Financial Services
By: Ken Pruett The majority of the customers I meet with use some sort of Velocity Checks to assist with their Fraud and Compliance process. However, there are still quite a few that do not, especially when opening up New Business Accounts. Historical data checks have proven to be an effective form of identity theft prevention for both Consumer fraud and Commercial Fraud. We see scenarios where a perpetrator will have one successful penetration of a business and opens up a fraudulent account. They then try and replicate this against the same business. All of the information may be different, with the exception of one element, often the phone number. Without velocity checks, this may not be identified at the time the account is being opened. More sophisticated rings try to be more creative in their fraudulent attempts. They may gain access to a consumers information and then go and apply at a variety of entities. They are more careful, so they never attempt to target the same business twice. They are aware that many companies have velocity checks, so they do not want to take a chance of having their information questioned. At a minimum, the use of in-house velocity checks should be a standard process for you fraud detection measures. Typical data elements to check against are; name (business or consumer), address, phone number, and Social Security Number. A fraud best practice would be to use a tool that provides velocity checks and incorporates the information into a fraud prevention tool. There are tools that provide checks across multiple businesses and this typically provides the best level of protection. By looking at inquiry information across multiple businesses, you are able to help prevent being a victim of some of the more sophisticated rings. Don’t find yourself being the easiest target. Once you get hit, it could snowball and you may be victimized multiple times. We all know there is no way to stop all of the fraud, but let’s not make it too easy on the perpetrators. Try and find a way to use some sort of velocity checks in your process to at least minimize your fraud risk.
By: Andrew Gulledge Bridgekeeper: “What is the air-speed velocity of an unladen swallow?” King Arthur: “What do you mean? An African or European swallow?” Here are some additional reasons why the concept of an “average fraud rate” is too complex to be meaningful. Different levels of authentication strength Even if you have two companies from the same industry, with the same customer base, the same fraudsters, the same natural fraud rate, counting fraud the same way, using the same basic authentication strategies, they still might have vastly different fraud rates. Let’s say Company A has a knowledge-based authentication strategy configured to give them a 95% pass rate, while Company B is set up to get a 70% pass rate. All else being equal, we would expect Company A to have a higher fraud rate, by virtue of having a less stringent fraud prevention strategy. If you lower the bar you’ll definitely have fewer false positives, but you’ll also have more frauds getting through. An “average fraud rate” is therefore highly dependent on the specific configuration of your fraud prevention tools. Natural instability of fraud behavior Fraud behavior can be volatile. For openers, one fraudster seldom equals one fraud attempt. Fraudsters often use the same techniques to defraud multiple consumers and companies, sometimes generating multiple transactions for each. You might have, for example, a hundred fraud attempts from the same computer-tanned jackass. Whatever the true ratio of fraud attempts to fraudsters is, you can be confident that your total number of frauds is unlikely to be representative of an equal number of unique fraudsters. What this means is that the fraud behavior is even more volatile than your general consumer behavior, including general fraud trends such as seasonality. This volatility, in and of itself, correlates to a greater degree of variance in fraud rates, further depleting the value of an “average fraud rate” metric. Limited fraud data It’s also worth noting that we only know which of our authentication transactions end up being frauds when our clients tell us after the fact. While plenty of folks do send us known fraud data (thus opening up the possibility of invaluable analysis and consulting), many of our clients do not. Therefore even if all of the aforementioned complexity were not the case, we would still be limited in our ability to provide global benchmarks such as an “average fraud rate.” Therefore, what? This is not to say that there is no such thing as a true average fraud rate, particularly at the industry level. But you should take any claims of an authoritative average with a grain of salt. At the very least, fraud rates are a volatile thing with a great deal of variance from one case to the next. It is much more important to know YOUR average fraud rate, than THE average fraud rate. You can estimate your natural fraud rate through a champion/challenger process, or even by letting the floodgates open for a few days (or however long it takes to gather a meaningful sample of known frauds), then letting the frauds bake out over time. You can compare the strategy fraud rates and false positive ratios of two (or more) competing fraud prevention strategies. You can track your own fraud rates and fraud trends over time. There are plenty of things you can do to create standardize metrics of fraud incidence, but good heavens for the next person to ask me what our average fraud rate is, the answer is “No.”
By: Andrew Gulledge I hate this question. There are several reasons why the concept of an “average fraud rate” is elusive at best, and meaningless or misleading at worst. Natural fraud rate versus strategy fraud rate The natural fraud rate is the number of fraudulent attempts divided by overall attempts in a given period. Many companies don’t know their natural fraud rate, simply because in order to measure it accurately, you need to let every single customer pass authentication regardless of fraud risk. And most folks aren’t willing to take that kind of fraud exposure for the sake of empirical purity. What most people do see, however, is their strategy fraud rate—that is, the fraud rate of approved customers after using some fraud prevention strategy. Obviously, if your fraud model offers any fraud detection at all, then your strategy fraud rate will be somewhat lower than your natural fraud rate. And since there are as many fraud prevention strategies as the day is long, the concept of an “average fraud rate” breaks down somewhat. How do you count frauds? You can count frauds in terms of dollar loss or raw units. A dollar-based approach might be more appropriate when estimating the ROI of your overall authentication strategy. A unit-based approach might be more appropriate when considering the impact on victimized consumers, and the subsequent impact on your brand. If using the unit-based approach, you can count frauds in terms of raw transactions or unique consumers. If one fraudster is able to get through your risk management strategy by coming through the system five times, then the consumer-based fraud rate might be more appropriate. In this example a transaction-based fraud rate would overrepresent this fraudster by a factor of five. Any fraud models based on solely transactional fraud tags would thus be biased towards the fraudsters that game the system through repeat usage. Clearly, however, different folks count frauds differently. Therefore, the concept of an “average fraud rate” breaks down further, simply based on what makes up the numerator and the denominator. Different industries. Different populations. Different uses. Our authentication tools are used by companies from various industries. Would you expect the fraud rate of a utility company to be comparable to that of a money transfer business? What about online lending versus DDA account opening? Furthermore, different companies use different fraud prevention strategies with different risk buckets within their own portfolios. One company might put every customer at account opening through a knowledge based authentication session, while another might only bother asking the riskier customers a set of out of wallet questions. Some companies use authentication tools in the middle of the customer lifecycle, while others employ fraud detection strategies at account opening only. All of these permutations further complicate the notion of an “average fraud rate.” Different decisioning strategies Companies use an array of basic strategies governing their overall approach to fraud prevention. Some people hard decline while others refer to a manual review queue. Some people use a behind-the-scenes fraud risk score; others use knowledge based authentication questions; plenty of people use both. Some people use decision overrides that will auto-fail a transaction when certain conditions are met. Some people use question weighting, use limits, and session timeout thresholds. Some people use all of the out of wallet questions; others use only a handful. There is a near infinite possibility of configuration settings even for the same authentication tools from the same vendors, which further muddies the waters in regards to an “average fraud rate.” My next post will beat this thing to death a bit more.
A recent article in the USA Today titled, “Jobs rebound will be slow”*, outlines state-by-state forecasts for the United States, as released by Moody\'s Economy.com. Although the national forecasted increase, 0.9%, reflects the expectation that unemployment will remain an issue throughout 2011, the state-level detail possesses interesting variances that should be further considered by lenders in determining their marketing and acquisition strategies. What I find intriguing, is that Moody’s forecasts job growth for several states that since the beginning of the housing decline have been the hot-spots for mortgage default and high delinquency rates. Moody’s projects job growth for Florida (+2.5%), Nevada (+1.5%), and California (+0.5%) – the so called “sand states” – with comparable growth rates to states like Texas (+2.5%) and North Carolina (+1.3%), which have not experienced the same notoriety for increased risk levels and delinquency. Should this growth transpire, then these states that have been the center of credit risk in recent years will soon become centers of opportunity for lenders, as increased employment should result in decreasing delinquency rates, improved repayment habits, and a generally more creditworthy consumer population. This shift is important, since any economic recovery will start with jobs growth, leading to increased lending, which will drive housing and a broader economic growth. As I noted above, the Moody’s forecast implies that lenders who are looking to drive growth may find that profitable portfolio segments exist in some of what appear to be the unlikeliest places. __________________ *http://www.usatoday.com/money/economy/2009-02-06-new-jobs-growth-graphic_N.htm
By: Margarita Lim It’s the holiday season and a festive time of year. Colorful Christmas lights and decorations, holiday songs, all of these things contribute to the celebratory atmosphere which causes many people to let their guards down. Unfortunately, fraudsters and other criminals take advantage of the prevailing goodwill and can help make one of the busiest shopping times of the year, a miserable one for their victims. It’s not a surprise that articles and news stories are released advising shoppers on how to continue enjoying their holiday season by not being victims of identity theft or other known fraud activities. Consumers can get tips from the Federal Trade Commission and other websites to prevent or minimize exposure to identity theft but I think key ones include: • If using credit cards for purchases, write ‘Check Photo ID’ on the back of your credit card. • Be very protective about disclosing personal information, especially Social Security Numbers. Did you know that it only takes one piece of personal information about you for a thief to steal your identity? • If shopping online, only make purchases from recognizable online retailers and websites. Many fraudsters will create fake websites that offer goods for sale in order to collect personal and credit information that can then be used to make fraudulent purchases. If consumers need to be careful this holiday season, businesses should also be vigilant. Fraudsters cause businesses like banks, retailers and credit card companies to lose millions of dollars that ultimately get passed on to their customers. Companies need to make sure they have tools in place to minimize these fraud losses. I’ve mentioned this in a previous post but Experian supports Identity Theft Prevention Programs by offering highly accurate consumer identity verification services. Our consumer authentication and fraud prevention product, Precise ID, and our knowledge based authentication product, Knowledge IQ, are highly respected in the marketplace for their reliability, quality and accuracy. Implementing either of these products would go a long way in preventing fraud this holiday season.
The U.S. Senate passed legislation recently that would exempt certain businesses from complying with the Red Flags Rule. Sponsored by Senator John Thune (R-SD), the bill (S. 3987) creates an exception to the Red Flags Rule for businesses that do not advance funds to a customer. The bill would, for example, redefine the term “creditor” as currently described under the Red Flags Rule guidelines, to apply only to those businesses who advance funds to, or on behalf of, a customer, and based upon an obligation to repay those advanced funds. The legislation also still provides the Federal Trade Commission with authority to require certain organizations to comply with the Red Flags Rule. The legislation now moves to the U.S. House of Representatives, where the chamber must approve the bill before the end of the year in order for the bill to become law. This may alleviate many businesses in industries such as law practices, healthcare providers (particularly solo practitioners), and perhaps some service providers in telecommunications and utilities. However, it is likely that many businesses in the utilities space will still fall under Red Flags Rule enforcement given their accessing of consumer credit profiles in many of their application processing procedures. Again, one has to wonder what the original intent of the Red Flags Rule was. If it was to protect consumers from identity theft and other fraud schemes via a robust identity theft prevention program, then vastly narrowing the businesses under which potential enforcement applies seems counter-productive. The advancement of funds or not doesn’t necessarily add to or reduce risk of fraud, as much as the actual obtainment of accounts and services with identity information…regardless of industry. More to follow…
By: Staci Baker Top five things to know about the Risk-Based Pricing Rule As many of you are preparing for the new Risk-Based Pricing Rule to take effect on January 1, 2011, I want to give you an overview of the top five things you need to know to ensure your business is compliant. 1. Applicability: Any company that uses a credit report or score in connection with a credit decision will be required to comply with the Risk-Based Pricing Rule. 2. Obligation: A lender is obligated to send a notice to a consumer when they use a credit report or score in connection with a credit transaction. When the lender provides credit to the consumer on material terms* that are materially less favorable than the most favorable terms available to a substantial proportion of consumers from or through that lender (any consumer who does not receive the lender’s best rate) based on the credit report or score, the lender is required to take action. 3. Compliancy: Lenders will be required to provide applicable consumers with the following: • A Risk-Based Pricing Notice, or • A Credit Score Disclosure Exception Notice • Model forms are available in the final ruling issued by the Federal Reserve Board and Federal Trade Commission 4. Exceptions to the Rule: There are several exceptions to the Rule, including: • When a lender is making a pre-screened offer or providing an adverse action notice, or • When a consumer applies for specific credit terms or business credit (all credit that is not for personal, family or household use is excluded from the rule.) 5. Exclusions to the Rule: Any lender who does not use a credit report or score in connection with a credit decision is excluded from the ruling. The ruling does not apply to small business lenders also. These top five key components of the Rule should get you on the way to compliancy by the beginning of the year. A pre-recorded webinar is available to give you additional information on compliancy and requirements of the Risk-based Pricing Rule. The Federal Reserve, http://www.federalreserve.gov/reportforms/formsreview/RegV_20100115_ffr.pdf * “Material terms” in most cases of the Rule are defined as the APR of the loan
By: Margarita Lim Recently, the Social Security Administration (SSA) announced that it will change how Social Security numbers (SSN) will be issued, with a move toward a random method of assigning SSNs. Social Security numbers are historically 9 digits in length, and are comprised of a three-digit number that represents a geographic area, a two-digit number referred to as a Group number and a four digit serial number.You can go to http://www.ssa.gov/employer/randomization.html to learn more about this procedural change, but in summary, the random assignment of SSNs will affect: • The geographic significance of the first three digits of the SSN because it will no longer uniquely represent specific states • The correlation of the Group number (the fourth and fifth digits of the SSN) to an issuance date range. What does this mean? It means that if you’re a business or agency that uses any type of authentication product in order to minimize fraud losses, one of the components used to verify a consumer’s identity – Social Security number, will no longer be validated with respect to state and date. However, one of the main advantages of utilizing a risk-based approach to authentication is the reduction in over-reliance on one identity element validation result. Validation of SSN issuance date and state, while useful in determining certain levels of risk, is but one of many attributes and conditions utilized in detailed results, robust analytics, and risk-based decisioning. It can also be argued that the randomization of SSN issuance, while somewhat impacting the intelligence we can glean from a specific number, may also prove to be beneficial to consumer protection and the overall confidence in the SSN issuance process.
As the December 31st deadline approaches for FTC enforcement of the Red Flags Rule, we still seem quite a ways off from getting out from under the cloud of confusion and debate related to the definition of ‘creditor’ under the statutory provisions. For example, the Thune-Begich amendment to “amend the Fair Credit Reporting Act with respect to the applicability of identity theft guidelines to creditors” looks to greatly narrow the definition of creditor under the Rule, and therefore narrow the universe of businesses and institutions covered by the Red Flags Rule. The question remains, and will remain far past the December 31 enforcement deadline, as to how narrow the ‘creditor’ universe gets. Will this amendment be effective in excluding those types of entities generally not in the business of extending credit (such as physicians, lawyers, and other service providers) even if they do provide service in advance of payment collection or billing? Will this amendment exclude more broadly, for example ‘buy-here, pay-here’ auto dealers who don’t extend credit or furnish data to a credit reporting agency? Finally, is this the tip of an iceberg in which more entities opt out of the requirement for robust and effective identity theft prevention programs? So one has to ask if the original Red Flags Rule intent to “require many businesses and organizations to implement a written Identity Theft Prevention Program designed to detect the warning signs – or “red flags” – of identity theft in their day-to-day operations, take steps to prevent the crime, and mitigate the damage it inflicts” still holds true? Or is the idea of protecting consumer identities only a good one when it is convenient? It doesn’t appear to be linked with fraud risk as healthcare fraud, for example, is of major concern to most practitioners and service providers in that particular industry. Lastly, from an efficiency perspective, this debate would likely have been better timed at the drafting of the Red Flags Rule, and prior to the implementation of Red Flags programs across industries that may be ultimately excluded.
By: Kari Michel As consumers and businesses continue to experience financial hardship, the likelihood of continued bankruptcy filings is fairly strong. Data from the Administrative Office of the U.S. Courts show there were 1,222,589 filings through September, versus 1,100,035 in the first nine months of 2009. According to American Bankruptcy Institute executive director Samuel J. Gerdano, \"As the economy looks to climb out of the recent recession, businesses and consumers continue to file for bankruptcy to regain their financial footing. With unemployment hovering near 10% and access to credit remaining tight, total filings in 2010 will likely exceed 1.6 million.\" Given the bankruptcy trends, what can lenders do to protect themselves from acquiring consumers that are at risk for filing for bankruptcy? Bankruptcy scores are available, such as Bankruptcy PLUS, and are developed to accurately identify characteristics specific to a consumer filing for bankruptcy. Bankruptcy scores are typically used in conjunction with risk scores to set effective acquisition strategies. _________________ Source: http://www.collectionscreditrisk.com/news/bankruptcy-filings-up-3003998-1.html
By: Staci Baker As we approach the end of the year, and the beginning of holiday spending, consumers are looking at their budgets to determine what level of spending they can do this holiday season, or if they will need additional credit for those much wanted gifts. With that in mind, it is a great time for lenders to evaluate their portfolios to determine which consumers are the best credit risks. According to the National Retail Federation, consumer spending will be up 2.1% for the 2010 holiday season. Although still at pre-recession levels, consumer confidence is starting to re-bound. But, with an increase in consumer confidence, how will lenders meet the demand for credit, and determine the credit worthiness of potential applicants? Since the beginning of the recession there has been a demand for tools that will assist lenders in managing credit risk. One such tool is the tri-bureau VantageScore, a scoring model that is highly accurate, offers greater predictiveness, and is able to score more people. Scoring models allow lenders to predict the likelihood a consumer will default on a loan. Determining who is a qualified candidate through scoring models is only part of the equation. Each lender needs to determine what level of risk to take, and what is the cost of the credit per applicant. By assessing credit risk, having a good plan in place and knowing who the target customer is, lenders will be more prepared for the holiday season. ___________________ National Retail Federation, http://www.nrf.com/modules.php?name=News&op=viewlive&sp_id=1016
As E-Government customer demand and opportunity increases, so too will regulatory requirements and associated guidance become more standardized and uniformly adopted. Regardless of credentialing techniques and ongoing access management, all enrollment processes must continue to be founded in accurate and, most importantly, predictive risk-based authentication. Such authentication tools must be able to evolve as new technologies and data assets become available, as compliance requirements and guidance become more defined, and as specific fraud threats align with various access channels and unique customer segments. A risk-based fraud detection system allows institutions to make customer relationship and transactional decisions based not on a handful of rules or conditions in isolation, but on a holistic view of a customer’s identity and predicted likelihood of associated identity theft. To implement efficient and appropriate risk-based authentication procedures, the incorporation of comprehensive and broadly categorized data assets must be combined with targeted analytics and consistent decisioning policies to achieve a measurably effective balance between fraud detection and positive identity proofing results. The inherent value of a risk-based approach to authentication lies in the ability to strike such a balance not only in a current environment, but as that environment shifts as do its underlying forces. The National Institute of Standards and Technology, in special publication 800-63, defines electronic authentication (E-authentication) as “the process of establishing confidence in user identities electronically presented to an information system”. Since, as stated in publication 800-63, “individuals are enrolled and undergo an identity proofing process in which their identity is bound to an authentication secret, called a token”, it is imperative that identity proofing is founded in an approach that generates confidence in the authentication process. Experian believes that a risk-based approach that can separate valid from invalid identities using a combination of data and proven quantitative techniques is best. As “individuals are remotely authenticated to systems and applications over an open network, using a token in an authentication protocol”, enrollment processes that drive ultimate provision of tokens must be implemented with an eye towards identity risk, and not simply a series of checks against one or more third party data assets. If the “keys to the kingdom” are housed in the ongoing use of tokens provided by Credentials Service Providers (CRA) and binding credentials to that token, trusted Registration Authorities (RA) must employ highly predictive identity proofing techniques designed to segment true, low-risk identities from identities that may have been manipulated, fabricated, or in true-form are subject to fraudulent use, abuse or victimization. Many compliance-oriented authentication requirements (ex. USA PATRIOT Act, FACTA Red Flags Rule) and resultant processes hinge upon identity element (ex. name, address, Social Security number, phone number) validation and verification checks. Without minimizing the importance of performing such checks, the purpose of a more risk-based approach to authentication is to leverage other data sources and quantitative techniques to further assess the probability of fraudulent behavior.
Experian recently contributed to a TSYS whitepaper focused on the various threats associated with first party fraud. I think the paper does a good job at summarizing the problem, and points out some very important strategies that can be employed to help both prevent first party fraud losses and detect those already in an institution’s active and collections account populations. I’d urge you to have a look at this paper as you begin asking the right questions within your own organization. Watch here The bad news is that first party fraud may currently account for up to 20 percent of credit charge-offs. The good news is that scoring models (using a combination of credit attributes and identity element analysis) targeted at various first party fraud schemes such as Bust Out, Never Pay, and even Synthetic Identity are quite effective in all phases of the customer lifecycle. Appropriate implementation of these models, usually involving coordinated decisioning strategies across both fraud and credit policies, can stem many losses either at account acquisition, or at least early enough in an account management stage, to substantially reduce average fraud balances. The key is to prevent these accounts from ending up in collections queues where they’ll never have any chance of actually being collected upon. A traditional customer information program and identity theft prevention program (associated, for example with the Red Flags Rule) will often fail to identify first party fraud, as these are founded in identity element verification and validation, checks that often ‘pass’ when applied to first party fraudsters.
By: Wendy Greenawalt Large financial institutions have acknowledged for some time that taking a more consumer-centric versus product-centric approach can be a successful strategy for an organization. However, implementing such a strategy can be difficult, because inherently organizations want to promote a specific product for one reason or another. With the current economic unrest, organizations are looking for ways to improve customer loyalty with their most profitable and lowest risk customers. They are also looking for ways to improve offers to consumers to provide segment of one decisioning, while satisfying organizational goals. Customer management, and specifically cross-sell or up-sell strategies, are a great example of where organizations can implement what I call “segment of one decisioning”. In essence, this refers to identifying the best possible decision or outcome for a specific consumer when given multiple offers, scenarios and objectives. Marketers strive to identify the best strategies to maximize decision-making, while minimizing costs. For many, this takes the form of models and complex strategy trees or spreadsheets to identify the ideal offering for a segment of consumers. While this approach is effective, algorithm-based decisioning processes exist that can help organizations identify the optimal decisioning strategies, while considering all possible options at a consumers level. By leveraging an optimization tool, organizations can expand the decision process by considering all variables and all alternatives to find the most cost effective, most-likely-to-be-successful strategies. By optimizing decisions, marketers can determine the ideal offer, while quantifying the ROI and adhering to budgetary or other campaign constraints. Many organizations are once again focusing on account growth and building strategies to implement in the near future. With the limited pool of qualified candidates and increased competition, it is more important than ever that each consumer offer be the best to increase response rates, achieve portfolio growth goals and build a profitable portfolio.
By: Kennis Wong In the last entry, I mentioned that consumers’ participation in protecting their own identity information is an important aspect of an identity theft prevention program to minimize fraud loss. Large financial institutions are starting to take charge in educating their customers, but others are having a hard time investing in such initiatives. I do understand that it is difficult to establish a direct linkage of revenue and positive return on investment for this type of activities. Business may view customer education of identity protection as a public service but not a necessity. After all, if my customer loses his identity information, it doesn’t necessarily mean that identity fraud will happen to my very own organization. But educating customers about identity protection and fraud trends can be a marketing tool and can increase customer loyalty, in additions to actual fraud prevention. Although consumers may not be aware of all the precautions they can take to protect their identity, undoubtedly identity theft is a hot topic in the media today. If there are two banks providing about the same service, but one of them goes an extra mile to provide me education on preventing identity theft, I would go with that bank. Also, as a financial institution, if my customers understand identity protection more, they would understand why I am putting some procedure in place and would be glad to comply with them. For example, they would be more patient when spending another minute in answering knowledge-based authentication questions, so that for their own protection, the bank can assure they are the true identity owners. Consumers can also actively monitor their credit report, whether through the bank or through other third party vendors. When consumers receive fraud alert from activities that could be a result of identity theft, they can actively contact the financial institutions about the situation. The sooner the identity fraud is discovered, the better off for both the consumers and the businesses.
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