By: Staci Baker As the economy has been hit by the hardest recession since the Great Depression, many people wonder how and when it will recover. And, once we start to see recovery, will consumer credit return to what it once was? In a recent Experian-Oliver Wyman Market Intelligence Report quarterly webinar, 70% of the respondents in a survey said they believe consumer debt will return to pre-2008 levels. Clearly, many believe that consumer spending and borrowing will return, despite the fact that consumer credit card borrowing recently declined for the 24th straight month*. Assuming that this optimism is valid, what can credit card lenders do to evaluate the risk levels of potential customers as they attempt to grow their portfolios? For lenders, determining who needs credit, as well as whom to lend to in this economic environment, can be quite challenging. However, there are many tools available to assist lenders in assessing credit risk and growing their portfolio. Many lenders look at a consumer’s credit score, such as the tri-bureau VantageScore, to evaluate their credit worthiness. By utilizing an individual’s VantageScore, a lender is able to determine potential customer risk levels. Another way to evaluate a consumer’s credit worthiness is to evaluate a population using credit attributes. Based on the attributes a lender is looking for in their portfolio, they can see improvement in evaluating risk prediction in their portfolio using pre-determined attributes, especially those specifically designed for the credit card industry. There are also models that can help lenders predict when a consumer is likely to be in the market for a new loan or account. Experian’s In the Market Models provide lenders with product-specific segmentation tools that can be combined with risk scores to enhance the efficiency and effectiveness of their offers. To identify the optimal cross-sell and line management decisions based on an individual customer’s risk score and potential value, a lender can also utilize optimization tools. Optimization, combined with a viable risk management strategy, can assist a lender to achieve a healthy portfolio growth in a highly constrained environment. Although lenders will need to determine the best method to meet their objectives, these are just a few of the many tools available that will assist them in correctly growing their lending portfolios. ____________________ * http://www.usatoday.com/money/economy/2010-10-07-consumer-credit_N.htm
By: Margarita Lim You may be surprised to learn that identity theft isn’t just a crime committed by an individual or individuals. There are identity theft rings that are organized and operated like corporations. A recent Justice Department press release described such an operation in New Jersey that involved 53 individuals who took part in a known fraud activity called Bust Out Fraud. Basically, the fraud ring purchased valid social security cards and then sold the social security cards to customers who then obtained driver’s licenses and other proof of identity-type cards. The fraud ring then built up the credit scores of these customers by adding them to existing credit card accounts. Once the customers with the fraudulent identities achieved good credit scores, then they opened their own fraudulent bank accounts, credit cards, lines of credit, etc. The credit cards were used to make fraudulent purchases or rack up charges with vendors in co-hoots with the fraud ring and the fraudulent bank accounts were used to pay off the charge accounts or the charges went unpaid. Fraud trends like these cost banks, credit card companies and many others millions of dollars – costs that ultimately get passed on to you and me, the consumers. Fortunately, Experian has Fraud Products that can help companies minimize fraud losses from Bust Out Fraud as well as other types of fraud. Our BustOut Score helps decrease bust out losses by predicting and detecting bust out frauds one to three months in advance of the event happening. In addition, we have Fraud Shield Indicators or fraud alerts available on credit reports that flag when there is a recent or new authorized user added to an established credit account. Experian supports Identity Theft Prevention Programs by offering highly accurate consumer identity verification services. We’re not reliant solely on credit bureau data and are able to use multi-sourced data to confirm different components of a consumer’s identity – name, address, date of birth, etc. Our consumer authentication and fraud prevention product, Precise ID, and our knowledge based authentication product, Knowledge IQ, are highly respected in the marketplace for their reliability, quality and accuracy.
By: Wendy Greenawalt In a recent poll conducted by Experian, 82 percent of the respondents indicated they were undecided or currently assessing options for complying with the Risk-Based Pricing Rule. If your organization is also considering which compliance option is right based on your unique circumstances, I would encourage you to act soon, as the deadline is quickly approaching. Some organizations have decided that they will be utilizing the Credit Score Disclosure Notice as their preferred compliance option, as it is supplied to all consumers and requires minimal procedural changes and maintenance. While at first glance this option may seem to be the most streamlined approach, it does come with its own considerations. The Disclosure Notice form letter is straightforward and includes minimal inputs such as the consumers credit score, score source, range of the score and a corresponding score distribution. The downside is that the Disclosure Notice must be provided individually to all consumers, even those that reside at the same address, and must be given in a format in which the consumer can keep/reference. This means there will be an inherently higher cost to mail or electronically provide the form to each applicant and obtain the required eSign confirmation (where applicable). The score distributions must be updated on a regular basis and lenders must be prepared to answer consumer questions related to scores and how they are derived. Conversely, the Risk Based Pricing Notice, which is the primary compliance option outlined in the rule, is provided to a specific segment of consumers and can be provided verbally, electronically or in writing. A model form is supplied in the ruling and requires a lender to provide the credit reporting agency used to obtain the consumers credit data and contact information for the agency. Some lenders feel the notice has awkward language; however I tend to think most consumers have a basic understanding of their credit and the language in the form will not provide a negative consumer experience. The language tells the consumer “the terms offered to you may be less favorable than the terms offered to consumers who have better credit histories”. The disadvantage of this notice is that a lender must determine which consumers must receive the notice, and this policy must be updated periodically. Fortunately, the ruling states that a lender must only review the policy every two years. For most lenders this will not be a problem as they perform more frequent reviews and validations of their portfolios and determining which consumers receive a notice can be performed at the same time with minimal resources. Lenders should carefully consider their compliance obligations in relation to the ruling and determine which notice is best for their organization given resource, maintenance and cost requirements. The January 1, 2011 deadline is looming and there is no indication that the effective date will be extended. I suspect the regulatory requirements will continue to evolve over the next few years with the creation of the Consumer Financial Protection Agency, which has the authority to set and enforce rules under 12 federal laws and the implications will continue to put a strain on lending institutions.
By: Margarita Lim Consumer data has increasingly become commoditized over the years. There’s a lot of it and it’s arguably more easily obtainable. Social Security number and date of birth information was once considered confidential information. Today, those data elements in addition to traditional consumer data such as name, address and phone number are more publicly available (either legitimately or illegitimately). The advent and popularity of social network Internet sites have also made considerable information about a person’s life – both professional and personal, available for anyone’s viewing pleasure. So the question is…how much is too much information? If you’re a consumer who is particular about privacy, then you’ll have a lower threshold. On the other hand, if you’re a business trying to minimize fraud losses, then you’re at the other end of the spectrum - you can never have enough information to help prevent fraud – especially when you’re trying to keep up with fraud trends. Data is a key element in fraud prevention. Experian has access to many data assets and has a reputation for providing high quality fraud products in the marketplace. The data we use in our fraud products comes from multiple sources and sets us apart from our competitors because corroborated data is more reliable than data from a single source. Having access to multiple data sources is especially beneficial in our Knowledge Based Authentication product where the different sources provide data that is critical to generating out of wallet questions. Since companies rely on our fraud products to comply with the government’s Red Flag Rules and support Identity Theft Prevention Programs, it is extremely important that we have as much data as possible in our arsenal to thwart fraudsters’ activities and prevent consumers from being victimized by criminals. Keep in mind that these programs are only as good as the data used to confirm a person’s identity. Although information can be a double-edged sword, I don’t think one can have too much information especially when the goal is to minimize fraud.
By: Kenneth Pruett I really thought I was going to be on easy street after receiving two emails in less than a week. The first email was telling me about some long lost relative in the UK who passed away over 10 years ago. His riches, which were over $20million dollars, would be forfeited to the government if an heir to the fortune did not claim the money. I was impressed how they figured out that I was the long lost “heir” to this millionaire just by looking at my email address. They also identified me specifically by calling me by name, “Dear Sir”. The other email was a bit more intriguing. It involved a suitcase full of money. This was sent to me by a woman, who was in an abusive relationship but somehow had a chest full of money in America. For a certain % of the money, she was willing to pay me for my efforts to help her gain access to the suitcase and its contents. I am still surprised at just how many people fall victim to these types of email scams. They have been going on for quite some time, commonly known as the Nigerian 419 scam. I have noticed that the emails have changed a bit and seem to have become more convincing. The scammers also seem to be a bit more patient and work harder to gain the victims confidence in the legitimacy of the transaction. Individuals who give their information to these scammers will soon find out what a big mistake they have made. The goal of these groups is to gain access to a consumer’s money. They also will attempt to gather personal and banking information. Some victims of these scams may end up having their identity stolen. If they do attempt to use the identity information, they will typically make multiple attempts in a short period of time to establish credit. One way to help fight this type of organized fraud ring activity is to use velocity checks to track data elements. For example, a bank may want to know if a Social Security number has been used more than once within a certain period of time. Fraud analytic studies have also found that tracking data elements across multiple customers can also be very predictive in preventing fraud tied to identity theft rings. Elements often tracked are things like addresses, Social Security numbers and phone numbers. If these scammers attempt to take over consumers current bank accounts, they may attempt to change the address and possibly the phone number on the account. This is to prevent the true consumer from getting a phone call or mail relating to their account changes. Before making these changes, many entities often send out letters or make calls to the prior information before officially making these changes in their systems. One other way to protect against account take over is to run the address and/or phone number against database of known frauds. A National Fraud Database can be helpful in identifying addresses that have been used in previous fraud activity. The Nigerian 419 scams will continue to be a problem. The need for money is just too great for some people to resist. For Banks, Card issuers, and Credit Unions, it is wise to put tools in place to help fight identity theft. This scam only represents a sample of the various fraudulent groups out there who make their living by ripping off these types of businesses. As I often say to my customers… I have done about everything in the fraud space, except commit it, which is the most profitable area. Good luck in your efforts to help us fight this ongoing problem.
By: Kari Michel Credit bureau data has been used for many years to develop credit risk models, bankruptcy scores, profitability models, and response models to name a few. For the utility industry (water and power companies), a new score is available to help them administer more efficiently their internal low-income assistance programs. One challenge that utility companies face is to identify those consumers who clearly qualify for low-income assistance in a more automated process in order to reduce the number of applications that require manual intervention. Utility companies are starting to use scoring models to help them determine the likelihood that a customer will qualify for low-income assistance from their local utility. In a recent Experian case study, a medium-sized municipal utility company in California conducted a test using Experian’s Financial Assistance Checker to understand the benefit of using this score in their recertification process. The test showed a reduction of manual review of about 40% of the test file and they expect a 40-50% reduction in manual review in the future. The inclusion of the score in the recertification process will reduce costs and make their low income assistance program more efficient and provide an excellent example of the utility’s efforts to make a positive impact on the community.
By: Wendy Greenawalt 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: Staci Baker On September 12, 2010, the new Basel III rules were passed in Basel, Switzerland. These new rules aim to increase the liquidity of banks over the next decade, thereby mitigating the risk of bank failures and mergers that transpired during the recent financial crisis. Currently, banks must maintain capital reserves of 4% on their balance sheet to account for enterprise risk. Starting January 1, 2013, banks will be required to progressively increase their capital reserves, known as tier 1 capital, to 4.5%. By the end of 2019, this reserve will need to be 6%. Banks will also be required to keep an emergency reserve, or “conservation buffer,” of 2.5%. What does this mean for banks? And, what are some tools that banks can use in assessing credit risk? By increasing capital reserves, banks will be more stable in times of economic hardship. The conservation buffer is meant to help absorb losses during times of economic stress, which means banks will be in a better position to maintain economic progress in the most challenging economic circumstances. The capital reserve designated by the Group of Governors and Heads of Supervision is the minimum requirement each bank will be held to. Each bank will need to assess their current risk levels, and run stress tests to ensure they are in a good financial position, and are able to sustain strong financial health during a failing economy. Stress tests should be run for different time intervals, which will allow lenders to assess future losses and to plan capital satisfactoriness accordingly. This type of credit risk analysis is possible through applications such as Moody’s CreditCycle Plus, powered by Experian, that allow for stress testing, and profit and loss forecasting. These applications will measure future performance of consumer credit portfolios under various economic scenarios, measured against industry benchmarks. ______________ Bank for International Settlements, 9/12/10, http://bis.org/press/p100912.htm
By: Kennis Wong In the last post, I emphasized the importance of fraud detection even after an account has been approved. If information gathered later indicates an application was fraudulent, credit issuers can still take action on the account to minimize fraud losses. Monitoring your internal systems to find suspicious activities is one way to do it. If the account holder has unusual purchase patterns, such as spending $2000 at a dry cleaner, you may want to stop and have a closer look. But more revealing would be the bigger picture – Is the account holder developing other financial relationships? Do these other applications indicate high identity theft risk? Are there any unusual patterns across the multiple financial relationships? The tricky part is finding the related applications. If you are looking for applications that use the same SSN, name, DOB, address and phone number, you may be missing information that helps detect fraud. Fraudsters often mutate elements of the PIIs when they use stolen identities to hide their fraudulent activity. If you link related applications together, you can then look for unusual patterns collectively. Find that the same social security number was used 10 times, with different addresses, all in the same week? Bad sign. Individual signs may help very little. False-positives and fraud referral rates may be too high if your action is based on just one or two signs. That’s why Experian recommends using a risk-based method for minimizing fraud instead of a rule-based method. You need fraud analytics to put all signs together in a way that is predictive of identity theft. Timeliness is the key to successful fraud account management. If the identity fraudster has already used all available credit on a credit line, then it is too late to minimize fraud and action on the account. The only benefit at that point -- saving time by telling your collection department not to waste effort attempting to collect on the account.
By: Kennis Wong Most lenders authenticate applicants before they extend credit. With identity theft so prevalent today, not ensuring you are dealing with the real consumer before starting a customer relationship is like playing Russian roulette. Especially for installment loans, when the goods are out, the chance of recouping the money in the case of identity theft is slim. Even for secured loans like car loans, fraudsters can always cash out the car in Mexico, and you will never see the shadow of it again. No wonder lenders place a lot of emphasis on checking people’s identities at application. For many cases, this is really the key point where identity fraud can be stopped. But it is not necessarily true for all type of lenders. For revolving loans, lenders could still minimize fraud losses after credit application is approved, as long as available credit still exists. You can imagine that once a fraudster gets hold of someone’s identity, s/he is likely to maximize its value by using it again and again. Therefore, there should be more credit activities, hence more evidence of misuse, by Day 7 than on Day 1. In the unfortunate event that a fraudster passes authentication on Day 1, it is still possible that you discover the fraud on Day 7 if you have new information. If you are a credit card issuer, it means you can still stop the action before the credit card gets to the fraudster’s hand and gets activated. Unfortunately for a lot of smaller lenders, the due diligence stops at the point of application. Even larger lenders only start their “account management” fraud detection at the point of high-risk transaction or payment. By not watching the new customer relationship closer and studying fraud trends, they are missing out fraud loss reduction opportunity.
By: Kristan Frend It seems as though desperate times call for desperate measures- with revenues down and business loans tougher than ever to get, “shelf” and “shell” companies appear to be on the rise. First let’s look at the difference between the two: Shelf companies are defined as corporations formed in a low-tax, low-regulation state in order to be sold off for its excellent credit rating. According to the Better Business Bureau, off-the-shelf structures were historically used to streamline a start-up, but selling them as a way to get around credit guidelines is new, making them unethical and possibly illegal. Shell companies are characterized as fictitious entities created for the sole purpose of committing fraud. They often provide a convenient method for money laundering because they are easy and inexpensive to form and operate. These companies typically do not have a physical presence, although some may set up a storefront. According to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network, shell companies may even purchase corporate office “service packages” in order to appear to have established a more significant local presence. These packages often include a state business license, a local street address, an office that is staffed during business hours, a local telephone listing with a receptionist and 24-hour personalized voice mail. In one recent bust out fraud scenario, a shell company operated out of an office building and signed up for service with a voice over Internet protocol (VoIP) provider. While the VoIP provider typically conducts on-site visits to all new accounts, this step was skipped because the account was acquired through a channel partner. During months one and two, the account maintained normal usage patterns and invoices were paid promptly. In month three, the account’s international toll activity spiked, causing the provider to question the unusual account activity. The customer responded with a seemingly legitimate business explanation of activity and offered additional documentation. However, the following month the account contact and business disappeared, leaving the VoIP provider with a substantial five figure loss. A follow-up visit to the business showed a vacant office suite. While it’s unrealistic to think all shelf and shell companies can be identified, there are some tools that can help you verify businesses, identify repeat offenders, and minimize fraud losses. In the example mention above, post-loss account review through Experian’s BizID identified an obvious address discrepancy - 12 businesses all listed at the same address, suggesting that the perpetrator set up numerous businesses and victimized multiple organizations. The moral of the story? Avoid being the next victim and refine and revisit your fraud best practices today. Click here for more information on Experian\'s BizID
By: Kristan Frend As if business owners need one more thing to worry about — according to the Javelin Strategy & Research’s 2010 Identity Fraud Survey Report, respondents who defined themselves as “self-employed” or “small business owners” were one-and-a-half times more likely to be victims of identity theft. Intuitively this makes sense- business owners exposure would be higher than the average consumer as their information is viewed more often due to the broad array of business service needs. Also consider the fact that until recently, multiple states had public records containing proprietors social security numbers as tax identification numbers readily accessible on-line. What a perfect storm this has all created! Javelin’s report also explained that while the average fraud incidence for business owners was lower than the average consumers, small business owner’s consumer costs were higher. In other words the small business owner suffered more out of pocket costs for identity theft losses than the average consumer. Experts believe this is due to the fact that commercial accounts often do not receive the same fraud guarantee protections that consumer accounts are afforded. While compliance regulations such as Red Flags Rules will enhance consumer safety, institutions must further develop their prevention and protection methods beyond what is legally required to sufficiently protect their small business customers from future fraud attacks. Small business owner fraud and the challenges organizations face in identifying and mitigating these losses are frequently overlooked and overshadowed by consumer fraud. Simply put, fraud is prevented because fraud is detected- verifying that the business owners is who they say they are using multiple data sources is critical to identifying applicant irregularities and protecting small business owners. A well-executed fraud strategy is more than just good business – it helps reduce small business customer acquisition costs and ultimately allows you to make better business decisions, creating a mutually beneficial relationship between your organization and the small business owner.
By: Kari Michel What are your acquisition strategies to increase consumer lending and gain market share? This blog will discuss new approaches to create segment-based targeting campaigns and the ability to precisely time the offer delivery with consumer needs. The most aggressive and successful banks are using need and attitudinal segmentation, coupled with models that identify consumers in the market for loan products. The return on marketing investment from these refined marketing efforts often exceed 350%, measured on a net of control basis, after all marketing costs. Here is a case study, using Experian tools, showing how one marketer used segment-based targeting, tailoring and timing to increase their response rate 145% over a competitor’s product. In the highly competitive credit card arena, a new business model is emerging that is dependent on acquiring new accounts from consumers that are grouped into specific behavior segments (Credit Hungry Card Switchers and Case Oriented Skeptics) and looking at consumers that were in the market, as well as had the highest likelihood of opening a bankcard account within the next 1 – 4 months. Test Results Total Competitor Experian Experian lift Quantity 624,000 623,953 Response Rate % 2.09% 3.03% 145% Actual Responses 13,035 18,902 Booked Rate % 1.64% 2.24% 137% Actual Booked 10,208 13,989 Approval Rate % 78.30% 74.01% 95% In addition to a 145% lift in response rate, over 3,700 more accounts were booked over the competition. These same tools, “In The Market Models” (developed using credit bureau data) and “Financial Personalities®”, can help your organization have a greater return on your direct marketing investment by increasing acquisition rates.
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