Financial Services
As our newly elected officials begin to evaluate opportunities to drive economic growth in 2011, it seems to me that the role of lenders in motivating consumer activity will continue to be high on the list of both priorities and actions that will effectively move the needle of economic expansion. From where I sit, there are a number of consumer segments that each hold the potential to make a significant impact in this economy. For instance, renters with spotless credit, but have not been able or confident enough to purchase a home, could move into the real estate market, spurring growth and housing activity. Another group, and one I am specifically interested in discussing, are the so called ‘fallen angels’ - borrowers who previously had pristine track records, but have recently performed poorly enough to fall from the top tiers of consumer risk segments. I think the interesting quality of ‘fallen angels’ is not that they don’t possess the motivation needed to push economic growth, but rather the supply and opportunity for them to act does not exist. Lenders, through the use of risk scores and scoring models, have not yet determined how to easily identify the ‘fallen angel’ amongst the pool of higher-risk borrowers whose score tiers they now inhabit. This is a problem that can be solved though – through the use of credit attributes and analytic solutions, lenders can uncover these up-side segments within pools of potential borrowers – and many lenders are employing these assets today in their efforts to drive growth. I believe that as tools to identify and lend to untapped segments such as the ‘fallen angels’ develop, these consumers will inevitably turn out to be key contributors to any form of economic recovery.
More prospects equal more profits, right? Not necessarily. But surprisingly, companies in every industry (including cable and telecom) routinely burn acquisition dollars as if it is. The reality is that only more qualified prospects can lead to more profitable campaigns, making acquisitions a clear case of quality besting quantity. But why? No substitute for quality Engaging unqualified prospects is an unprofitable exercise requiring time and resources that are better spent on those who are ready, willing and able to buy from you. Benefits of an effective acquisition strategy include greater: Resource efficiency—less time, money and energy wasted on no-payback prospects Brand loyalty and higher lifetime value—by accurately matching consumers to products they relate to and desire Profitability and less bad debt—this one is probably obvious Fishing where the (best) fish are So how should a profit-minded telecom or cable company identify highly qualified prospects and invite them into the fold? Using a credit-score threshold, where anyone possessing the target score receives an offer, is one method. The benefit is simplicity. One disadvantage is unnecessary risk, as credit score is just one factor reflecting an individual’s creditworthiness. Another possibility is analyzing your best customers’ profiles or most profitable underwriting policies and integrating profit-building criteria into your campaign. This takes a little more effort but the payback potential is higher. Tapping into available sources Many companies find public records a rich source of decisioning data. Others have discovered that adding consumer-credit information to their acquisition formula not only improves prospect quality, it also reduces on-boarding costs. Derogatory payment information, revolving debt levels or unacceptable debt-to-income ratios will all surface in the process, informing and improving your credit management decisions. (Note: using credit data to assess risk requires you to make a firm offer of credit, according to FCRA guidelines.) You’ll do a lot of prospecting in 2011, so remember: when it comes to acquiring new customers, more isn’t better. Better is better. And using reliable, high-quality data is one way to ensure the impact and return of every marketing dollar.
Experian Decision Analytics has recorded increased demand from the marketplace for service integrations with interactive voice response (IVR), a phone technology that allows for automated detection of both voice and touch–tones. In the past quarter, there has been a more than 70 percent increase in IVR interest and it continues to grow. Why is there a demand for knowledge based authentication through IVR? Besides consumer acceptance of out of wallet questions, there is a dramatic increase in the need for remote authentication and fraud analytics that are accurate, not a burden to the consumer, cost–effective for organizations and part of an overall risk based authentication approach. Consumers stay connected in a number of ways — phone, online, mobile and short message service (SMS) — and are demanding the means to remain safe without compromising convenience. Knowledge based authentication through IVR provides this safety. Organizations must consider all the tools at their disposal to keep consumer data protected while preserving and promoting a positive customer experience. Given the interactive nature of knowledge based authentication, it is quite adaptable to various customer access channels, such as IVR, and it enables full automation of both inbound and outbound authentication calls. We know from both our own experience and from working with clients that consumers are more connected, more mobile and more networked than ever before - and fraud trends demonstrate this increases risk. As consumers continue to expand online profiles and fraud artists continue to seek out victims, successful fraud prevention will become paramount to financial survival. Leveraging products already in use by combining the technology capitalizes on an existing investment and is good business.
Many compliance regulations such the Red Flags Rule, USA Patriot Act, and ESIGN require specific identity elements to be verified and specific high risk conditions to be detected. However, there is still much variance in how individual institutions reconcile referrals generated from the detection of high risk conditions and/or the absence of identity element verification. With this in mind, risk-based authentication, (defined in this context as the “holistic assessment of a consumer and transaction with the end goal of applying the right authentication and decisioning treatment at the right time\") offers institutions a viable strategy for balancing the following competing forces and pressures: Compliance – the need to ensure each transaction is approved only when compliance requirements are met; Approval rates – the need to meet business goals in the booking of new accounts and the facilitation of existing account transactions; Risk mitigation – the need to minimize fraud exposure at the account and transaction level. A flexibly-designed risk-based authentication strategy incorporates a robust breadth of data assets, detailed results, granular information, targeted analytics and automated decisioning. This allows an institution to strike a harmonious balance (or at least something close to that) between the needs to remain compliant, while approving the vast majority of applications or customer transactions and, oh yeah, minimizing fraud and credit risk exposure and credit risk modeling. Sole reliance on binary assessment of the presence or absence of high risk conditions and identity element verifications will, more often than not, create an operational process that is overburdened by manual referral queues. There is also an unnecessary proportion of viable consumers unable to be serviced by your business. Use of analytically sound risk assessments and objective and consistent decisioning strategies will provide opportunities to calibrate your process to meet today’s pressures and adjust to tomorrow’s as well.
By: Staci Baker There has been a lot of talk in the news about the Dodd-Frank Act lately. According to the Dodd-Frank Resource Center of the American Financial Services Association (AFSA), “The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which passed on July 21, 2010, is unprecedented in magnitude, and will impact every sector of the financial services industry.” The aim of the Act is to put measures in place that address the issues that led to the financial crisis. This is done by setting up new regulatory bodies, and limiting the dealings of banks and other financial institutions. For the purpose of this blog, I will focus on describing the new regulatory agencies. The Bureau of Consumer Financial Protection (CFPB), is an independent watchdog housed within the Federal Reserve. The CFPB has the authority to “regulate consumer financial products and services in compliance with federal law.”[ii] They are responsible for the accuracy of information, hidden fees and deceptive practices for consumers from within the following industries – mortgage, credit cards and other financial products. The Financial Stability Oversight Council is “charged with identifying threats to the financial stability of the United States, promoting market discipline, and responding to emerging risks to the stability of the United States financial system.”ii Through the Treasury, this council will create a new Office of Financial Research, which will be responsible for collecting and analyzing data to identify and monitor emerging risks to the economy, and publish the findings in periodic reports. These new regulatory agencies are critical to US business processes, as they will more closely monitor business practices, create new tighter legislation, and report findings to the public. The legislation that is created will decrease risk levels posed by large, complex companies, as well as address discrepancy that has been raised throughout the financial crisis. What are your views of the Dodd-Frank Act? Do you believe this is the legislation needed to stem future financial crisis? If not, what would help you and your business?
Increased incidence of “involuntary renters” According to the Mortgage Bankers Association, one out of every 200 homes will be foreclosed. The incidence of “involuntary renters” will increase as a high foreclosure rate continues, in turn, fueling the current trend of consumers who rely solely on mobile service instead of landlines. Implications for communications companies Does it necessarily follow that foreclosure equals bad risk? I don’t think so. For example, many consumers who have undergone foreclosure were subjected to a readjusted ARM that doubled or even tripled their mortgage payments. While taking a mortgage out of a consumer’s credit file can negatively impact the overall credit score, it can also potentially generate a more positive cash flow. The consumer’s new rent payments would be lower than the readjusted mortgage would have been, making the consumer a potentially good customer for communications services. Wireless companies, in particular, prefer to approve customers for regular installment plans (as opposed to prepaid plans). The goal, for nearly all communications companies, is to qualify customers for service without the need for a deposit. The key, when assessing credit risk, is to look at the total credit/payment history, not just the credit score alone. Best Practices for qualifying involuntary renters: Validate ID/authenticate. Checking the credit application information against several data sources will help avoid potential fraud. Look at the overall credit picture, especially the current debt-to-income ratio. Review third-party data for payment history. Along with the typical payment data, Experian now offers rental histories through RentBureau. This data has the ability to increase credit report accuracy for renters. Consider the basic lender mentality. Consumers who have exhibited good payment history on utilities, credit cards, and other debt in the past are likely to continue that behavior despite having lost their house to foreclosure. Considering the total credit picture allows you to rank-order customers and group them into populations that are lower risk, identifying, for example, those who can be serviced without an upfront deposit. In future posts, I’ll provide some guidance for rank-ordering customers as to their credit-worthiness.
Experian’s Fraud and Identity Solutions team recently conducted a webinar entitled: “A risk-based approach to finding opportunity in today’s market: New approaches to fraud, compliance, and operational efficiency in an evolving economy.” I specifically discussed the current business drivers and fraud trends we, as a consumer and commercial authentication services provider, hear most often from our existing and potential clients. I was encouraged to have the following forces validated by our audience, and I thought they’d be worth sharing with you via this forum. In what I believe to be rank order with most influencing first: Customer experience is king. The addressable market for most of our clients is effectively an ever more limited pool of viable consumers. From the consumer’s perspective it’s a ‘buyer’s market’. ‘Good’ consumers know they are ‘good’ and those 750 scorers don’t tolerate poor customer service. Risk seeking credit policies may be making a comeback. Many of our clients are starting to heal from the past few years, and are ready to get back on the bike. However, this does open the door more widely for application fraud activity and risk. New products and associated solicitations and access channels translate to higher risk as fraud prevention and fraud detection processes may be less robust in the early launch stages and certainly less time-tested. Human & IT resources are still in short supply. As these new channels open and fraud risk increases, necessary fraud prevention and authentication oriented resources are still overly constrained and often significantly lagging in proportionality behind the recovery-minded marketing minds. Regulatory pressures continue to equate to higher operational costs, in the form of fraud referral rates, in process engineering and human intervention and activities, not to mention the opportunity costs associated with denial of service to those ‘good’ consumers I just mentioned. So, hosted services and solutions are where it’s at these days. Our clients want their vendors, including us at Experian, to save their IT resources, deliver quicker to market services, such as fraud models, knowledge based authentication, and other authentication tools, and provide collective capabilities that would otherwise be years away if left to the mercy of their internal development queues. All products and processes are under review, as you might imagine. Cost control is no longer a back-burner policy and focus. ROI is the key metric these days, and likely above any other. Our clients demand flexible tools that can be deployed in multiple process points and across multiple business units. Blanket policies (including fraud prevention and authentication) are no longer good enough. Our clients’ tailored products, access channels, and market segmentations require the same level of unique design in the products we deliver.
In the communications industry, effective acquisition is a multi-step process, best begun by asking (and accurately answering) simple, but critical questions: Who are our best prospects? Where can we find them? What should we offer them and how? Of course, the “why” is obvious—beating competitors to the punch. The similarities of today’s increasingly undifferentiated products and services make attracting high-quality customers more critical than ever. On the surface, the “who” seems equally straightforward. But it’s surprising how many communications companies still blanket the nation with ads and offers without knowing whom they want to reach or which messages to lead with. This brings us to the “how” of effective acquisition. Banks get it right Banks provide a good acquisition model. In these days of tight budgets and high expectations, most would never dream of investing in a campaign without first creating a well-defined, data-driven segmentation strategy. To get the results they want, institutions usually establish some credit-score threshold, check past payment history and assess other factors and behaviors, before starting up their marketing machine. Not surprisingly, the rewards for this foresight often include higher response rates, lower costs and greater value per promotional dollar. What’s next? Once you zero in on a fresh crop of qualified prospects the “whats” come next: what’s the best marketing channel? What products or services should we offer? What terms? Again, clean historic data, combined with up-to-date information from surveys and questionnaires can reveal surprising insights into why customers choose your company or offer over your competitors’. In communications, as in banking, reliable data is a proven source for answers to a whole slew of customer-acquisition questions. But does it offer similar value in other phases of customer lifecycle management? And if so, how? Funny you should ask. Because that’s exactly what future posts here will cover, so please check back often.
By: Kari Michel What are you doing to prepare for the new credit score disclosure requirements for taking adverse action on the basis of information contained in a consumer credit profile report, including scoring models? The Dodd-Frank Wall Street Reform and Consumer Protection Act (CFPB) which was signed by President Obama on July 21, 2010, have prescribed new rules for Adverse Action and Risk Based Pricing notifications. The new credit score disclosure rules will become effective July 21, 2011. The rules have NOT been finalized at this time. With the information currently available, the new rules will impact all lenders who take adverse action against a consumer due to information in a consumer credit report. Lenders will be required to disclose to the consumer: · The actual numerical score used in the adverse decision (new requirement) · The range of possible scores under the model used (new requirement) · All key factors that adversely affected the credit score - This legislation mandates the delivery of 5 factor codes (when applicable). The notice must include the top 4 and then a 5th when inquiries play a negative part in the score calculation (new requirement) · The date on which the credit score was created · The name of the entity that provided the score If you have questions regarding the FCRA sections that are changing, you can refer to the Dodd-Frank legislation section 1100F.
Many compliance regulations such the Red Flags Rule, USA Patriot Act, and ESIGN require specific identity elements to be verified and specific high risk conditions to be detected. However, there is still much variance in how individual institutions reconcile referrals generated from the detection of high risk conditions and/or the absence of identity element verification. With this in mind, risk-based authentication, (defined in this context as the “holistic assessment of a consumer and transaction with the end goal of applying the right authentication and decisioning treatment at the right time\") offers institutions a viable strategy for balancing the following competing forces and pressures: Compliance – the need to ensure each transaction is approved only when compliance requirements are met; Approval rates – the need to meet business goals in the booking of new accounts and the facilitation of existing account transactions; Risk mitigation – the need to minimize fraud exposure at the account and transaction level. A flexibly-designed risk-based authentication strategy incorporates a robust breadth of data assets, detailed results, granular information, targeted analytics and automated decisioning. This allows an institution to strike a harmonious balance (or at least something close to that) between the needs to remain compliant, while approving the vast majority of applications or customer transactions and, oh yeah, minimizing fraud and credit risk exposure and credit risk modeling. Sole reliance on binary assessment of the presence or absence of high risk conditions and identity element verifications will, more often than not, create an operational process that is overburdened by manual referral queues. There is also an unnecessary proportion of viable consumers unable to be serviced by your business. Use of analytically sound risk assessments and objective and consistent decisioning strategies will provide opportunities to calibrate your process to meet today’s pressures and adjust to tomorrow’s as well.
Ready for Risk-Based Pricing? The New Year always marks a start. A new year. New resolutions. And, this year, it marks the start of the Risk-Based Pricing Rule. Just to review, risk-based pricing involves setting or adjusting a customer’s interest rate and other terms of credit based on that consumer’s credit history and other factors used to measure risk. Established by the Federal Reserve Board and the Federal Trade Commission (FTC) last December, and effective as of Jan. 1, 2011, the Risk-Based Pricing (RBP) Rule addresses the concern by policymakers that consumers are not sufficiently informed of the impact their credit report can have on the annual percentage rate (APR) they get charged for new credit. When a lender makes a credit decision based upon a consumer credit report and does not offer the best rate possible, the RBP Rule requires lenders to notify the customer about the decision. Currently, there are two options to comply with the RBP Rule: 1) Send a notice to inform customers that they didn’t get the best rate possible. 2) Or, provide customers with a credit score, along with educational information. The Rule is changing With passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act earlier this year, the compliance options for organizations will soon become more complicated. Companies will still have the option to send a risk-based pricing notice, but they will be required to provide all customers with a credit score within that notice. Standard adverse action notices, given when the consumer is denied credit, will also have to include a score disclosure. The new requirement will likely take effect as early as July 21, 2011 (the target date for the new Bureau of Consumer Financial Protection (CFPB) to be fully operational). Most companies have already begun instituting compliance policies, but they may need to take a longer view. Opportunities Beyond compliance, the rule change and the Dodd-Frank law provide new opportunities to educate consumers about what credit scores mean to them and how they’re used by lenders. This presents new ways to strengthen customer relationships and improve overall financial literacy among the public if companies are willing to take the initiative. Three important RBP Rule issues to keep in mind: The effective date for compliance is January 1, 2011.Companies will have two options: (1) inform customers that they didn’t get the best rate based upon their credit report or (2) provide a credit score. Requirements for risk-based pricing could change as early as July 21, 2011, when oversight transfers to the CFPB and all companies must begin providing customers with a credit score. With an increase in the number of credit scores organizations are disclosing, customers will come to creditors with questions about their credit report and score. In coming posts, I’ll explore the various facets of the Risk-Based Pricing Rule and the challenges and opportunities communications companies will be presented with. Note: While Experian is happy to provide our observations related to the new Risk-Based Pricing Rule, please work with your own legal counsel to ensure that you comply with your obligations under the rule.
By: Staci Baker According to Wikipedia, mobile banking is defined as, “a term used for performing balance checks, account transactions, payments, credit applications, etc. via a mobile device such as a mobile phone or Personal Digital Assistant (PDA).” However, as several large lenders and phone carriers test mobile banking and mobile payments, there is still much to be deciphered. Will it help businesses compete? Is it safe for a consumer? Should a bank offer a mobile solution; and if so, what precautions will they need to take to ensure their customer’s information, i.e. fraud, consumer identity? Peter Garuccio, spokesman for the American Bankers Association in Washington D.C., noted that “various experts predict that some 20 million people may be banking via cell phone this year, and that number is projected to skyrocket to 50 million by 2013.” And, according to a mobile payment study by Juniper Research ,“Combined market for all types of mobile payments is expected to reach more than $630B globally by 2014.” For the purpose of this blog, I will focus on the mobile banking solution, and questions to consider before entering into the mobile banking arena. Mobile banking today is akin to online banking a few years ago. It’s new, getting a lot of press, late adopters want more information, while the early adopters are already participating and it appears to be on the verge of taking over more conventional banking and payments. Before entering into the world of mobile solutions, there are a few things to consider: How will new regulations, such as the Durbin Amendment to the Frank-Dodd Act (a new Interchange fee proposal), affect implementation and usage? The current average interchange fee is between $1 and $1.30, the new cap at $.12 will reduce the charges by up to 90%.While the interchange fee proposal will not be finalized until after February, it is not known how the new “swipe fee” legislation will affect mobile solutions. If the new amendment directly affects debit cards only, mobile solutions can become a new revenue stream for many lenders. As more information becomes available regarding the Durbin Amendment, I will relay additional details and implications. What fraud prevention solutions do you have in place? Fraud is an issue in all industries; therefore utilizing fraud best practices specific to your market, or identifying fraud trends is essential in keeping retailers, consumers and your company safe. As consumers replace the need for a wallet with a phone, identity theft can become an issue. This is especially true of phones with minimal security, or if their phone gets into the hands of a hacker. Therefore companies can initiate an identity theft prevention program to raise awareness in consumers and retailers. As well as implement new internal processes and requirements. As we delve further into an IT-led economy, businesses will continually need to adjust how they do business in order to meet consumer demand, as well as finding new revenue streams. I am curious, how many businesses have already begun to implement a mobile solution, and what issues or results have you already seen? If you have not already implemented a mobile solution, is this in your planning for the upcoming year?
By: Kari Michel Lending institutions are more challenged today than ever before when assessing credit risk to find creditworthy consumers. Since 2006, the start of the housing bust and recession, consumer’s overall creditworthiness has deteriorated, especially those consumers who once had a high score (low risk). “For example, a study earlier this year by VantageScore found that the probability of serious delinquency, defined as nonpayment for 90 days or more, had increased by 417 percent among “super prime” borrowers between June 2007 and June 2009. Default risk during the same period rose by 406 percent for the second-highest rated category of “prime” consumers, and nearly doubled for those at the “near prime” scoring level.”* VantageScore is one example of a credit risk model that was recently redeveloped to capture the changing consumer behavior of repayment. The development data set included 45 million consumer credit profiles for the time period of 2006 to 2009. VantageScore 2.0 will be released for lenders use January 2011. *Source: The Washington Post, “Walk-aways leading to big changes for all borrower’s credit score, November 5, 2010 Link for article: http://www.washingtonpost.com/wp-dyn/content/article/2010/11/05/AR2010110502133.html
By: Kristan Frend According to the 2011 Identity Theft Assistance Center Outlook (ITAC), new forms of small business identity theft are emerging. This shouldn’t be a surprise that criminals view small business accounts as a lucrative funding source. What is surprising is that the ‘new’ form of small business identity theft consists of the U.S. Postal Inspection Service reporting a surge in criminal rings using small business information from stolen mail, check writing software and other tactics to counterfeit checks. That’s the new wave of small business identity theft??? I consider this one of the least sophisticated types of fraud that can easily be eliminated by small business owners not leaving mail unattended. Reading this report makes me realize that we have a long way to go in identifying and reporting the more sophisticated types of small business fraud. As I’ve mentioned before, the industry has come a long way in advancing consumer fraud solutions. Yet, as fraud has migrated into business accounts, we as an industry still have a ways to go in reporting the latest business fraud trends and tracking statistics. I’m adding this to my wish list for 2011… What’s on your wish list? On a side note, I’ve noticed nearly all of the articles posted in our blog include no reader comments. I’d like to think that this means our readers are too busy to add comments and/or our articles are so well-written that they answer all of your questions. One can dream right? Seriously though, as we approach 2011 and plan our topics, we’d love to hear from you- if you can think of any topic you’d like us to cover more in depth, please let us know.
By: Kristan Frend As my colleague Margarita Lim discussed in her December 3rd article, the SSA announced that it will change how social security numbers (SSNs) will be issued, with a move toward a random method of assigning SSNs. For organizations that currently incorporate the validation of an applicant’s SSN issue date and state as a part of their risk-based decisioning, they will lose this piece of applicant authentication post-randomization. But there is some good news - first, this validation piece won’t be entirely terminated on day one of the SSN randomization for organizations. All the change means is that the newly issued SSNs will be randomized. In other words, the only SSNs that the issue data and state won’t be validated on day one are the SSNs that have just been issued to the recently born or immigrants. Given that its likely newborns won’t be applying for credit for another 18 years, the bulk of the newly issued SSNs that organizations will see for a while are those belonging to adults who were recently issued a SSN…A growing number of applicants, but not the majority of applicants. The other bit of good news is this may actually be a good thing for all of us in the long run. While we’ll end up losing the ability to validate an applicant’s SSN issue data and state, the criminals will be at an even greater disadvantage. Consider this- Last year researchers* were able to “identify all nine digits for 8.5 percent of people born after 1988 in fewer than 1,000 attempts. For people born recently in smaller states, researchers sometimes needed just 10 or fewer attempts to predict all nine digits.” I don’t expect this change to drastically reduce third party fraud rates but over time it should eliminate one component of identity theft and ultimately benefit an organization’s Customer Information Program. *The National Science Foundation, the U.S. Army Research Office, Carnegie Melon Cylab, and the Berkman Faculty Development Fund provided support for the research. To view the entire study, please visit http://www.pnas.org/content/106/27/10975.full.pdf+html.
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