All posts by Kerry Rivera
It was two years ago when I found myself sitting cross-legged on my home office floor, papers strewn about as I organized piles of tax returns, W-2s, pay stubs, 401k and bank statements, and previous escrow docs. My task? Sort through it all, scan them (if I couldn’t access them digitally) and then upload/email them to a site for my mortgage broker to print and package for my refinance application. For a girl accustomed to Amazon Prime, mobile banking, social media and smart TVs, this monumental financial task seemed utterly archaic – even in 2015. Fast forward two years later, and the mortgage space has failed to make much progress. Clearly, the financial meltdown and Great Recession placed more regulation and compliance stresses on financial institutions. Verification steps and requirements needed to be strengthened – and that made sense. We want to make sure people are capable of paying for those sizable mortgage payments, right? Even now, I get flashbacks to scenes from The Big Short. Still, the hunt for paper, the endless scanning, the emailing, the document uploads required? In an era where the smartphone rules, how has the mortgage industry failed to evolve in the digital age? It’s no secret the financial services industry is typically slow to adopt the latest in technology advancements, but consumers are pushing. A 2016 Accenture survey reveals online banking is now the top choice of consumers at 28%, followed by branch banking at 24%. In the mobile banking space, there has additionally been a significant increase. From 2011 to 2015, mobile banking doubled (22% to 43%) and rose from 43% to 53% for smartphone users in particular. But what about mortgage? Finally, it seems, shifts are underway. In a recent Oliver Wyman paper titled Digital Mortgage Nirvana, the authors state, “Gone are the days when the only way to properly underwrite a mortgage was with long application forms and tall stacks of documents.” Once easy to carry in one hand, the average mortgage application file has ballooned to 500 pages, according to David Stevens, CEO of the Mortgage Bankers Association. And while the application may not shrink, portions of the application process can be digitized and automated. Today, lenders have the ability to partner with data aggregators to verify a consumer’s assets and income with online solutions. In fact, lenders can take this a step further, feeding the data into their automated decision engines, providing the consumer with an approval, decline or conditions that must be met in order to clear the loan process. Nonbanks have been picking off business and disrupting the onerous mortgage process for the past several years. Think Quicken, LoanDepot and GuaranteedRate. But all mortgage lenders have the ability to speed up consumer verification and decisioning by partnering with data aggregators and leveraging solutions like Experian’s digital verification suite. Are we talking a one-click shopping experience? No. This is a mortgage after all, not your average online purchase. But banks now have the opportunity to dramatically enhance the mortgage experience for consumers. The question is whether they are ready to finally embrace a digital journey in the mortgage space in 2017, or will they let another year pass them by?
Knowing a consumer’s credit information at a single point in time only tells part of the story. I often hear one of our Experian leaders share the example of two horses, running neck-in-neck, at the races. Who will win? Well, if you had multiple insights into those two horses – and could see the race in segments – you might notice one horse losing steam, and the other making great strides. In the world of credit consumers, the same metaphor can ring true. You might have two consumers with identical credit scores, but Consumer A has been making minimum payments for months and showing some payment stress, while Consumer B has been aggressively making larger pay-offs. Trended data adds that color to the story, and suddenly there is more intel on who to market to for future offers. To understand the whole story, lenders need the ability to assess a consumer’s credit behavior over time. Understanding how a consumer uses credit or pays back debt over time can help lenders: Offer the right products & terms to increase response rates Determine up sell and cross sell opportunities Prevent attrition Identify profitable customers Avoid consumers with payment stress Limit loss exposure The challenge with trended data, however, is finding a way to sort through the payment patterns in the midst of huge datasets. At the singular level, one consumer might have 10 trades. Trended data in turn reveals five historical payment fields and then you multiple all of this by 24 months and you suddenly have 1,200 data points. But let’s be real … a lender is not going to look at just one consumer as they consider their marketing or retention campaigns. They may look at 100,000 consumers. And on that scale you are now looking at sorting through 120M data points. So while a lender may think they need trended data – and there is definitely value in accessing it – they likely also need a solution to help them wade through it all, assessing and decisioning on those 120M data points. Tapping into something like Credit3D, which bundles in propensity scores, profitability models and trended attributes, is the solution that truly unveils the value of trended data insights. By layering in these solutions, lenders can clearly answer questions like: Who is likely to respond to an offer? How does a consumer use credit? How can I identify revolvers, transactors and consolidators? Is there a better way to understand risk or to conduct swap set analysis? How can I acquire profitable consumers? How do I increase wallet share and usage? Trended data sounds like a “no-brainer” and it definitely has the ability to shed light on that consumer credit horse race. Lenders, however, also need to have the appropriate analytics and systems to assess on the huge volume of data points. Need more information on Trended Data and Credit 3D? Contact Us
Direct mail is not dead, but it\'s 2017. Financial services companies need to acknowledge there might be other ways to deliver credit offers and capture consumer eyeballs. There are multiple screens competing for our attention, including one of the originals - TV. Advertising and TV have been married forever, but addressable TV allows marketers to target on a much more sophisticated level. Welcome to credit marketing in the digital age. To help financial services companies understand the addressable TV channel, Experian marketing expert Brienna Pinnow answered the following questions in a short interview. What is addressable TV? Addressable TV is an amazing 1-to-1 direct marketing capability. To put it simply, addressable TV is the ability for an advertiser to deliver a TV ad to a specific household. From a consumer perspective, that means even if you and your next door neighbor are watching the latest episode of The Voice, you may see an ad for a mini-van while your neighbor sees an ad for upcoming one-day sale from their favorite retailer. With addressable TV, brands can define their target audience based on 1st, 2nd or 3rd party data (like Experian’s). With the help of satellite and cable companies, they can deliver a personalized, measurable experience. This is an exciting departure from the way that TV advertising has been planned and targeted for nearly 70 years. Instead of focusing on the program, marketers can now focus on the person. Addressable TV makes reaching a precise audience – the same way you would with a direct mail piece or an email – a marketing reality. How long have marketers been leveraging addressable TV? Experian has been an pivotal player in the development of the addressable TV space. Since the first addressable TV trials back in 2004, nearly 13 years ago, Experian has provided the audience targeting data and privacy-compliant matching capabilities that make addressable TV possible. The past 3 years, however, have demonstrated unprecedented, hockey-stick growth in addressable TV. In 2016 alone, the volume of addressable campaigns doubled from the previous year accounting for nearly $300 million spend. That trajectory remains the same in 2017 and beyond. So why are we seeing this growth now? Here are a few reasons addressable TV is continuing to grow… Scale: Millions of households can now be targeted using addressable technology, and the footprint continues to grow with smart TVs and additional cable operators. Data: As organizations put data at the heart of their business, addressable TV enables them to infuse their most important customer information into the targeting. Education: Agencies, data providers, and TV providers have invested time educating brands on the process and power of addressable TV. And now, advertisers are becoming more experienced at making this a consistent part of their marketing plan. Accountability: You’ll be hard pressed to find a marketer that doesn’t have to demonstrate ROI on their marketing campaigns. The measurement capabilities that addressable TV provides adds a layer of accountability and insight that was not previously possible. Technology: Experian has developed an audience management platform, the Audience Engine, which makes addressable TV possible in a matter of clicks. In the past year alone, our platform has distributed over 1,800 audiences for addressable advertising campaigns. What types of companies have been utilizing addressable TV? Have you seen many financial services companies test this channel? The early adopters of addressable TV were primarily automotive advertisers. Compared to other verticals, auto advertisers still spend the largest proportion of their budgets across TV. For that reason, they know it’s a necessity to see if their dollars are actually driving sales for their big-ticket items. Addressable TV solves that problem for auto advertisers. In a DIRECTV campaign leveraging Experian’s automotive data for audience targeting and post-campaign sales reporting, one major auto OEM saw a 26.2% lift in sales for the advertised model compared to the control group. In the past few years, Experian has worked closely with advertisers across verticals – from retail to travel to finance – to launch addressable campaigns. Financial services clients particularly find Experian’s financial related segments, such as income or net worth, to be accurate and powerful in creating qualified target audiences that improve campaign performance. I’ve read that millennials are abandoning cable and TV providers in favor of services like Hulu and Netflix. Does this mean the market for addressable TV will shrink in the coming years? There is a segment of consumers who are abandoning traditional cable services. However, this doesn’t mean they are abandoning content. In fact, content consumption is at an all-time high with offerings from Roku, Hulu, Netflix, Sling TV, CBS, and beyond. All this shift in behavior means is that the definition of TV is becoming more fluid. “TV” doesn’t have to be a big screen sitting in your living room; it can be a laptop on a red-eye flight. And from a marketing perspective, the concept of addressable, 1-to-1 targeting is already moving into some of these products and services. The footprint of addressable TV will only continue to rise as consumers stay connected to the content they love. How can companies measure the success of utilizing addressable TV as a channel? Not only does addressable TV provide laser-targeted ad delivery, but it also opens up measurement capabilities that were never possible for TV advertisers in the past. Traditionally, TV audience measurement has focused simply on eyeballs and not revenue impact, with little insight into how TV advertising converts into sales. The primary source for audience measurement in the TV world has been program ratings and expensive brand studies. With addressable TV, that story is changing. With companies that collect second-by-second viewership data linked to households, marketers now have the ability to tie this data back to their online and offline sales. Experian is pivotal in making closed-loop TV reporting possible. As a data and matching safe-haven, we link together the viewing information from the target audience with the sales data provided by the advertiser. The end result is a privacy compliant report that clearly demonstrates the impact of the campaign on the target audience. Did the targeted audience visit a bank location? Email customer service? Sign up for a new account? Spend a certain amount? These are all questions our TV attribution reporting answers for clients. If a company wants to begin marketing in addressable TV, what is required in terms of set-up? Addressable TV may sound new, exciting or even complex. But it doesn’t have to be. Getting started is as simple as defining the target audience. Decide whether you would like to leverage your own CRM data, a custom model, third-party data or a combination of these data sources. If you’re still not sure where to start, ask yourself a very simple question, “Who am I sending a direct mail piece or email to in the next month?” There’s your audience. Better yet, you will be amplifying your message, reaching the customer with a consistent message and meeting them wherever they are. After you’ve determined who you want to target, a matching partner like Experian can work with you to show you the reach of your audience across TV providers. You’ll finalize your budget, creative and media plan while Experian distributes your audience to the selected media destinations. Before you know it, your campaign will be live, and reaching your target audience whether they’re watching Shark Tank or Sharknado. When the campaign wraps, you’ll be on your way to measuring results like never before. Are there any additional trends you see emerging in the addressable TV space? The future of addressable TV is related to both the targeting and measurement capabilities. More advertisers are working with Experian, for example, to launch coordinated campaigns. That doesn’t just mean launching a digital campaign and TV campaign at the same time. It really means targeting the same exact people for the digital and TV campaign. We like to consider this a \"surround sound\" approach where the customer or prospect experiences a consistent message across channels. As for measurement, Experian is working closely with advertisers to explore the power of mobile data. Recently, Experian partnered with Ninth Decimal and DIRECTV to incorporate mobile location data into the post-campaign measurement process for Toyota. The results proved a 19% lift in dealership visits for those exposed to the campaign. This is an exciting development because this approach can translate well for any other advertiser who wants to measure metrics like location visitation. If you’d like to learn more, check out our Addressable TV whitepaper.
As lenders seek to enhance their credit marketing strategies this year, they are increasingly questioning how to split their budgets between digital, direct mail and beyond. What is the ideal media mix to reach consumers in 2017? And is the solution different in the financial services space? Scott Gordon, Experian\'s senior director of digital credit marketing, recently tackled some of the tough questions financial services marketers are posing. Here are his responses: Q: We live in a world where consumers are receiving hundreds of messages and offers on a daily basis. How can financial services companies stand out and capture the attention of the customers they wish to engage with relevant offers? A: When it comes to the optimal marketing media mix, there is no “silver bullet.” It varies from product to product. The current post-campaign analysis is showing us that consumers react positively to coordinated multi-channel messaging. We’ve seen studies showing that marketers can see up to a 30% lift in sales by combining email with social media, for example. This makes sense, when you look at how consumers engage through devices. We are no longer a single channel culture; we check Facebook while watching TV, listen to podcasts while checking our email, etc. Consequently, marketers have had to adapt their campaign strategies accordingly – and this starts with the organizational structure. Far too often we see silo’ed groups responsible for disparate media verticals. For example, a company may have a direct mail group and a digital marketing team, and then (in extreme cases) outsource television to one agency group and social media to another. Aligning these groups and breaking down the barriers between the groups is a critical first step toward building a true multi-channel campaign strategy. This includes addressing budget concerns that are inherent with a culture where the size of a budget is tied to job security and corporate status. Aligning campaigns and finding the perfect cross channel market mix is much easier once you’ve broken down internal barriers and encouraged marketing collaboration. Q: What are some of the new best practices financial companies must embrace in 2017 in order to improve their marketing efforts? A: Thanks to tremendous efforts from industry leaders, we can now utilize regulated data with the same proficiency that they’ve been executing campaigns using non-regulated data. This presents unique challenges, as the industry races to get up-to-speed on new capabilities, take best-in-breed practices and apply them to the world of regulated campaigns. We’re seeing tremendous demand to combine programmatic advertising with people-based advertising, with cross-channel campaigns spanning mobile, video, social, and addressable TV. Measurement and analytics must play a large part in these strategies. While the industry hasn’t achieved true cross-channel measurement to identify a consumer’s path to purchase across multiple devices, it’s getting closer, thanks to technology advances. Q: Is direct mail dead? How should financial marketers be using direct mail in 2017? How can it best be combined with digital? A: Direct mail is certainly not dead. It has its place among a media mix that continues to grow as new advertising technologies come to market and are adopted by consumers. Will direct mail’s influence diminish in the future? Possibly. At Experian, we are focused on making sure that our advertisers can reach consumers where they spend time, when they are most receptive to receiving messages, and most importantly in a cost-effective manner. So no matter where consumers shift their focus in the future, we’ll be able to support comprehensive targeted advertising campaigns. How can digital be best combined with direct mail? We’ve seen encouraging results in retargeting direct mail with digital credit marketing like email and display. With that said, we haven’t seen a silver bullet solution, and we’re still advising our clients to put a heavy focus toward “test and learn” in concert with comprehensive campaign measurement and analytics protocols. Q: What are the advantages to serving up a firm offer of credit to a consumer in a digital format? Are consumers ready to embrace this type of delivery in the financial services space? A: The advantages of serving up a firm offer of credit to a consumer in a digital format are similar to those benefits for “traditional” digital marketing. Lower cost, more measurement capabilities, and greater flexibility to optimize campaigns are just some of the benefits. Early indications show that consumers are very receptive to digital credit marketing offers. It provides them with offers in the channels in which they spend time, in a consumer friendly manner which offers them numerous paths in which they can have a voice in the messages that they receive. Q: Some say digital credit marketing should largely be directed to Millennials? Do you think other generations are ready to embrace this type of digital messaging? A: We don’t view digital credit marketing as an exclusive offering just for Millennials. It is a holistic consumer offering – applicable to all generations as our parents and grandparents make the move to new channels such as addressable TV and social media. Need more info on Digital Credit Marketing? Learn More
Prescreen, prequalification and preapproval. The terms sound similar, but lenders beware. These credit solutions are quite different and regulations vary depending on which product is utilized. Let’s break it down … What’s involved with a Prescreen? Prescreen is a behind-the-scenes process that screens consumers for a firm offer of credit without their knowledge. Typically, a Credit Reporting Agency, like Experian, will compile a list of consumers who meet specific credit criteria, and then provide the list to a lending institution. Consumers then see messaging like, “You have been approved for a new credit card.” Sometimes, marketing offers use the phrase “You have been preapproved,” but, by definition, these are prescreened offers and have specific notice and screening requirements. This solution is often used to help credit grantors reduce the overall cost of direct mail solicitations by eliminating unqualified prospects, reducing high-risk accounts and targeting the best prospects more effectively before mailing. A firm offer of credit and inquiry posting is required. And, it’s important to note that prescreened offers are governed by the Fair Credit Reporting Act (FCRA). Specifically, the FCRA requires lenders initiating a prescreen to: Provide special notices to consumers offered credit based on the prescreened list; Extend firm offers of credit to consumers who passed the prescreening, but allows lenders to limit the offers to those who passed the prescreening; Maintain records regarding the prescreened lists; and Allow for consumers to opt-out of prescreened offers. Lenders and the Consumer Reporting Agencies must scrub the list against the opt-outs. Finally, it is important to note that a soft inquiry is always logged to the consumer’s credit file during the prescreen process. What’s involved with a Prequalification? Prequalification, on the other hand, is a consumer consent-based credit screening tool where the consumer opts-in to see which credit products they may be qualified for in real time at the point of contact. Unlike a prescreen which is initiated by the lender, the prequalification is initiated by the consumer. In this instance, envision a consumer visiting a bank and inquiring about whether or not they would qualify for a credit card. During a prequalification, the lender can actually explore if the consumer would be eligible for multiple credit products – perhaps a personal loan or HELOC as well. The consumer can then decide if they would like to proceed with the offer(s). A soft inquiry is always logged to the consumer’s credit file, and the consumer can be presented with multiple credit options for qualification. No firm offer of credit is required, but adverse action may be required, and it is up to the client’s legal counsel to determine the manner, content, and timing of adverse action. When the consumer is ready to apply, a hard inquiry must be logged to the consumer’s file for the underwriting process. How will a prequalification or prescreen invitation/offer impact a consumer’s credit report? Inquiries generated by prequalification offers will appear on a consumer’s credit report, but can only be seen by the consumer when they specifically request a report from the credit bureaus. Soft inquiries are never included in credit score calculations. For “soft” inquiries, in both prescreen and prequalification instances, there is no impact to the consumer’s credit score. However, once the consumer elects to proceed with officially applying for and/or accepting a new line of credit, the hard inquiry will be noted in the consumer’s report, and the credit score may be impacted. Typically, a hard inquiry subtracts a few points from a consumer’s credit score, but only for a year, depending on the scoring model. --- Each of these product solutions have their place among lenders. Just be careful about using the terms interchangeably and ensure you understand the regulatory compliance mandates attached to each. More info on Prequalification More Info on Prescreen
Personal loans have been booming for the past couple of years with double-digit growth year-over-year. But the party can’t last forever, right? In a recent Experian webinar, experts noted they have seen originations leveling off. In fact, numbers indicate it’s gone from leveled off to a slight year-over-year decline. They projected the first quarter of calendar year 2017 may also be down, but then we’ll see a peak again in the second quarter, which is typical with the seasonality often associated with personal loans. The landscape is changing. A recent data pull revealed a 9-point shift in the average VantageScore® for originations from Q3 to Q4 of 2016. Lenders are digging deeper in order to keep their loan volumes up, and it is definitely a more competitive marketplace. The days where lenders were once able to grow their personal loan business with little effort are gone. Kelley Motley, Experian’s director of analytics, noted some of the personal loan origination volume shifts may be due to the rebound in the housing market and increased housing values, enabling super-prime and prime consumers to now also consider home equity loans and lines of credit, in lieu of personal loans. Still, the personal loan market is healthy. Lenders just need to be smart about their marketing efforts and utilize data to improve their response rates, expand their risk criteria to identify consumers trending upward in the credit ranks, and then retain them as their cash-flow and financial situations evolve. In the presentation, experts revealed a few interesting stats: 67% of those that open a personal installment loan had a revolving trade with a balance >$0 5% of consumer that close a personal loan reopen another within a few months of the original loan closure 68% of consumers that re-open a new personal loan within a short timeframe of closing another personal loan do so with the same company Together, these stats illustrate that individuals are largely leveraging personal loans to consolidate debt or perhaps fund an expense like a vacation or an unexpected event. Once the consumer comes into cash, they’ll pay off the loan, but consider revisiting a personal loan again if their financial situation warrants it. The calendar year Q2 peak has been consistent since the Great Recession. For many consumers, after racking up holiday debt and end-of-year expenses, the bills start coming in during the first quarter. With the high APRs often attached to revolving cards, there is a sense of urgency to consolidate and lock in a more reasonable rate. Others utilize the personal loan to fund weddings, vacations and home improvement projects. Kyle Matthies, a senior product manager for Experian, reminded participants that most people don’t need your product, so it’s essential to leverage data find those that do. Utilizing propensity score and attributes, as well as tools to dig into ability-to-pay metrics and offer alignment can really fine-tune both an organization’s marketing and retention strategies. To learn more about the current state of personal loans, access our free webinar How lenders can capitalize on the growth in personal loans.
Experian shares five trends and twists coming over the next 12 months, that could push new boundaries and in many cases improve the customer experience as it pertains to the world of credit and finance.
You know what I love getting in the mail? Holiday cards, magazines, the occasional picturesque catalog. What I don’t open? Credit card offers, invitations to apply for loans and other financial advertisements. Sorry lenders, but these generally go straight into my shredder. Your well-intentioned efforts were a waste in postage, printing and fulfillment costs, and I’m guessing my mail consumption habits are likely shared by millions of other Americans. I’m a cusper, straddling the X and Millennial generations, and it’s no secret people like me have grown accustomed to living on our mobile devices, shopping online and managing our financial lives digitally. While many retailers have wised up to the trends and shifted marketing dollars heavily into the digital space, the financial services industry has been slow to follow. I’m hoping 2017 will be the year they adapt, because solutions are emerging to help lenders deliver firm offers of credit via email, display, retargeting and even social media platforms. There are multiple reasons to make the shift to digital credit marketing. It’s trackable. The beauty of digital marketing is that it can be tracked much more efficiently over direct mail efforts. You can see if offer emails are opened, if banners are clicked, if forms are completed and how quickly all of this takes place. In short, there are more touchpoints to measure and track, and more insights made available to help with marketing and offer optimization. It’s efficient. A solid digital campaign means you now have more flexibility. And once those assets start to deploy and you begin tracking the results, you can additionally optimize on the fly. Subject line not getting the open rate you want? Test a new one. Banners not getting clicked? Change the creative. A portion of your target audience not responding? Capture that feedback sooner rather than later, and strategize again. With direct mail, the lag time is long. With digital, the intelligence gathering begins immediately. It’s what many consumers want. They are spending 25% of their time on mobile devices. Research has found they check their phones and average 46 times per day. They are bouncing from screen to screen, engaging on desktops, tablets, smartphones, wearables and smart TVs. If you want to capture the eyeballs and mindshare of consumers, financial marketers must embrace the delivery of digital offers. Consumer behaviors have evolved, so must lenders. Sure, there is still a place for direct mail efforts, but it would be wasteful to not embrace the world of digital credit marketing and find the right balance between offline and online. It’s a digital world. It’s time financial institutions join the masses and communicate accordingly.
Which part of the country has bragging rights when it comes to sporting the best consumer credit scores? Drum roll please … Honors go to the Midwest. In fact, eight of the 10 cities with the highest consumer credit scores heralded from Minnesota and Wisconsin. Mankato, Minn., earned the highest ranking with an average credit score of 708 and Greenwood, Miss., placed last with an average credit score of 622. Even better news is that the nation’s average credit score is up four points; 669 to 673 from last year and is only six points away from the 2007 average of 679, which is a promising sign as the economy continues to rebound. Experian’s annual study ranks American cities by credit score and reveals which cities are the best and worst at managing their credit, along with a glimpse at how the nation and each generation is faring. “All credit indicators suggest consumers are not as ‘credit stressed’ — credit card balances and average debt are up while utilization rates remained consistent at 30 percent,” said Michele Raneri, vice president of analytics and new business development at Experian. As for the generational victors, the Silents have an average 730, Boomers come in with 700, Gen X with 655 and Gen Y with 634. We’re also starting to see Gen Z emerge for the first time in the credit ranks with an average score of 631. Couple this news with other favorable economic indicators and it appears the country is humming along in a positive direction. The stock market reached record highs post-election. Bankcard originations and balances continue to grow, dominated by the prime borrower. And the housing market is healthy with boomerang borrowers re-emerging. An estimated 2.5 million Americans will see a foreclosure fall of their credit report between June 2016 and June 2017, creating a new pool of potential buyers with improved credit profiles. More than 12 percent who foreclosed back in the Great Recession have already boomeranged to become homeowners again, while 29 percent who experienced a short sale during that same time have also recently taken on a mortgage. “We are seeing the positive effects of economic recovery with the rise in income and low unemployment reflected in how Americans are managing their credit,” said Raneri. Which means all is good in the world of credit. Of course there is always room for improvement, but this year’s 7th annual state of credit reveals there is much to be thankful for in 2016.
It’s been a wild ride for the financial services industry over the past eight years. After the mortgage meltdown, the Great Recession and a stagnant economy … well, one could say the country had seen better days. Did you watch The Big Short last winter? It all came crumbling down. And then President Barack Obama entered the scene. Change was needed. More oversight introduced. Suddenly, we had the Affordable Care Act, the Dodd-Frank Wall Street Reform Act and the creation of the Consumer Financial Protection Bureau (CFPB). Taxes were raised on the country’s highest earners for the first time since the late-1990s. In essence, the pendulum swung hard and fast to a new era of tightened and rigorous regulation. Fast forward to present day and we find ourselves on the cusp of transitioning to new leadership for the country. A new president, new cabinet, new leaders in Congress. What will it all mean for financial services regulations? It’s helpful to initially take a look back at the key regulations that have been introduced over the past eight years. Mortgage Reform: Long gone are the days of obtaining a quick mortgage. New rules have required loan originators to verify and document the consumer’s income and assets, including employment status (if relied upon), existing debt obligations, mortgage-related obligations, alimony and child support. The CFPB has also expanded foreclosure protections for struggling borrowers and homeowners. Maintaining the health of the mortgage industry is important for the entire country, and updated rules have enhanced the safety and transparency of the mortgage market. Home values have largely recovered from the darkest days, but some question whether the underwriting criteria have become too strict. Combatting Fraud: The latest cyber-attack trends and threats come fast and furious. Thus, regulators are largely addressing the challenge by expecting banks to adhere to world-class standards from organizations such as the National Institute of Standards and Technology (NIST). The Federal Trade Commission (FTC) and the National Credit Union Administration (NCUA) implemented the Red Flags Rule in November 2008. It requires institutions to establish policies and procedures to identify and recognize red flags — i.e., patterns, practices or specific activities that indicate the possible existence of identity theft — that occur during account-opening activities, existing account maintenance and new activity on an account that has been inactive for two or more years. Loss Forecasting: The Dodd-Frank Act Requires the Federal Reserve to conduct an annual stress test of bank holding companies (BHCs), savings and loan holding companies, state member banks, and nonbank financial institutions. In October 2012, the Fed Board adopted the Comprehensive Capital Analysis and Review (CCAR) rules. This requires banks with assets of $50 billion or more to submit to an annual review centered on a supervisory stress test to gauge capital adequacy. In January 2016, Dodd-Frank Act Stress Testing (DFAST) was introduced, requiring bank holding companies with assets of $10 billion or more to conduct separate annual stress tests known as “company-run tests” using economic scenarios. Every year regulators expect to see continued improvement in stress-testing models and capital-planning approaches as they raise the bar on what constitutes an acceptable practice. CFPB: No longer the new kids on the block, the CFPB has transitioned to an entity that has its tentacles into every aspect of consumer financial products. Mortgage lending was one of their first pursuits, but they have since dug into “ability-to-pay underwriting” and servicing standards for auto loans, credit cards and add-on products sold through third-party vendors. Now they are looking into will likely be the next “bubble,” – student lending – and educating themselves about online marketplace lending. Data Quality: Expectations related to data quality, risk analytics, and regulatory reporting have risen dramatically since the financial downturn. Inaccuracy in data is costly and harmful, slows down the industry, and creates frustration. In short, it’s bad for consumers and the industry. It’s no secret that financial institutions rely on the accuracy of credit data to make the most informed decisions about the creditworthiness of their customers. With intense scrutiny in this area, many financial institutions have created robust teams to handle and manage requirements and implement sound policies surrounding data accuracy. --- This is merely a sliver of the multiple regulations introduced and strengthened over the past eight years. Is there a belief that the regulatory pendulum might take a swing to other side with new leadership? Unlikely. The agenda for 2017 largely centers on the need to improve debt collections practices, enhance access to credit for struggling Americans, and the need for ongoing monitoring of the fintech space. Only time will tell, but one thing is certain. Anyone involved in financial services needs to keep a watchful eye on the ever-evolving world of regulation and Washington.
Much has been written about Millennials over the past few years, and many continue to speculate on how this now largest living generation will live, age and ultimately change the world. Will they still aspire to achieve the “American Dream” of education, home and raising a family? Do they wish for something different? Or has the “Dream” simply been delayed with so many individuals saddled with record-high student loan debt? According to a recent study by Pew, for the first time in more than 130 years, adults ages 18 to 34 were slightly more likely to be living in their parents’ home than they were to be living with a spouse or partner in their own household. It’s no secret the median age of first marriage has risen steadily for decades. In fact, a growing share of young adults may be eschewing marriage altogether. Layer on the story that about half of young college graduates between the ages of 22 and 27 are said to be “underemployed”—working in a job that hasn’t historically required a college degree – and it’s clear if nothing else that the “American Dream” for many Millennials has been delayed. So what does this all mean for the world of homeownership? While some experts warn the homeownership rate will continue to decrease, others – like Freddie Mac – believe that sentiment is overly pessimistic. Freddie Mac Chief Economist Sean Becketti says, “The income and education gaps that are responsible for some of the differences may be narrowed or eliminated as the U.S. becomes a \'majority minority\' country.” Mortgage interest rates are still near historic lows, but home prices are rising far faster than incomes, negating much of the savings from these low rates. Experian has taken the question a step further, diving into not just “Do Millennials want to buy homes” but “Can Millennials buy homes?” Using mortgage readiness underwriting criteria, the bureau took a large consumer sample and assessed Millennial mortgage readiness. Experian then worked with Freddie Mac to identify where these “ready” individuals had the best chance of finding homes. The two factors that had the strongest correlation on homeownership were income and being married. From a credit perspective, 33 percent of the sample had strong or moderate credit, while 50 percent had weak credit. While the 50 percent figure is startling, it is important to note 40 percent of that grouping consisted of individuals aged 18 to 26. They simply haven’t had enough time to build up their credit. Second, of the weak group, 31 percent were “near-moderate,” meaning their VantageScore is 601 to 660, so they are close to reaching a “ready” status. Overall, student debt and home price had a negative correlation on homeownership. In regards to regions, Millennials are most likely to live in places where they can make money, so urban hubs like Los Angeles, San Francisco, Chicago, Dallas, Houston, Boston, New York and DC currently serve as basecamp for this group. Still, when you factor in affordability, findings revealed the Greater New York, Houston and Miami areas would be good areas for sourcing Millennials who are mortgage ready and matching them to affordable inventory. Complete research findings can be accessed in the Experian-Freddie Mac co-hosted webinar, but overall signs indicate Millennials are increasingly becoming “mortgage ready” as they age, and will soon want to own their slice of the “American Dream.” Expect the Millennial homeownership rate of 34 percent to creep higher in the years to come. Brokers, lenders and realtors get ready.
With the Oct. 3, 2016 compliance date upon us, many lenders continue to debate how they would like to solve for the Military Lending Act (MLA). With new enhancements, more protections have been granted to members of the military and their dependents when it comes to “consumer credit” products, specifically around the 36% cap on the MAPR. The key then becomes how to identify these individuals. At origination, how can the lender know if an individual is a member of the military, or a service member’s dependent? The answer, of course, lies in verification. Under the new Department of Defense (DOD) rule, lenders will have to check each credit applicant to confirm that they are not a service member, spouse, or the dependent of a service member. The final rule includes a “safe harbor” from liability for lenders who verify the MLA status of a consumer through a nationwide Credit Reporting Agency (CRA) or the DOD’s own database, known as the DMDC. Obviously, lenders will want to have this “safe harbor,” so the question becomes do you opt for the direct or indirect solution? The direct solution is to have the lender access the DMDC on their own. With this option, expected turnaround time is 24 hours for batch searches. The DMDC expects the volume of searches to their servers to increase from 220 million a week to 1.9 billion a week. For some, this feels like a more manual process, but it can be done. The indirect solution involves the CRA accessing the DMDC data on the lender’s behalf. In Experian’s case, this would translate into lenders seeing the MLA indicator on the credit report at point of origination or making a call out for just the MLA indicator. The process is integrated into the credit-pull cycle, so no manual effort is required on the lender’s end. MLA status is simply flagged. The rule also permits the consumer report to be obtained from a reseller that obtains such a report from a nationwide consumer reporting agency. Required data to perform a search includes full legal name, address, social security number and date of birth. This applies to both the credit report add-on and Experian’s standalone solutions. If any of this data is missing from the inquiry, Experian is unable to perform the MLA search. Credit card lenders have until Oct. 3, 2017 to adhere to the new standards, but all other applicable lenders must act now and build out their compliance standards and solutions. Direct or indirect? That is the question. To learn more about MLA or how Experian can help, visit our dedicated-MLA site.
In this age of content and increasing financial education available to all, most entities are familiar with credit bureaus, including Experian. They are known for housing enormous amounts of data, delivering credit scores and helping businesses decision on credit. On the consumer side, there are certainly myths about credit scores and the credit report. But myths exist among businesses as well, especially as it pertains to the topic of reporting credit data. How does it work? Who’s responsible? Does reporting matter if you’re a small lender? Let’s tackle three of the most common myths surrounding credit reporting and shine a light on how it really is essential in creating a healthy credit ecosystem. Myth No. 1: Reporting to one bureau is good enough. Well, reporting to one bureau is definitely better than reporting to none, but without reporting to all three bureaus, there could be gaps in a consumer’s profile. Why? When a lender pulls a consumer’s profile to evaluate it for extending additional credit, they ideally would like to see a borrower’s complete credit history. So, if one of their existing trades is not being reported to one bureau, and the lender makes a credit pull from a different bureau to use for evaluation purposes, no knowledge of that trade exists. In cases like these, credit grantors may offer credit to your customer, not knowing the customer already has an obligation to you. This may result in your customer getting over-extended and negatively impacting their ability to pay you. On the other side, in the cases of a thin-file consumer, not having that comprehensive snapshot of all trades could mean they continue to look “thin” to other lenders. The best thing you can do for a consumer is report to all three bureaus, making their profile as robust as it can be, so lenders have the insights they need to make informed credit offers and decisions. Some believe the bureaus are regional, meaning each covers a certain part of the country, but this is false. Each of the bureaus are national and lenders can report to any and all. Myth No. 2: Reporting credit data is hard. Yes, accurate and timely data reporting requires a few steps, but after you get familiar with Metro 2, the industry standard format for consumer data reporting, choose a strategy, and register for e-Oscar, the process is set. The key is to do some testing, and also ensure the data you pass is accurate. Myth No. 3: Reporting credit data is a responsibility for the big institutions –not smaller lenders and companies. For all lenders, credit bureau data is vitally important in making informed risk determinations for consumer and small business loans. Large financial institutions have been contributing to the ecosystem forever. Many smaller regional banks and credit unions have reported consistently as well. But just think how much stronger the consumer credit profile would be if all lenders, utility companies and telecom businesses reported? Then you would get a true, complete view into the credit universe, and consumers benefit by having the most comprehensive profile --- Bottom line is that when comprehensive data on consumer credit histories is readily available, it’s a good thing for consumers and lenders. And the truth is all businesses - big and small - can make this a reality.
Tick-tock. Tick-tock. Lenders are just weeks away from the required Military Lending Act compliance date of Oct. 3, yet many are scrambling to find a solution. In fact, officials with CUNA and the American Bankers Association said they were still confused by the rules, and requested a six-month extension from the Department of Defense for compliance. Card holders have until Oct. 3, 2017 to comply, but others are trying to navigate what the rule means and how to introduce new practices to protect and serve military credit consumers. What are the top questions still circulating about this key piece of regulation? Here are a few we’ve been tracking, along with some responses to assist with this shift in compliance. 1. What types of accounts are covered under the Military Lending Act (MLA)? It initially applied to three narrowly-defined “consumer credit” products: Closed-end payday loans; Closed-end auto title loans; and Closed-end tax refund anticipation loans. The new rule, issued in 2015 by the Department of Defense, expands the definition of “consumer credit” covered by the regulation to more closely align with the definition of credit in the Truth in Lending Act and Regulation Z. This means MLA now covers a wide range of credit transactions. It does not apply to residential mortgages and credit secured by personal property, such as vehicle purchase loans. 2. Who are the covered borrowers under the MLA? The DMDC database identifies individuals who meet one of the following criteria: Is on active duty Regular or reserve member of the Army, Navy, Marine Corps, Air Force, or Coast Guard, serving on active duty under a call or order that does not specify a period of 30 days or less, or such a member serving on Active Guard and Reserve duty as that term is defined in 10 u.s.c. 101 (d)(6) The member’s spouse The member’s child defined in 38 USC 101(4), or An individual for whom the member provided more than one-half of the individual’s support for 180 days immediately preceding the extension of consumer credit covered by 32 C.F.R. Part 232 The flag returned from DMDC will not specifically identify the active duty military member, but it will flag if the applicant is a covered borrower. 3. How is MAPR calculated? What additional fees are included? The MAPR includes interest, fees, credit service charges, credit renewal charges, credit insurance premiums and other fees for credit-related products sold in connection with the loan. You should work with your legal/compliance teams for MLA restrictions and applicability. 4. What is the difference between the Servicemembers Civil Relief Act (SCRA) and the Military Lending Act (MLA)? Both regulations are designed to protect U.S. service members and their families, but each focus on different areas. SCRA has been around for decades and was designed to temporarily suspend judicial and administrative proceedings and transactions that may adversely affect service members during their actual military service. In fact, if a service member has a debt before he or she joined the active military service, they can have the interest rate reduced to 6 percent, upon request. If the loan is a mortgage, that rate can also be reduced for the duration the member is in the military, plus one year. Other loans are only reduced for the duration the member is on active duty. MLA, on the other hand, is focused solely on providing specific protections for active duty service members and their dependents in certain consumer credit transactions. It was introduced in 2007, but strengthened in 2015. Specifically, it limits APR to 36 percent on covered products, which was recently expanded to include closed-end payday loans, closed-end auto title loans and closed-end tax refund anticipation loans. Unlike SCRA, where the responsibility to activate these protections falls on the service member, MLA requires creditors to verify active duty status and dependents at origination. 5. Explain the difference between accessing MLA status directly versus indirectly. The Final Rule permits a creditor to use information obtained directly from the Department of Defense’s Database. Information can also be obtained from a nationwide consumer reporting agency to determine whether a consumer applicant is a covered borrower. When working with Experian, the one-stop solution will entail outputting the MLA indicator on the credit report at point of origination. We anticipate this solution will be available in fall 2016. --- Not much is known about what the punishments or fines will look like for infractions, but now is the time to start reviewing business governance and procedures that support compliance. To learn more about MLA and to access an on-demand webinar with industry experts, visit our site.
All customers are not created equally – at least when it comes to one’s ability to pay. Incomes differ, financial circumstances vary and economic challenges surface. Lost job. Totaled car. Unplanned medical bills. Life happens. Research conducted by a recent Bankrate study revealed just 38 percent of Americans said they could cover an unexpected emergency room visit or a $500 car repair with available cash in a checking or savings account. It’s a scary situation for individuals, and also a source of stress for the lender expecting payment. So what are the natural moments for a lender to assess “ability to pay?” Moment No. 1: When prepping for a prescreen campaign and at origination. Many lenders leverage an income estimation model, designed to give an indication of the customer’s capacity to take on additional debt by providing an estimation of their annual income. Within the model, multiple attributes are used to calculate the income, including: Number of accounts Account balances Utilization Average number of months since trade opened Combined, all of these insights determine a customer’s current obligations, as well as an estimation of their current income, to see if they can realistically take on more credit. The right models and criteria on the front-end – whether used when a consumer applies for new credit or when a lender is executing a prescreen campaign to acquire new customers – minimizes the risk for default. It’s a no-brainer. Moment No. 2: When a customer is already on your books. As the Bankrate study mentioned, sudden life events can send some customers’ lives into a financial tailspin. On the other hand, financial circumstances can change for the better too. Aggressively paying down a HELOC, doubling down on a mortgage, or wiping out a bankcard balance could signal an opportunity to extend more credit, while the reverse could be the first signs of payment stress. Attaching triggers to accounts can give lenders indications on what to do with either scenario, helping to grow a portfolio and protect it. Moment No. 3: When an account goes south. While a lender hates to think any of its accounts will plummet into collections, sometimes, it’s inevitable. Even prime customers fall behind, and suddenly financial institutions are faced with looking at collections strategies. Where should they place their bets? You can’t treat all delinquent customer equally and work the accounts the same way. Collection resources can be wasted on customers who are difficult or impossible to recover, so it’s best to turn to predictive analytics and a collections scoring strategy to prioritize efforts. Again, who has the greatest ability to pay? Then place your manpower on those individuals where you can recover the most dollars. --- Assessing one’s ability to pay is a cornerstone to the financial services business. The quest is to find the sweet spot with a combination of application data, behavioral data and credit risk scoring analytics.
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