As regulators continue to warn financial institutions of the looming risk posed by HELOCs reaching end of draw, many bankers are asking: Why should I be concerned? What are some proactive steps I can take now to reduce my risk? This blog addresses these questions and provides clear strategies that will keep your bank on track. Why should I be concerned? Just a quick refresher: HELOCs provide borrowers with access to untapped equity in their residences. The home is taken as collateral and these loans typically have a draw period from five to 10 years. At the end of the draw period, the loan becomes amortized and monthly payments could increase by hundreds of dollars. This payment increase could be debilitating for borrowers already facing financial hardships. The cascading affect on consumer liquidity could also impact both credit card and car loan portfolios as borrowers begin choosing what debt they will pay first. The breadth of the HELOC risk is outlined in an excerpt from a recent Experian white paper. The chart below illustrates the large volume of outstanding loans that were originated from 2005 to 2008. The majority of the loans that originated prior to 2005 are in the repayment phase (as can be seen with the lower amount of dollars outstanding). HELOCs that originated from 2005 to 2008 constitute $236 billion outstanding. This group of loans is nearing the repayment phase, and this analysis examines what will happen to these loans as they enter repayment, and what will happen to consumers’ other loans. What can you do now? The first step is to perform a portfolio review to assess the extent of your exposure. This process is a triage of sorts that will allow you to first address borrowers with higher risk profiles. This process is outlined below in this excerpt from Experian’s HELOC white paper. By segmenting the population, lenders can also identify consumers who may no longer be credit qualified. In turn, they can work to mitigate payment shock and identify opportunities to retain those with the best credit quality. For consumers with good credit but insufficient equity (blue box), lenders can work with the borrowers to extend the terms or provide payment flexibility. For consumers with good credit but sufficient equity (purple box), lenders can work with the borrowers to refinance into a new loan, providing more competitive pricing and a higher level of customer service. For consumers with good credit but insufficient equity (teal box), a loan modification and credit education program might help these borrowers realize any upcoming payment shock while minimizing credit losses. The next step is to determine how you move forward with different customers segments. Here are a couple of options: Loan Modification: This can help borrowers potentially reduce their monthly payments. Workouts and modification arrangements should be consistent with the nature of the borrower’s specific hardship and have sustainable payment requirements. Credit Education: Consumers who can improve their credit profiles have more options for refinancing and general loan approval. This equates to a win-win for both the borrower and lender. HELOCs do not have to pose a significant risk to financial institutions. By being proactive, understanding your portfolio exposure and helping borrowers adjust to payment changes, banks can continue to improve the health of their loan portfolios. Ancin Cooley is principal with Synergy Bank Consulting, a national credit risk management and strategic planning firm. Synergy provides a rangeof risk management services to financial institutions, which include loan reviews, IT audits, internal audits, and regulatory compliance reviews. As principal, Ancin manages a growing portfolio of clients throughout the United States.
Experian defines how businesses should approach Identity Relationship Management for identity and devices to enable better fraud protection through our latest perspective paper, The 3 Pillars of Identity Relationship Management: How organizations can reduce risk and increase engagement.
Ten years after homeowners took advantage of a thriving real-estate market to borrow against their homes, many are falling behind on payments, potentially leaving banks with millions of dollars in losses tied to housing. Most banks likely have homeowners with home-equity lines of credit (HELOCs) nearing end-of-draw within their portfolio, as more than $236 billion remain outstanding on loans originated between 2004 and 2007. The reality is many consumers are unprepared to repay their HELOCs. In 2014, borrowers who signed up for HELOCs in 2004 were 30 or more days late on $1.8 billion worth of outstanding balances just four months after principal payments began, reported RealtyTrac. That accounts for 4.3 percent of the balance on outstanding 2004 HELOCs. In practice, this is what an average consumer faces at end-of-draw: A borrower has $100,000 in HELOC debt. During the draw period, he makes just interest-only payments. If the interest rate is 6 percent, then the monthly payment is $500. Fast forward 10 years to the pay-down period. The borrower still has the $100,000 debt and five years to repay the loan. If the interest rate is 6 percent, then the monthly payment for principal and interest is $1,933 – nearly four times the draw payment. For many borrowers, such a massive additional monthly payment is unmanageable, leaving many with the belief that they are unable to repay the loan. The Experian study also revealed consumer behaviors in the HELOC end-of-draw universe: People delinquent on their HELOC are also more likely to be delinquent on other types of debt. If consumers are 90 days past due on their HELOC at end of draw, there is a 112 percent, 48.5 percent and 24 percent increase in delinquency on their mortgage, auto loan and credit cards, respectively People with HELOCs at end-of-draw are more likely to both close and open other HELOCs in the next 12 months That same group is also more likely to open or close a mortgage in the next 12 months. Now is the time to assess borrowers’ ability to repay their HELOC, and to give them solutions for repayment to minimize their payment stress. Identify borrowers with HELOCs nearing end of term and the loan terms to determine their potential payment stress Find opportunities to keep borrowers with the best credit quality. This could mean working with borrowers to extend the loan terms or providing payment flexibility Consider the opportunities. Consumers who have the ability to pay may also seek another HELOC as their loan comes to an end or they may shop for other credit products, such as a personal loan.
For years, organizations have used data to improve operational efficiencies and cost savings. Now they are beginning to use data to optimize or improve nearly every aspect of their organization. When justifying the return on investment for managing data quality, consider these findings from a recent Experian Data Quality survey of U.S. organizations: 23% of customer data is believed to be inaccurate 75% think inaccurate data is undermining their ability to provide an excellent customer experience 79% say it is difficult to predict when and where the next data challenge will arise 77% believe data management is driven by multiple stakeholders in their organization rather than by a single data specialist >>Download: The 2016 global data management benchmark report
Fraudsters invited into bank branches The days of sending an invitation in the mail have for the most part gone by the wayside. Aside from special invitations for weddings and milestone anniversaries, electronic and email invitations have become the norm. However, one major party planner has refused to change practices — banks inviting fraudsters into their banking centers. As a fraud consultant I have the privilege of meeting many banking professionals, and I hear the same issues and struggles over and over again. It’s clear that the rapid increase of fraudulent account-opening applications are top of mind to many. What the executives making policy don’t realize is they’re facing fraud because they’re literally inviting the fraudsters into their branches. Think I’m exaggerating? Let me explain. I often encounter bank policymakers who explain their practice of directing a suspicious person into a banking center. Yes, many banks still direct applicants who cannot be properly verified over the phone or online into their banking center to show proof of identity. Directing or inviting criminals into your bank instead of trying to keep them out is an outdated, high-risk practice — what good can possibly come of it? The argument I typically hear from non-fraud banking professionals: “The bad guys know that if they come into the bank we will have them on film.” Other arguments include that the bad guys are not typically bold enough to actually come into the banking center or that their physical security guards monitor high-traffic banking centers. But often that is where bank policies and employee training ends. Based on my years of experience dealing with banks of all sizes, from the top three global card issuers to small regional banks, let me poke a few holes in the theory that it is a good deterrent to invite perpetrators into your banking center. Let’s role-play how my conversation goes: Me: “When an underwriter with limited fraud training making the decision to direct a suspicious applicant into a banking center, what is the policy criteria to do so?” Bank policymaker: (typical response) “What do you mean?” Me: “What high-risk authentication was used by the underwriter to make the decision to extend an invitation to a high-risk applicant to come into the banking center? If the applicant failed your high-risk authentication questions and you were not able to properly identify them, what authentication tools do the branch managers have that the underwriters do not?” Bank: “Nothing, but they can usually tell when someone is nervous or seems suspicious.” Me: “Then what training do they receive to identify suspicious behaviors?” (You guessed it …) Bank: “None.” (I then switch to the importance of customer experience.) Me: “How do you notify the banking center in advance that the suspicious applicant was invited to come in to provide additional verification?” Bank: “We do not have a policy to notify the banking center in advance.” Me: “What is considered acceptable documentation? And are banking center employees trained on how to review utility statements, state ID cards, drivers’ licenses or other accepted media?“ Bank: “We do not have a list of acceptable documentation that can be used for verification; it is up to the discretion of the banking center representative.” Me: “How do you ensure the physical safety of your employees and customers when you knowingly invite fraudsters and criminals into your banking center? How do you turn down or ask the suspicious person to leave because they do not have sufficient documentation to move forward with the original application for credit? If a suspicious person provides your employee with a possible stolen identification card, is that employee expected to keep it and notify police or return it to the applicant? Are employees expected to make a photocopy of the documentation provided?” The response that I usually receive is, “I am not really sure.” I hope by now you are seeing the risk of these types of outdated practices on suspicious credit applications. The fact is that technology has allowed criminals to make fairly convincing identification at a very low cost. If employees in banking centers are not equipped, properly trained, and well-documented procedures do not exist in your fraud program — perhaps it’s time to reconsider the practice or seek the advice of industry experts. I have spent two decades trying to keep bad guys out of banks, but I can’t help but wonder — why do some still send open invitations to criminals to come visit their bank? If you are not yet ready to stop this type of bad behavior, at the very least you must develop comprehensive end-to-end policies to properly handle such events. This fraud prevention tactic to invite perpetrators into banks was adopted long before the age of real-time decisions, robust fraud scores, big data, decision analytics, knowledge-based authentication, one-time passcodes, mobile banking and biometrics. The world we bank in has changed dramatically in the past five years; customers expect more and tolerate less. If a seamless customer experience and reducing account-opening and first-party fraud are part of your strategic plan, then it is time to consider Experian fraud solutions and consulting.
Time heals countless things, including credit scores. Many of the seven million people who saw their VantageScore® credit scores drop to sub-prime levels after suffering a foreclosure or short sale during the Great Recession have recovered and are back in the housing market. These Boomerang Buyers — people who foreclosed or short sold between 2007 and 2014 and have opened a new mortgage — will be an important segment of the real estate market in the coming years. According to Experian data, through June 2016 roughly 800,000 people had boomeranged, with Los Angeles, Phoenix, and Sacramento housing the most buyers. Some analysts believe more than three million Americans will become eligible for a home over the next three years. Are potential Boomerang Buyers a great opportunity to boost market share or a high risk for a portfolio? Early trends are positive. The majority of Boomerang Buyers who opened mortgages between 2011 and June 2016 are current on their debts. An Experian study revealed more than 29 percent of those who short sold have boomeranged, and just 1.5 percent are delinquent on their mortgage —falling below the national average of 2.8 percent. This group is also ahead of or even with the national average for delinquency on auto loans (1.2 percent vs. the national average of 2.2 percent), bankcards (3 percent vs. 4.3 percent) and retail (even at 2.7 percent). For those Boomerang Buyers who had foreclosed, the numbers are also strong. More than 12 percent have boomeranged, with just 3 percent delinquent on their mortgage. They also match or are below national average delinquency rates on auto loans (1.9 percent) and bankcards (4.1 percent), and have a slightly higher delinquency rate for retail (3.5 percent). Due to their positive credit behaviors, Boomerang Buyers also have higher VantageScore® credit scores than before. On average, the overall non-boomerang group’s credit score sunk during a foreclosure but went up 10 percent higher than before the foreclosure, and Boomerang Buyers rose by nearly 14 percent. For people who previously had a prime credit score, their number dropped by nearly 5 percent, while those who boomeranged returned to the score they had prior to the foreclosure. By comparison, the overall non-boomerang and boomerang group saw their credit score drop during a short sale and increase more than 11 percent from before the short sale. For people who previously had prime credit, they dropped 2 percent while those who boomeranged were almost flat to where they were before the short sale. Another part of the equation is the stabilized housing market and relatively low loan-to-value (LTV) limits that lenders have maintained. In the past, borrowers most often strategically defaulted on their mortgages when their LTV ratios were well over 100 percent. So as long as lenders maintain relatively low LTV limits and the housing market remains strong, strategic default is unlikely to re-emerge as a risk.
Experian’s annual global fraud report reveals trends that can help organizations mitigate fraud and improve the customer experience: Apply the right-sized fraud solutions to reduce unnecessary customer disruption Ensure you have a universal consumer view Select fraud solutions that are future-proof As fraudsters evolve, losses are climbing and the status quo is no longer effective. Organizations should be as forward-looking in fighting fraud as they are in business operations and marketing. >> Global Business Trends: Protecting Growth Ambitions Against Rising Fraud Threats
In an attempt to stay ahead of fraud, systems have become more complex, more expensive and even more difficult to manage, leading to more friction for customers. How extensive is this impact? 30% of online customers are interrupted to catch one fraudulent attempt One in 10 new applicants may be an imposter using breached data $40 billion of legitimate customer sales are declined annually Businesses must continue their efforts to protect all parties’ interests if they are to thrive in this new world of rapid technological growth. >> Infographic: Global fraud trends
We are excited to announce that Experian Fraud and Identity Solutions is presenting at FinovateFall 2016! Finovate conferences showcase cutting-edge banking and financial technology in a unique demo-only format. Held twice a year, the conferences bring together the leaders from top financial institutions, fintech companies, investors from around the globe, and fintech media to share and promote the most innovative financial technology solutions. "Experian’s Fraud and Identity Solutions is a leader in customer-centric identity and fraud solutions, providing fraud management solutions to some of the world’s largest brands in financial services, insurance, and retail," said Adam Fingersh, general manager and senior vice president of Fraud and Identity Solutions in North America. "We will introduce our Fraud and Identity Solutions and promote our newly released CrossCore platform. CrossCore puts more control in the hands of fraud teams to adapt and deploy strategies that keep up with the pace of fraud while reducing burdens on IT and data science teams." Fingersh and John Sarreal, senior director of Fraud and Identity product management at Experian, are presenting the 7-minute demo focusing on the key CrossCore capabilities, and how CrossCore manages fraud and identity services through its flexible API; open, plug-and-play platform; and powerful workflow and strategy design capabilities. In Forrester’s 2016 “Vendor Landscape: Mobile Fraud Management”, Experian Fraud and Identity Solutions was cited as having the most capabilities and one of the highest estimated revenues in total fraud management in the market, between $200 million and $250 million. Join us for the event on September 8-9 in New York. Experian also has an exclusive 20% off discount code (Experian20FF16) to get even more savings! For more information on the event or to view videos of previous demos, please visit finovate.com.
As credit behavior and economic conditions continue to evolve, using a model that is validated regularly can give lenders greater confidence in the model’s performance. VantageScore® Solutions, LLC validates all its models annually to promote transparency and support financial institutions with model governance. The results of the most recent validation demonstrate the consistent ability of VantageScore® to accurately score more than 30 million to 35 million consumers considered unscoreable by other models — including 9.5 million Hispanic and African-American consumers. The findings reinforce the importance of using advanced credit scoring models to make more accurate decisions while providing consumers with access to fair and equitable credit. >> VantageScore® Annual Validation Results 2016 VantageScore® is a registered trademark of VantageScore Solutions, LLC
Congress recently took several actions signaling a growing interest in regulatory issues surrounding the Fintech sector. This growing attention follows a number of recent inquiries by federal and state regulators into the business practices in the industry. Subcommittee takes a deep dive into Fintech and OML regulatory landscape In July, the House Subcommittee on Financial Institutions and Consumer Credit held a hearing entitled Examining the Opportunities and Challenges with Financial Technology (“Fintech”). Witnesses and lawmakers voiced optimism that online marketplace lending can help to expand access to capital for consumers and small businesses, but the hearing also focused on a growing schism as to whether new regulations or changes to the underlying framework is necessary to ensure consumers are protected. Some lawmakers and the witness from the American Banking Association expressed concerns that the Fintech and marketplace lenders may benefit from being outside of the supervisory scope of prudential regulators and the Consumer Financial Protection Bureau (CFPB). Witnesses from the marketplace lending industry argued that they are obligated to meet all of the same regulatory compliance requirements as traditional lenders. Rep. McHenry introduces package of Fintech bills aimed at spurring innovation In addition, Congressman Patrick McHenry (R-NC), a member of the House Republican Leadership team and the Vice Chairman of the House Financial Services Committee, introduced two bills this month aimed at spurring innovation in the Fintech industry. H.R. 5724, the Protecting Consumers’ Access to Credit Act of 2016, would clarify that federal law preempts a loan’s interest rate as valid when made. The bill is in response to the Supreme Court’s recent decision not to hear Madden v Midland, a case in which the Second Circuit court ruled that the National Bank Act does not have a preemptive effect after the national bank has sold or otherwise assigned the loan to another party. The reading of this law has created uncertainty for Fintech companies and the banks that partner with them. H.R. 5725, the IRS Data Verification Modernization Act of 2016, requires the IRS to automate the Income Verification Express Service process by creating an Application Programming Interface (API). The legislation is aimed at speeding up and improving the automation of the loan application process. In particular, it is aimed at streamlining the process by which lenders gain access to tax transcript data. Currently, lenders may require applicants to fill out IRS form “4506-T,” which gives the lender the right to access a summarized version of their tax transcript as part of the process to confirm certain data points on their application. According to industry reports, this manual process at the IRS takes two to eight days, creating unnecessary delays for Fintech companies and banks that rely on leveraging data and technology to make faster, informed decision for consumer and small business lending Both bills have been referred to the House Financial Services Committee for review.
A recent national survey by Experian revealed opportunities for businesses to build relationships with future homebuyers before they’re ready to obtain a loan. Insights include: 35% of future buyers said they don’t know what steps to take to qualify for a larger loan 75% of future buyers are not preapproved for a home loan 29% of those surveyed would purchase a more expensive home if they had better credit and could qualify for a larger loan A large portion of near-future homebuyers are millennials. Building relationships with this generation now will benefit financial institutions in the future. >> White paper: Building lasting relationships with millennials
Many fraud and compliance teams are struggling to keep pace with new business dynamics. Here are several of the many mobile device trends affecting business today: 35% year-over-year growth in mobile commerce from 2014-2015 Value of mobile payment transactions is forecasted to reach more than $27 billion in 2016 45% of smartphone owners use a mobile device to make a purchase every month This rapid growth only reinforces the need for aggressive fraud prevention strategies and the adoption of new technologies to prepare for the latest emerging cybersecurity threats. >> Forrester's 2016 Vendor Landscape: Mobile Fraud Management Solutions Report
Every day, millions of new things get connected online, such as toasters, heart monitors and cars. Many of these things have weak security controls that create vulnerabilities in critical private networks. As more products get connected, the casual mindset about the security risks inherent in the Internet of Things must begin to change. Here are 12 tips to help safeguard your systems from the Internet of Things. >> Securing the Internet of Things
According to a national survey by Experian, college students may be receiving their degrees, but their financial management knowledge still needs some schooling. The survey reveals some troubling data about recent graduates: Average student loan debt is $22,813 31% have maxed out a credit card 39% have accepted credit card terms and conditions without reading them Learning to manage debt and finances properly is key to young adults’ future financial success. Since students aren’t receiving credit and debt management education in college, they need to educate themselves proactively. Credit education resources are available on Experian's Website. >> Experian College Graduate Survey Report