Financial Services
2017 data breach landscape Experian Data Breach Resolution releases its fourth annual Data Breach Industry Forecast report with five key predictions What will the 2017 data breach landscape look like? While many companies have data breach preparedness on their radar, it takes constant vigilance to stay ahead of emerging threats and increasingly sophisticated cybercriminals. To learn more about what risks may lie ahead, Experian Data Breach Resolution released its fourth annual Data Breach Industry Forecast white paper. The industry predictions in the report are rooted in Experian\'s history helping companies navigate more than 17,000 breaches over the last decade and almost 4,000 breaches in 2016 alone. The anticipated issues include nation-state cyberattacks possibly moving from espionage to full-scale cyber conflicts and new attacks targeting the healthcare industry. \"Preparing for a data breach has become much more complex over the last few years,\" said Michael Bruemmer, vice president at Experian Data Breach Resolution. \"Organizations must keep an eye on the many new and constantly evolving threats and address these threats in their incident response plans. Our report sheds a light on a few areas that could be troublesome in 2017 and beyond.\" \"Experian\'s annual Data Breach Forecast has proven to be great insight for cyber and risk management professionals, particularly in the healthcare sector as the industry adopts emerging technology at a record pace, creating an ever wider cyber-attack surface, adds Ann Patterson, senior vice president, Medical Identity Fraud Alliance (MIFA). \"The consequences of a medical data breach are wide-ranging, with devastating effects across the board - from the breached entity to consumers who may experience medical ID fraud to the healthcare industry as a whole. There is no silver bullet for cybersecurity, however, making good use of trends and analysis to keep evolving our cyber protections along with forecasted threats is vital.\" \"The 72 hour notice requirement to EU authorities under the GDPR is going to put U.S.-based organizations in a difficult situation, said Dominic Paluzzi, co-chair of the Data Privacy & Cybersecurity Practice at McDonald Hopkins. \"The upcoming EU law may just have the effect of expediting breach notification globally, although 72 hour notice from discovery will be extremely difficult to comply with in many breaches. Organizations\' incident response plans should certainly be updated to account for these new laws set to go in effect in 2017.\" Omer Tene, Vice President of Research and Education for International Association of Privacy Professionals, added \"Clearly, the biggest challenge for businesses in 2017 will be preparing for the entry into force of the GDPR, a massive regulatory framework with implications for budget and staff, carrying stiff fines and penalties in an unprecedented amount. Against a backdrop of escalating cyber events, such as the recent attack on Internet backbone orchestrated through IoT devices, companies will need to train, educate and certify their staff to mitigate personal data risks.\" Download Whitepaper: Fourth Annual 2017 Data Breach Industry Forecast Learn more about the five industry predictions, and issues such as ransomware and international breach notice laws in our the complimentary white paper. Click here to learn more about our fraud products, find additional data breach resources, including webinars, white papers and videos.
How will the FinCEN revisions impact your business? (Part 2) I recently discussed the new FinCEN requirements to Customer Due Diligence. This time, I’d like to focus on the recent FinCEN advisory regarding “email-compromise fraud.” This new advisory sheds additional light on the dual threats of both Email Account Compromise impacting the general public and Business Email Compromise that targets businesses. FinCEN has rightly identified and communicated several high-risk conditions common to the perpetration of scams such as varied languages, slight alterations in email addresses, out-of-norm account and transaction information, and social engineering in the form of follow-up requests for additional transfers. In addition to introducing operational standards to detect such conditions, institutions also would benefit from these other tactics and focal points as they respond to email requests for financial transfers: Email validation and verification — use of third-party vendor services that can deliver a measurable level of confidence in the association of an email address to an actual, true identity. Multifactor authentication — use of dual-step or out-of-band verification of the requested transaction using alternate channels such as phone. Robust KYC/CIP at application and account opening to ensure that name, address, date of birth and Social Security number are verified and positively and consistently linked to a single identity, as well as augmented with phone and email verification and association for use in customer communications and multifactor authentications. Customer transactional monitoring in the form of establishing typical or normal transfer activity and thresholds for outlying variations of concern. Known and suspected fraud databases updated in real time or near real time for establishing blacklist emails to be segmented as high risk or declines upon receipt. Identity application and transactional link analysis to monitor for and detect the use of shared and manipulated email addresses across multiple transaction requests for disparate identities. Access to device intelligence and risk assessment to ensure consistent association of a true customer with one or more trusted devices and to detect variance in those trusted associations. Which of these 7 tactics are you using to stop email-compromise fraud?
In order to compete for consumers and to enable lender growth, creating operational efficiencies such as automated decisioning is a must. Unfortunately, somewhere along the way, automated decisioning unfairly earned a reputation for being difficult to implement, expensive and time consuming. But don’t let that discourage you from experiencing its benefits. Let’s take a look at the most popular myths about auto decisioning. Myth #1: Our system isn’t coded. If your system is already calling out for Experian credit reporting data, a very simple change in the inquiry logic will allow your system to access Decisioning as a ServiceSM. Myth #2: We don’t have enough IT resources. Decisioning is typically hosted and embedded within an existing software that most credit unions currently use – thus eliminating or minimizing the need for IT. A good system will allow configuration changes at any time by a business administrator and should not require assistance from a host of IT staff, so the demand on IT resources should decrease. Decisioning as a Service solutions are designed to be user friendly to shorten the learning curve and implementation time. Myth #3: It’s too expensive. Sure, there are highly customized products out there that come with hefty price tags, but there are also automated solutions available that suit your budget. Configuring a product to meet your needs and leaving off any extra bells and whistles that aren’t useful to your organization will help you stick to your allotted budget. Myth #4: Low ROI. Oh contraire…Clients can realize significant return-on-investment with automated decisioning by booking more accounts … 10 percent increase or more in booked accounts is typical. Even more, clients typically realize a 10 percent reduction in bad debt and manual review costs, respectively. Simply estimating the value of each of these things can help populate an ROI for the solution. Myth #5: The timeline to implement is too long. It’s true, automation can involve a lot of functions and tasks – especially if you take it on yourself. By calling out to a hosted environment, Experian’s Decisioning as a Service can take as few as six weeks to implement since it simply augments a current system and does not replace a large piece of software. Myth #6: Manual decisions give a better member experience. Actually, manual decisions are made by people with their own points of view, who have good days and bad days and let recent experiences affect new decisions. Automated decisioning returns a consistent response, every time. Regulators love this! Myth #7: We don’t use Experian data. Experian’s Decisioning as a Service is data agnostic and has the ability to call out to many third-party data sources and configure them to be used in decisioning. --- These myth busters make a great case for implementing automated decisioning in your loan origination system instead of a reason to avoid it. Learn more about Decisioning as a Service and how it can be leveraged to either augment or overhaul your current decisioning platforms.
For members of the U.S. military, relocating often, returning home following a lengthy deployment and living with uncertainty isn’t easy. It can take an emotional and financial toll, and many are unprepared for their economic reality after they separate from the military. As we honor those who have served our country this Veterans Day, we are highlighting some of the special financial benefits and safeguards available to help veterans. Housing Help One of the best benefits offered to service members is the Veteran’s Administration (VA) home-loan program. Loan rates are competitive, and the VA guarantees up to 25 percent of the payment on the loan, making it one of the only ways available to buy a home with no down payment and no private mortgage insurance. Debt Relief Having a VA loan qualifies military members for a Military Debt Consolidation Loan (MDCL) that can help with overcoming financial difficulties. The MDCL is similar to a debt consolidation loan: take out one loan to pay off all unsecured debts, such as credit cards, medical bills and payday loans, and make a single payment to one lender. The advantage of a MDCL? Paying a lower interest rate and closing costs than civilians and far less interest than paying the same bills with credit cards. These refinancing loans can be spread out over 10, 15 and sometimes 30 years. Education Benefits The GI Bill is arguably the best benefit for veterans and members of the armed forces. It helps service members pay for higher education for themselves and their dependents, and is one of the top reasons people enlist. Eligible service members receive up to 36 months of education benefits, based on the type of training, length of service, college fund availability and whether he or she contributed to a buy-up program while on active duty. Benefits last up to 10 years, but the time limit may be extended. Saving & Investing Money According to the Department of Defense’s annual Demographics Report, 87 percent of military families contribute to a retirement account. Service members who participated in the Thrift Savings Plan, however, are often unaware of their options after they separate from service, and many don’t realize the advantages of rolling their plans into an IRA or retirement plan of a new employer. Safeguarding Identity Everyone is a potential identity theft target, but military personnel and veterans are particularly vulnerable. Routinely reviewing a credit report is one way to detect a breach. The Attorney General\'s Office provides general information about what steps to take to recover from identify theft or fraud. Today is a great time to consider ways to support your veteran and active military consumers. They are deserving of our support and recognition not just today but continuously. Learn more about services for veterans and active military to understand the varying protections, and how financial institutions can best support military credit consumers and their families.
Experian is recognized as a leading security solution provider for fraud and identity solutions in order to protect customers and financial institutions
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.
$1.3 trillion. 41.1 million Americans. $31,590. These are the growing numbers associated with student loan debt in the United States: $1.3 trillion in outstanding student loans, spread across 41.1 million people, who are leaving college with an average balance of $31,590. The numbers are staggering, and for the first time student loan debt is playing a prominent role in a presidential election. For all of their differences, presidential nominees Hillary Clinton and Donald Trump seem to agree on one thing: student loan debt is a crushing burden. Both candidates have proposed solutions for student lending. Clinton’s “New College Compact” would allow borrowers to refinance their student loans at current rates available to students taking out new loans. She also wants to reduce interest rates on new student loans, and make it easier for borrowers to enroll in income-driven repayment programs that would cap monthly payments at 10 percent of discretionary income. Trump proposes giving more oversight to colleges to decide whether to grant loans to students based on their prospective major. The plan would also give private banks oversight over government-backed student loans—reversing a 2010 decision under President Obama to make the federal government the lender. Neither candidate, however, has outlined a solution for taming growing tuition costs. Tuition expenses are up 1,225 percent over the past 36 years, outpacing medical costs (634 percent rise) and the consumer price index (279 percent) over the same period, according to the Bureau of Labor Statistics. So it’s not surprising an Experian study shows the student loan rate has grown five percent in the past three years. What is surprising is the number of people and the average age of those people holding student loans. Experian found: 20 percent of people with a credit file hold a student loan that is being repaid or deferred. The average age of a consumer with a student loan is 37, with an average income of $47,200 compared to 53.8 and an average income is $44,500 for consumers without a student loan. The average age of a consumer with at least one deferred student loan is 32.7 with an average income of $32,900 compared to 38.7 and an average income of $53,200 for consumers with at least one non-deferred student loan. Candidate proposals aside, one thing is certain: student loan debt has a very real impact on the daily lives of people, many of whom have delayed buying homes, starting families, and saving for retirement. Until policymakers find a way to address bloated tuitions and student debt, it will take many longer to realize their dreams.
Since 1948, International Credit Union Day – a time to recognize the credit union movement – has been celebrated the third Thursday of October. The day is the perfect time to remind your members and consumers about all of the services and benefits your credit union offers. This year’s theme, “The Authentic Difference,” celebrates what makes credit unions stand out. Here are 10 reasons CUs deserve a spotlight: Credit unions are non-profit cooperatives, owned and operated by its members. That means they emphasize consumer value to more than 217 million members worldwide. Profits go back to members in the form of reduced fees, higher savings rates and lower loan rates. Personal relationships are key. Credit unions pride themselves on developing relationships with their members, and CUs are typically staffed by friendly reps who know customers by name. Checking accounts are free. Roughly 80 percent of credit unions offer free checking accounts, compared to less than 50 percent of banks, according to economic research firm Moebs Services. Few ATM fees. Many credit union customers are able to avoid ATM fees because CUs typically give them access to a large network of ATMs by sharing branches and other resources. Savings rates are above average. Because credit unions don\'t have to pay dividends to shareholders and are exempt from federal taxes they can offer high rates on saving accounts. The average credit union offers CD, money market, and savings rates well above the national banking rates average. Lower interest rates. Credit unions offer lower interest rates on some loans. The difference between banks and credit unions was greatest in car-loan interest rates, according to a September report by SNL Financial. The average 36-month used-car loan interest rate offered by CUs was 2.67 percent compared to 4.45 percent for banks. For new-car loans, CUs offered an average interest rate for 48 months of 2.60 percent compared to 3.94 percent for banks. Invested in the community. A credit union’s core values are focused on its members and the communities where they live and work. Many provide financial education and outreach to consumers. It’s easier to get credit. CUs don’t have to abide by loan restrictions and qualifications mandated by a corporate office, so they have more flexibility to make loans when possible. Small-business support: CUs may know borrowers and are able to take into account intangibles like community reputation and accountability. Also, they understand the value to the community of a small business, its market and credit needs. Joining is easy. Many credit unions base eligibility simply on where you live, instead of restricting membership to a particular employer. Since expanding eligibility, credit union membership has grown by about two percent a year for the past decade.
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.
When financial planners and tax advisors meet with clients to review their portfolios, chances are they don\'t go over their credit reports often. Maybe they never do. Kiplinger’s estimates less than half of professional financial advisors take the time to review credit reports with clients. But taking this step is critical to understanding a person’s complete financial situation and creating a realistic plan. Prepare for Future Opportunities Clients may have all the credit they need at the moment, but if their credit score is mediocre or low, they might end up paying for it in the future. Just when they want to refinance a loan, buy more insurance, apply for a dream job or buy a business, they may discover their credit score is an obstacle. Check for Errors Credit bureaus collect billions of data points from millions of businesses each year, and it’s important to check a credit report for accuracy. If there are errors in a client’s file, he or she may be unfairly penalized. Keep in mind that nearly every company checks credit reports to determine who to do business with. Potential employers, business partners and insurance companies give credit files a look before deciding whether or not to make an offer to a person. Awareness Mistakes aren\'t the only factor leading to a low credit score. Too many hard inquiries, a maxed-out credit card or a number of small loans that could be paid off all cost credit points. Reviewing a credit report is a great way to help clients see the real impact their habits have on their financial life, and they could realize a significant rise in their credit score with little effort. Stand Out in the Crowd Even if a person has an exceptional credit report, a financial or tax advisor will gain credibility by reviewing their information with them. Doing so demonstrates out-of-the-box thinking and concern for a person’s financial health. Let\'s see a robo-advisor do this. Financial professionals can easily and securely review their clients’ credit reports online. Ready to understand your client’s complete financial situation? Try out our online solution at no cost to you. Interested in integrating with your existing financial or tax planning software? Learn more about integration options with Experian’s API.
In this new Telephone Consumer Protection Act (TCPA) era, calling your customers isn’t a thing of the past. It’s still okay to reach out to your clients by phone, whether to offer a new product or collect on an overdue bill. But strict compliance with TCPA rules is critical for any business that contacts customers by phone. Some of the very best ways you can protect yourself from TCPA exposure is to follow four steps when creating your dialing strategy: Customer consent: It’s important to maintain and update your customers’ contact preferences and consent to call them. Simply having a phone number on an application isn’t sufficient. Companies are required to have written permission, such as “I consent to calling my cell phone when there’s a problem …” Remember, permission may only be granted by the party who subscribes to the cellular service or who regularly uses that cell phone number. Landline or wireless?: Your database should also include the phone type for the telephone numbers you have for your customers. The dialing rules differ depending on the phone type, so it’s critical to know the type of phone you are calling or texting. Verify ownership: Ownership of cell phones should especially be validated to ensure the number hasn’t been reassigned and that the person who gave consent still owns the phone. One call can be made to a reassigned number with no liability, assuming you have no knowledge the number has changed. Repeating the action could lead to fines from $500 to $1,500 per infraction. Scrub Your Database: Have practices in place to remove any confirmed reassigned phone numbers from your database. This will help to improve your right-party contact rate and save you from potential TCPA headaches. No one disagrees that calling cell numbers is a risky business, but it can be done if you set the proper workflow in motion. Click here to learn more about Experian solutions that will help to reduce your TCPA compliance risk.
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.
Prescriptive solutions: Get the Rx for your right course of action By now, everyone is familiar with the phrase “big data” and what it means. As more and more data is generated, businesses need solutions to help analyze data, determine what it means and then assist in decisioning. In the past, solutions were limited to simply describing data by creating attributes for use in decisioning. Building on that, predictive analytics experts developed models to predict behavior, whether that was a risk model for repayment, a propensity model for opening a new account or a model for other purposes. The next evolution is prescriptive solutions, which go beyond describing or predicting behaviors. Prescriptive solutions can synthesize big data, analytics, business rules and strategies into an environment that provides businesses with an optimized workflow of suggested options to reach a final decision. Be prepared — developing prescriptive solutions is not simple. In order to fully harness the value of a prescriptive solution, you must include a series of minimum capabilities: Flexibility — The solution must provide users the ability to make quick changes to strategies to adjust to market forces, allowing an organization to pivot at will to grow the business. A system that lacks agility (for instance, one that relies heavily on IT resources) will not be able to realize the full value, as its recommendations will fall behind current market needs. Expertise — Deep knowledge and a detailed understanding of complex business objectives are necessary to link overall business goals to tactical strategies and decisions made about customers. Analytics — Both descriptive and predictive analytics will play a role here. For instance, the use of a layered score approach in decisioning — what we call dimensional decisioning — can provide significant insight into a target market or customer segment. Data — It is assumed that most businesses have more data than they know what to do with. While largely true, many organizations do not have the ability to access and manage that data for use in decision-making. Data quality is only important if you can actually make full use of it. Let’s elaborate on this last point. Although not intuitive, the data you use in the decision-making process should be the limiting factor for your decisions. By that, I mean that if you get the systems, analytics and strategy components of the equation right, your limitation in making decisions should be data-driven, and not a result of another part of the decision process. If your prescriptive environment is limited by gaps in flexibility, expertise or analytic capabilities, you are not going to be able to extract maximum value from your data. With greater ability to leverage your data — what I call “prescriptive capacity” — you will have the ability to take full advantage of the data you do have. Taking big data from its source through to the execution of a decision is where prescriptive solutions are most valuable. Ultimately, for a business to lead the market and gain a competitive advantage over its competitors — those that have not been able to translate data into meaningful decisions for their business — it takes a combination of the right capabilities and a deep understanding of how to optimize the ecosystem of big data, analytics, business rules and strategies to achieve success.
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.
Learn More Image
