing profitability measurement on contribution to Equity allows banks with differing asset structures to be compared to each other.  This also may apply even for banks to be compared to other types of businesses. The asset-independency of ROE can also allow a bank to compare internal product lines to each other. Perhaps most importantly, this permits looking at the comparative profitability of lines of business that are almost complete opposites, like lending versus deposit services. This includes risk-based pricing considerations. This would be difficult, if even possible, using ROA. ROE also tells us how effectively a bank (or any business) is using shareholders equity. Many observers prefer ROE, since equity represents the owners’ interest in the business. As we have all learned anew in the past two years, their equity investment is fully at-risk. Equity holders are paid last, compared to other sources of funds supporting the bank. Shareholders are the last in line if the going gets rough. So, equity capital tends to be the most expensive source of funds, carrying the largest risk premium of all funding options. Its successful deployment is critical to the profit performance, even the survival, of the bank. Indeed, capital deployment, or allocation, is the most important executive decision facing the leadership of any organization. So, why bother with RORAC or RAROC? In short, it is to take risks more fully into the process of risk management within the institution. ROA and ROE are somewhat risk-adjusted, but only on a point-in-time basis and only to the extent risks are already mitigated in the net interest margin and other general ledger numbers. The Net Income figure is risk-adjusted for mitigated (hedged) interest rate risk, for mitigated operational risk (insurance expenses) and for the expected risk within the cost of credit (loan loss provision). The big risk management elements missing in general ledger-based numbers include: market risk embedded in the balance sheet and not mitigated, credit risk costs associated with an economic downturn, unmitigated operational risk, and essentially all of the strategic risk (or business risk) associated with being a banking entity. Most of these risks are summed into a lump called Unexpected Loss (UL). Okay, so I fibbed about no more new acronyms. UL is covered by the Equity account, or the solvency of the bank becomes an issue. RORAC is Net Income divided by Allocated Capital. RORAC doesn’t add much risk-adjustment to the numerator, general ledger Net Income, but it can take into account the risk of unexpected loss. It does this, by moving beyond just book or average Equity, by allocating capital, or equity, differentially to various lines of business and even specific products and clients. This, in turn, makes it possible to move towards risk-based pricing at the relationship management level as well as portfolio risk management.  This equity, or capital, allocation should be based on the relative risk of unexpected loss for the different product groups. So, it’s a big step in the right direction if you want a profitability metric that goes beyond ROE in addressing risk. And, many of us do. RAROC is Risk-Adjusted Net Income divided by Allocated Capital. RAROC does add risk-adjustment to the numerator, general ledger Net Income, by taking into account the unmitigated market risk embedded in an asset or liability. RAROC, like RORAC, also takes into account the risk of unexpected loss by allocating capital, or equity, differentially to various lines of business and even specific products and clients. So, RAROC risk-adjusts both the Net Income in the numerator AND the allocated Equity in the denominator. It is a fully risk-adjusted metric or ratio of profitability and is an ultimate goal of modern risk management. So, RORAC is a big step in the right direction and RAROC would be the full step in management of risk. RORAC can be a useful step towards RAROC. RAROC takes ROE to a fully risk-adjusted metric that can be used at the entity level.  This  can also be broken down for any and all lines of business within the organization. Thence, it can be further broken down to the product level, the client relationship level, and summarized by lender portfolio or various market segments. This kind of measurement is invaluable for a highly leveraged business that is built on managing risk successfully as much as it is on operational or marketing prowess.