Regulatory Compliance
It’s Halloween time – time for trick or treating, costume parties and monsters lurking in the background. But this year, the monsters aren’t just in the background. They’re in your portfolio. This year, “Frankenstein” has another meaning. Much more ominous than the neighbor kid in the costume. “Frankenstein IDs” refer to synthetic identities — a type of fraud carried out by criminals that have created fictitious identities. Just as Dr. Frankenstein’s monster was stitched together from parts, synthetic IDs are stitched together pieces of mismatched identities — some fake, some real, some even deceased. It typically takes fraudsters 12 to 18 months to create and nurture a synthetic identity before it’s ready to "bust out" – the act of building a credit history with the intent of maxing out all available credit and eventually disappearing. That means fraudsters are investing money and time to build numerous tradelines, ensure these "fake" identities are in good credit standing, and ultimately steal the largest amount of money possible. “Wait Master, it might be dangerous . . . you go, first.” — Igor Synthetic identities are a notable challenge for many financial institutions and retail organizations. According to the recently released Federal Reserve Board White Paper, synthetic identity fraud accounts for roughly 20% of all credit losses, and cost U.S. businesses roughly $6 billion in 2016 with an estimated 41% growth over 2 years. 85-95% of applicants identified as potential synthetic are not even flagged by traditional fraud models. The Social Security Administration recently announced plans for the electronic Consent Based Social Security Number Verification service – pilot program scheduled for June 2020. This service is designed to bring efficiency to the process for verifying Social Security numbers directly with the government agency. Once available, this verification could be an important tool in the fight against the elusive “Frankenstein” identity monster. But with the Social Security Administration's pilot program not scheduled for launch until the middle of next year, how can financial institutions and other organizations bridge the gap and adequately prepare for a potential uptick in synthetic identity fraud attacks? It comes down to a multilayered approach that relies on advanced data, analytics, and technology — and focuses on identity. Any significant progress in making synthetic identities easier to detect could cost fraudsters significant time and money. Far too many financial institutions and other organizations depend solely on basic demographic information and snapshots in time to confirm the legitimacy of an identity. These organizations need to think beyond those capabilities. The real value of data in many cases lies between the data points. We have seen this with synthetic identity — where a seemingly legitimate identity only shows risk when we can analyze its connections and relationships to other individuals and characteristics. In addition to our High Risk Fraud Score, we now have a Synthetic Fraud Risk Level Indicator available on credit profiles. These advanced detection capabilities are delivered via the simplicity of a straightforward indicator returned on the credit profile which lenders can use to trigger additional identity verification processes. While there are programs and initiatives in the works to help financial institutions and other organizations combat synthetic identity fraud, it's important to keep in mind there's no silver bullet, or stake to the heart, to completely keep these Frankenstein IDs out. Oh, and don’t forget… “It’s pronounced ‘Fronkensteen.’ ” — Dr. Frankenstein
To provide consumers with clear-cut protections against disturbance by debt collectors, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) to implement the Fair Debt Collection Practices Act (FDCPA) earlier this year. Among many other things, the proposal would set strict limits on the number of calls debt collectors may place to reach consumers weekly and clarify requirements for consumer-facing debt collection disclosures. A bigger discussion Deliberation of the debt collection proposal was originally scheduled to begin on August 18, 2019. However, to allow commenters to further consider the issues raised in the NPRM and gather data, the comment period was extended by 20 days to September 18, 2019. It is currently still being debated, as many argue that the proposed rule does not account for modern consumer preferences and hinders the free flow of information used to help consumers access credit and services. The Association of Credit and Collection Professionals (ACA International) and US House lawmakers continue to challenge the proposal, stating that it doesn’t ensure that debt collectors’ calls to consumers are warranted, nor does it do enough to protect consumers’ privacy. Many consumer advocates have expressed doubts about how effective the proposed measures will be in protecting debtors from debt collector harassment and see the seven-calls-a-week limit on phone contact as being too high. In fact, it’s difficult to find a group of people in full support of the proposal, despite the CFPB stating that it will help clarify the FDCPA, protect lenders from litigation and bring consumer protection regulation into the 21st century. What does this mean? Although we don’t know when, or if, the proposed rule will go into effect, it’s important to prepare. According to the Federal Register, there are key ways that the new regulation would affect debt collection through the use of newer technologies, required disclosures and limited consumer contact. Not only will the proposed rules apply to debt collectors, but its provisions will also impact creditors and servicers, making it imperative for everyone in the financial services space to keep watch on the regulation’s status and carefully analyze its proposed rules. At Experian, our debt collection solutions automate and moderate dialogues and negotiations between consumers and collectors, making it easier for collection agencies to connect with consumers while staying compliant. Our best-in-class data and analytics will play a key role in helping you reach the right consumer, in the right place, at the right time. Learn more
Experian is excited to have been chosen as one of the first data and analytics companies that will enable access to Social Security Administration (SSA) data for the purposes of verifying identity against the Federal Agency’s records. The agency’s involvement in the wake of Congressional interest and successful legislation will create a seismic shift in the landscape of identity verification. Ultimately, the ability to leverage SSA data will reduce the impact of identity fraud and synthetic identity and put real dollars back into the pockets of people and businesses that absorb the costs of fraud today. As this era of government and private sector collaboration begins, many of our clients and partners are breathing a sigh of relief. We see this in a common question our customers ask every day, “Do I still need an analytical solution for synthetic ID now that eCBSV is on the horizon?” The common assumption is that help is on the way and this long tempest of rising losses and identity uncertainty is about to leave us. Or is it? We don’t believe it’s the end of the synthetic ID storm. This is the eye. Rather than basking in the calm light of this moment, we should be thinking ahead and assessing our vulnerabilities because the second half of this storm will be worse than the first. Consider this: The people who develop and exploit synthetic IDs are playing a long game. It takes time, research, planning and careful execution to create an identity that facilitates fraud. The bigger the investment, the bigger the spoils will be. Synthetic ID are being used to purchase luxury automobiles. They’re passing lender marketing criteria and being offered credit. The criminals have made their investment, and it’s unlikely they will walk away from it. So, what does SSA’s pending involvement mean to them? How will they prepare? These aren’t hard questions. They’ll do what you would do in the eye of a storm — maximize the value of the preparations that are in place. Gather what you can quickly and brace yourself for the uncertainty that’s coming. In short, there’s a rush to monetize synthetic IDs on the horizon, and this is no time to declare ourselves safe. It’s doubtful that the eCBSV process will be the silver bullet that ends synthetic ID fraud — and certainly not on day one. It’s more likely that the physical demands of the data exchange, volume constraints, response times and the actionability of the results will take time to optimize. In the meantime, the criminals aren’t going to sit by and watch as their schemes unravel and lose value. We should take some comfort that we’ve made it through the first half of the storm, but recognize and prepare for what still needs to be faced.
Earlier this year, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) to implement the Fair Debt Collection Practices Act (FDCPA). The proposal, which will go into deliberation in September and won't be finalized until after that date at the earliest, would provide consumers with clear-cut protections against disturbance by debt collectors and straightforward options to address or dispute debts. Additionally, the NPRM would set strict limits on the number of calls debt collectors may place to reach consumers weekly, as well as clarify how collectors may communicate lawfully using technologies developed after the FDCPA’s passage in 1977. So, what does this mean for collectors? The compliance conundrum is ever present, especially in the debt collection industry. Debt collectors are expected to continuously adapt to changing regulations, forcing them to spend time, energy and resources on maintaining compliance. As the most recent onslaught of developments and proposed new rules have been pushed out to the financial community, compliance professionals are once again working to implement changes. According to the Federal Register, here are some key ways the new regulation would affect debt collection: Limited to seven calls: Debt collectors would be limited to attempting to reach out to consumers by phone about a specific debt no more than seven times per week. Ability to unsubscribe: Consumers who do not wish to be contacted via newer technologies, including voicemails, emails and text messages must be given the option to opt-out of future communications. Use of newer technologies: Newer communication technologies, such as emails and text messages, may be used in debt collection, with certain limitations to protect consumer privacy. Required disclosures: Debt collectors will be obligated to send consumers a disclosure with certain information about the debt and related consumer protections. Limited contact: Consumers will be able to limit ways debt collectors contact them, for example at a specific telephone number, while they are at work or during certain hours. Now that you know the details, how can you prepare? At Experian, we understand the importance of an effective collections strategy. Our debt collection solutions automate and moderate dialogues and negotiations between consumers and collectors, making it easier for collection agencies to reach consumers while staying compliant. Powerful locating solution: Locate past-due consumers more accurately, efficiently and effectively. TrueTraceSM adds value to each contact by increasing your right-party contact rate. Exclusive contact information: Mitigate your compliance risk with a seamless and unparalleled solution. With Phone Number IDTM, you can identify who a phone is registered to, the phone type, carrier and the activation date. If you aren’t ready for the new CFPB regulation, what are you waiting for? Learn more Note: Click here for an update on the CFPB's proposal.
The fact that the last recession started right as smartphones were introduced to the world gives some perspective into how technology has changed over the past decade. Organizations need to leverage the same technological advancements, such as artificial intelligence and machine learning, to improve their collections strategies. These advanced analytics platforms and technologies can be used to gauge customer preferences, as well as automate the collections process. When faced with higher volumes of delinquent loans, some organizations rapidly hire inexperienced staff. With new analytical advancements, organizations can reduce overhead and maintain compliance through the collections process. Additionally, advanced analytics and technology can help manage customers throughout the customer life cycle. Let’s explore further: Why use advanced analytics in collections? Collections strategies demand diverse approaches, which is where analytics-based strategies and collections models come into play. As each customer and situation differs, machine learning techniques and constraint-based optimization can open doors for your organization. By rethinking collections outreach beyond static classifications (such as the stage of account delinquency) and instead prioritizing accounts most likely to respond to each collections treatment, you can create an improved collections experience. How does collections analytics empower your customers? Customer engagement, carefully considered, perhaps comprises the most critical aspect of a collections program—especially given historical perceptions of the collections process. Experian recently analyzed the impact of traditional collections methods and found that three percent of card portfolios closed their accounts after paying their balances in full. And 75 percent of those closures occurred shortly after the account became current. Under traditional methods, a bank may collect outstanding debt but will probably miss out on long-term customer loyalty and future revenue opportunities. Only effective technology, modeling and analytics can move us from a linear collections approach towards a more customer-focused treatment while controlling costs and meeting other business objectives. Advanced analytics and machine learning represent the most important advances in collections. Furthermore, powerful digital innovations such as better criteria for customer segmentation and more effective contact strategies can transform collections operations, while improving performance and raising customer service standards at a lower cost. Empowering consumers in a digital, safe and consumer-centric environment affects the complete collections agenda—beginning with prevention and management of bad debt and extending through internal and external account resolution. When should I get started? It’s never too early to assess and modernize technology within collections—as well as customer engagement strategies—to produce an efficient, innovative game plan. Smarter decisions lead to higher recovery rates, automation and self-service tools reduce costs and a more comprehensive customer view enhances relationships. An investment today can minimize the negative impacts of the delinquency challenges posed by a potential recession. Collections transformation has already begun, with organizations assembling data and developing algorithms to improve their existing collections processes. In advance of the next recession, two options present themselves: to scramble in a reactive manner or approach collections proactively. Which do you choose? Get started
Today, Experian and Oliver Wyman announced the launch of Ascend CECL ForecasterTM, a solution built to help financial institutions of all sizes more quickly and accurately forecast lifetime credit losses. The Financial Accounting Standards Board’s current expected credit loss (CECL) model has been a hot discussion topic throughout the financial services industry - first when it was announced (and considered one of the most significant accounting changes in decades), and most recently with the FASB’s delay for implementation for smaller lenders. As the compliance deadlines approach, Experian and Oliver Wyman have joined forces to help financial institutions adhere their loan portfolios to the new guidelines. Delivered through Experian’s Ascend Technology PlatformTM, Ascend CECL Forecaster is a new user-friendly, web-based application that combines Experian’s vast loan-level data and Premier AttributesSM, third-party macroeconomic data, valuation data and Oliver Wyman’s industry-leading CECL modeling methodology to accurately calculate potential losses over the life of a loan. “Ascend CECL Forecaster is a critical capability needed urgently by all lending and financial institutions,” said Ash Gupta, a Senior Advisor to Oliver Wyman and former Chief Risk Officer for American Express, in a press release. “The collaboration between Experian and Oliver Wyman allows a frictionless synthesis of industry data, capabilities and experience to serve customers in both first and second line of defense.” The premise behind the model, which will need access to more data than that used to calculate reserves under the incurred loss model, Allowance for Loan and Lease Losses (ALLL), is for financial institutions to estimate the expected loss over the life of a loan by using historical information, current conditions and reasonable forecasts. Built using advanced machine learning and statistical techniques, the web-based application maximizes the more than 15 years of historical credit data spanning previous economic cycles to help financial institutions gauge loan portfolio performance under various scenarios. Ascend CECL Forecaster does not require additional data nor does it require a secondary integration from the financial institution and enables organizations to more quickly test their portfolios under different economic factors. Moreover, financial institutions receive guidance from industry experts to assist with implementation and strategy. Additionally, Experian and Oliver Wyman will host a webinar to help financial institutions better understand and prepare for the upcoming CECL standards. Register today! Read the Press Release Register for Webinar
Have you seen the latest Telephone Consumer Protection Act (TCPA) class action lawsuit? TCPA litigations in the communications, energy and media industries are dominating the headlines, with companies paying up to millions of dollars in damages. Consumer disputes have increased more than 500 percent in the past five years, and regulations continue to tighten. Now more than ever, it’s crucial to build effective and cost-efficient contact strategies. But how? First, know your facts. Second, let us help. What is the TCPA? As you’re aware, TCPA aims to safeguard consumer privacy by regulating telephone solicitations and the use of prerecorded messages, auto-dialed calls, text messages and unsolicited faxes. The rule has been amended and more tightly defined over time. Why is TCPA compliance important? Businesses found guilty of violating TCPA regulations face steep penalties – fines range from $500 to $1500 per individual infraction! Companies have been delivered hefty penalties upwards of hundreds of thousands, and in some cases, millions of dollars. Many have questions and are seeking to understand how they might adjust their policies and call practices. How can you protect yourself? To help avoid risk for compliance violations, it’s integral to assess call strategies and put best practices in place to increase right-party contact rates. Strategies to gain compliance and mitigate risk include: Focus on right and wrong-party contact to improve customer service: Monitoring and verifying consumer contact information can seem like a tedious task, but with the right combination of data, including skip tracing data from consumer credit data, alternative and other exclusive data sources, past-due consumers can be located faster. Scrub often for updated or verified information: Phone numbers can continuously change, and they’re only one piece of a consumer’s contact information. Verifying contact information for TCPA compliance with a partner you can trust can help make data quality routine. Determine when and how often you dial cell phones: Or, given new considerations proposed by the CFPB, consider looking at collections via your consumers’ preferred communication channel – online vs. over the phone. Provide consumers user-friendly mechanisms to opt-out of receiving communications At Experian, our TCPA solutions can help you monitor and verify consumer contact information, locate past-due consumers, improve your right-party contact rates and automate your collections process. Get started
Financial institutions preparing for the launch of the Financial Accounting Standard Board’s (FASB) new current expected credit loss model, or CECL, may have concerns when it comes to preparedness, implications and overall impact. Gavin Harding, Experian’s Senior Business Consultant and Jose Tagunicar, Director of Product Management, tackled some of the tough questions posed by the new accounting standard. Check out what they had to say: Q: How can financial institutions begin the CECL transition process? JT: To prepare for the CECL transition process, companies should conduct an operational readiness review, which includes: Analyzing your data for existing gaps. Determining important milestones and preparing for implementation with a detailed roadmap. Running different loss methods to compare results. Once losses are calculated, you’ll want to select the best methodology based on your portfolio. Q: What is required to comply with CECL? GH: Complying with CECL may require financial institutions to gather, store and calculate more data than before. To satisfy CECL requirements, financial institutions will need to focus on end-to-end management, determine estimation approaches that will produce reasonable and supportable forecasts and automate their technology and platforms. Additionally, well-documented CECL estimations will require integrated workflows and incremental governance. Q: What should organizations look for in a partner that assists in measuring expected credit losses under CECL? GH: It’s expected that many financial institutions will use third-party vendors to help them implement CECL. Third-party solutions can help institutions prepare for the organization and operation implications by developing an effective data strategy plan and quantifying the impact of various forecasted conditions. The right third-party partner will deliver an integrated framework that empowers clients to optimize their data, enhance their modeling expertise and ensure policies and procedures supporting model governance are regulatory compliant. Q: What is CECL’s impact on financial institutions? How does the impact for credit unions/smaller lenders differ (if at all)? GH: CECL will have a significant effect on financial institutions’ accounting, modeling and forecasting. It also heavily impacts their allowance for credit losses and financial statements. Financial institutions must educate their investors and shareholders about how CECL-driven disclosure and reporting changes could potentially alter their bottom line. CECL’s requirements entail data that most credit unions and smaller lenders haven’t been actively storing and saving, leaving them with historical data that may not have been recorded or will be inaccessible when it’s needed for a CECL calculation. Q: How can Experian help with CECL compliance? JT: At Experian, we have one simple goal in mind when it comes to CECL compliance: how can we make it easier for our clients? Our Ascend CECL ForecasterTM, in partnership with Oliver Wyman, allows our clients to create CECL forecasts in a fraction of the time it normally takes, using a simple, configurable application that accurately predicts expected losses. The Ascend CECL Forecaster enables you to: Fulfill data requirements: We don’t ask you to gather, prepare or submit any data. The application is comprised of Experian’s extensive historical data, delivered via the Ascend Technology PlatformTM, economic data from Oxford Economics, as well as the auto and home valuation data needed to generate CECL forecasts for each unsecured and secured lending product in your portfolio. Leverage innovative technology: The application uses advanced machine learning models built on 15 years of industry-leading credit data using high-quality Oliver Wyman loan level models. Simplify processes: One of the biggest challenges our clients face is the amount of time and analytical effort it takes to create one CECL forecast, much less several that can be compared for optimal results. With the Ascend CECL Forecaster, creating a forecast is a simple process that can be delivered quickly and accurately. Q: What are immediate next steps? JT: As mentioned, complying with CECL may require you to gather, store and calculate more data than before. Therefore, it’s important that companies act now to better prepare. Immediate next steps include: Establishing your loss forecast methodology: CECL will require a new methodology, making it essential to take advantage of advanced statistical techniques and third-party solutions. Making additional reserves available: It’s imperative to understand how CECL impacts both revenue and profit. According to some estimates, banks will need to increase their reserves by up to 50% to comply with CECL requirements. Preparing your board and investors: Make sure key stakeholders are aware of the potential costs and profit impacts that these changes will have on your bottom line. Speak with an expert
What is CECL? CECL (Current Expected Credit Loss) is a new credit loss model, to be leveraged by financial institutions, that estimates the expected loss over the life of a loan by using historical information, current conditions and reasonable forecasts. According to AccountingToday, CECL is considered one of the most significant accounting changes in decades to affect entities that borrow and lend money. To comply with CECL by the assigned deadline, financial institutions will need to access much more data than they’re currently using to calculate their reserves under the incurred loss model, Allowance for Loan and Lease Losses (ALLL). How does it impact your business? CECL introduces uncertainty into accounting and growth calculations, as it represents a significant change in the way credit losses are currently estimated. The new standard allows financial institutions to calculate allowances in a variety of ways, including discounted cash flow, loss rates, roll-rates and probability of default analyses. “Large banks with historically good loss performance are projecting increased reserve requirements in the billions of dollars,” says Experian Advisory Services Senior Business Consultant, Gavin Harding. Here are a few changes that you should expect: Larger allowances will be required for most products As allowances will increase, pricing of the products will change to reflect higher capital cost Losses modeling will change, impacting both data collection and modeling methodology There will be a lower return on equity, especially in products with a longer life expectancy How can you prepare? “CECL compliance is a journey, rather than a destination,” says Gavin. “The key is to develop a thoughtful, data-driven approach that is tested and refined over time.” Financial institutions who start preparing for CECL now will ultimately set their organizations up for success. Here are a few ways to begin to assess your readiness: Create a roadmap and initiative prioritization plan Calculate the impact of CECL on your bottom line Run altered scenarios based on new lending policy and credit decision rules Understand the impact CECL will have on your profitability Evaluate current portfolios based on CECL methodology Run different loss methods and compare results Additionally, there is required data to capture, including quarterly or monthly loan-level account performance metrics, multiple year data based on loan product type and historical data for the life of the loan. How much time do you have? Like most accounting standards, CECL has different effective dates based on the type of reporting entity. Public business entities that file financial statements with the Security and Exchange Commission will have to comply by 2020, non-public entity banks must comply by 2022 and non-SEC registered companies have until 2023 to adopt the new standard. How can we help: Complying with CECL may require you to gather, store and calculate more data than before. Experian can help you comply with CECL guidelines including data needs, consulting and loan loss calculation. Experian industry experts will help update your current strategies and establish an appropriate timeline to meet compliance dates. Leveraging our best-in-class industry data, we will help you gain CECL compliance quickly and effectively, understand the impacts to your business and use these findings to improve overall profitability. Learn more
“Experian is transforming our business from a traditional credit bureau to a true technology and software provider,” said Craig Boundy, CEO of Experian, North America, as part of his opening remarks Monday morning to kick off the 2019 Experian Vision Conference. “We are committed to working as a force of good.” Covering the themes of financial inclusion, giving consumers control of their lives and better outcomes, a digital-first society, and the latest trends in fraud and security, Boundy addressed a crowd of over 850. Alex Lintner, Experian’s Group President, gave a quick history of the past 3,000 years, from the first credit card, to the addition of wheels to a suitcase, to the iPhone and artificial intelligence. “Innovation is not invention,” Lintner said. He gave the example of the iPhone and how a tear down analysis revealed there were no new elements; however, it was the translation of an idea into a good or service that benefited everyone (as the entire audience raised their hand when asked who had a smart phone). Lintner’s mainstage presentation also featured three live demos, including how the Ascend Technology Platform takes complex model building and outputs from days and weeks to a few clicks, to the incorporation of Small Business Financial Exchange (SBFE) data into the Ascend Analytical Sandbox (incorporating more than 17 years of small business tradeline data and 150 predictive attributes) and lastly, Experian Boost, which according to a live tracker, has boosted consumer credit scores by a total of 3.2 million points, as of this morning, since its launch eight weeks ago. Keynote Speaker: Gary D. Cohn Gary D. Cohn, Former Director of the U.S. National Economic Council, was Monday morning’s keynote speaker. He weighed in on the domestic and global economy, policy issues, financial institutions’ responsibilities and some of his predictions. Cohn brought attention to the ever-changing financial services space, including new forms of encryption and the world of biometric security, calling the financial services industry the “tip of the spear” when it comes to the digitization of the world. Session Highlights - Day 1 Machine Learning From the building blocks of neural networks to artificial intelligence, machine learning has been used in the areas of financial services that do not have adverse actions – think fraud, ID, collections. As we look to harness machine learning for models and other spaces (including adverse action), it’s important to delineate descriptive data (what’s happening now); predictive data (what’s happening in the future); prescriptive data (what am I going to do now); and cognitive data (are we asking the right question?). In addition, it’s necessary to address the five advanced analytic drivers including customer experience, cost, risk and loss, growth and compliance. Home Equity & Lending US macroeconomic trends show consumer confidence is still on an upward trend. While investor confidence is a little volatile, the GDP remains strong (though slightly slowing down) and unemployment is low and forecasted to remain low. Since 2006, the US hasn’t returned in the HELOC space. Mortgage and personal loans are up 20% and 13% respectively, while mortgages have dropped 1% and HELOCs have dropped 2%. With an estimated market potential of over $700 billion, HELOCs may be an untapped credit line given the strength of the economy. Identity Evolution From dumpster divers, aka pulling receipts out of dumpsters behind businesses, to today’s identity-based authentication, there’s been an evolution of how identity is defined as well as its corresponding risks. According to Experian’s Global Fraud & Identity Report, 74% of consumers value security as the most important part of the online experience (over convenience and personalization). However, 74% of consumers abandoned a shopping session that required too much information, and 72% of consumers said they were willing to share more data if it meant a seamless experience. What does this mean? Consumers want it all. Identity today now includes proxies and activity, which can also mean greater risk. Because of aggregators and other associated entities acting on a consumer’s behalf, there are lots of nuances that will need to be looked through. Consumer-Permissioned Data In order to be more consumer-centric, there are four levers through which consumers are given control: data accuracy, knowing their financial profile, the ability to improve their scores (via Experian BoostTM and UltraFICOTM) and protecting consumers when they permission access to their identity credentials. Using Experian Boost, consumers have seen an average increase of 13 points for consumers with positive changes. Additionally, using alternative credit data, financial institutions can score more people and score more accurately. One hundred million consumers could gain greater access to credit with consumer-permissioned data sources. --- Meanwhile, the tech showcase featured over 20 demos covering alternative data, digital credit marketing, consumer empowerment, fraud and identity, integrated decisioning and technology. More insights from Vision to come. Follow @ExperianVision and #ExperianVision on Twitter to see more of the action.
Although half of businesses globally report an increase in fraud management over the past 12 months, many still experience fraud losses and attacks. To help address these challenges, Experian held its first-ever Fintech Fraud & Identity Meetup on February 5 in San Francisco, Calif. The half-day event was aimed at offering insights on the main business drivers of fraud, market trends, challenges and technology advancements that impact identity management and fraud risk strategy operations. “We understand the digital landscape is changing – inevitably, with technology enhancements come increased fraud risk for businesses operating in the online space,” said Jon Bailey, Experian’s Vice President of Fintech. “Our focus today is on fraud and identity, and providing our fintech customers with the tools and insights needed to grow and thrive.” The meetup was attended by number of large fintech companies with services spanning across a broad spectrum of fintech offerings. To kick off the event, Tony Hadley, Experian’s Senior Vice President of Government & Regulatory Affairs, provided an update on the latest regulatory news and trends impacting data and the fintech space. Next followed a fraud and identity expert panel, which engaged seasoned professionals in an in-depth discussion around two main themes 1) fraud trends and risk mitigation; and 2) customer experience, convenience, and trust. Expert panelists included: David Britton, Experian’s Vice President of Industry Solutions; Travis Jarae, One World Identity’s Founder & CEO; George Kurtyka, Joust’s Co-Founder & COO; and Filip Verley, Airbnb’s Product Manager. “The pace of fraud is so fast, by the time companies implement solutions, the shelf-life may already be old,” Britton said. “That is the crux – how to stay ahead. The goal is to future-proof your fraud strategy and capabilities.” At the close of the expert panel, Kathleen Peters, Experian’s Senior Vice President Head of Fraud and Identity, demoed Experian’s CrossCore™ solution – the first smart, open, plug-and-play platform for fraud and identity services. Peters began by stating, “Fraud is constant. Over 60% of businesses report an increase in fraud-related losses over the past year, with the US leading the greatest level of concern. The best way to mitigate risk is to create a layered approach; that’s why Experian invented CrossCore.” With the sophistication of fraudsters, it’s no surprise that many businesses are not confident with the effectiveness of their fraud strategy. Learn more about how you can stay one step ahead of fraudsters and position yourself for success in the ever-changing fraud landscape; download Experian’s 2019 Global Identity and Fraud Report here. For an inside look at Experian’s Fintech Fraud & Identity Meetup, watch our video below.
2019 is here — with new technology, new regulations and new opportunities on the docket. What does that mean for the financial services space? Here are the five trends you should keep your eye on and how these affect your credit universe. 1. Credit access is at an all-time high With 121 million Americans categorized as credit-challenged (subprime scores and a thin or nonexistent credit file) and 45 million considered credit-invisible (no credit history), the credit access many consumers take for granted has appeared elusive to others. Until now. The recent launch of Experian BoostTM empowers consumers to improve their credit instantly using payment history from their utility and phone bills, giving them more control over their credit scores and making them more visible to lenders and financial institutions. This means more opportunities for more people. Coupled with alternative credit data, which includes alternative financial services data, rental payments, and full-file public records, lenders and financial institutions can see a whole new universe. In 2019, inclusion is key when it comes to universe expansion goals. Both alternative credit and consumer-permissioned data will continue to be an important part of the conversation. 2. Machine learning for the masses The financial services industry has long been notorious for being founded on arguably antiquated systems and steeped in compliance and regulations. But the industry’s recent speed of disruption, including drastic changes fueled by technology and innovation, may suggest a changing of the guard. Digital transformation is an industry hot topic, but defining what that is — and navigating legacy systems — can be challenging. Successfully integrating innovation is the convergence at the center of the Venn diagram of strategy, technology and operations. The key, according to Deloitte, is getting “a better handle on data to extract the greatest value from technology investments.” How do you get the most value? Risk managers need big data, machine learning and artificial intelligence strategies to deliver market insights and risk evaluation. Between the difficulty of leveraging data sets and significant investment in time and money, it’s impossible for many to justify. To combat this challenge, the availability and access to an analytical sandbox (which contains depersonalized consumer data and comparative industry intel) is crucial to better serve clients and act on opportunities in lenders’ credit universe and beyond. “Making information analysis easily accessible also creates distinct competitive advantages,” said Vijay Mehta, Chief Innovation Officer for Experian’s Consumer Information Services, in a recent article for BAI Banking Strategies. “Identifying shifts in markets, changes in regulations or unexpected demand allows for quick course corrections. Tightening the analytic life cycle permits organizations to reach new markets and quickly respond to competitor moves.” This year is about meaningful metrics for action, not just data visualization. 3. How to fit into the digital-first ecosystem With so many things available on demand, the need for instant gratification continues to skyrocket. It’s no secret that the financial services industry needs to compete for attention across consumers’ multiple screens and hours of screen time. What’s in the queue for 2019? Personalization, digitalization and monetization. Consumers’ top banking priorities include customized solutions, omnichannel experience improvement and enhancing the mobile channel (as in, can we “Amazonize” everything?). Financial services leaders’ priorities include some of the same things, such as enhancing the mobile channel and delivering options to customize consumer solutions (BAI Banking Strategies). From geolocation targeting to microinteractions in the user experience journey to leveraging new strategies and consumer data to send personalized credit offers, there’s no shortage of need for consumer hyper-relevance. 33 percent of consumers who abandon business relationships do so because personalization is lacking, according to Accenture data for The Financial Brand. This expectation spans all channels, emphasizing the need for a seamless experience across all devices. 4. Keeping fraudsters out Many IT professionals regard biometric authentication as the most secure authentication method currently available. We see this technology on our personal devices, and many companies have implemented it as well. Biometric hacking is among the predicted threats for 2019, according to Experian’s Data Breach Industry Forecast, released last month. “Sensors can be manipulated and spoofed or deteriorate with too much use. ... Expect hackers to take advantage of not only the flaws found in biometric authentication hardware and devices, but also the collection and storage of data,” according to the report. 5. Regulatory changes and continued trends Under the Trump Administration, the regulatory front has been relatively quiet. But according to the Wall Street Journal, as Democrats gain control of the House of Representatives, lawmakers may be setting their sights on the financial services industry — specifically on legislation in response to the credit data breach in 2017. The Democratic Party leadership has indicated that the House Financial Services Committee will be focused on protecting consumers and investors, preserving sector stability, and encouraging responsible innovation in financial technology, according to Deloitte. In other news, the focus on improving accuracy in data reporting, transparency for consumers in credit scoring and other automated decisions can be expected to continue. Consumer compliance, and specifically the fair and responsible treatment of consumers, will remain a top priority. For all your needs in 2019 and beyond, Experian has you covered. Learn more
Federal legislation makes verifying an individual’s identity by scanning identity documents during onboarding legal in all 50 states Originally posted on Mitek blog The Making Online Banking Initiation Legal and Easy (MOBILE) Act officially became law on May 24, 2018, authorizing a national standard for banks to scan and retain information from driver’s licenses and identity cards as part of a customer online onboarding process, via smartphone or website. This bill, which was proposed in 2017 with bipartisan support, allows financial institutions to fully deploy mobile technology that can make digital account openings across all states seamless and cost efficient. The MOBILE Act also stipulates that the digital image would be destroyed after account opening to further ensure customer data security. As an additional security measure, section 213 of the act mandates an update to the system to confirm matches of names to social security numbers. “The additional security this process could add for online account origination was a key selling point with the Equifax data breach fresh on everyone’s minds,” Scott Sargent, of counsel in the law firm Baker Donelson’s financial service practice, recently commented on AmericanBanker.com. Read the full article here. Though digital banking and an online onboarding process has already been a best practice for financial institutions in recent years, the MOBILE Act officially overrules any potential state legislation that, up to this point, has not recognized digital images of identity documents as valid. The MOBILE Act states: “This bill authorizes a financial institution to record personal information from a scan, copy, or image of an individual’s driver’s license or personal identification card and store the information electronically when an individual initiates an online request to open an account or obtain a financial product. The financial institution may use the information for the purpose of verifying the authenticity of the driver’s license or identification card, verifying the identity of the individual, or complying with legal requirements.” Why adopt online banking? The recently passed MOBILE Act is a boon for both financial institutions and end users. The legislation: Enables and encourages financial institutions to meet their digital transformation goals Makes the process safe with digital ID verification capabilities and other security measures Reduces time, manual Know Your Customer (KYC) duties and costs to financial institutions for onboarding new customers Provides the convenient, on-demand experience that customers want and expect The facts: 61% of people use their mobile phone to carry out banking activity.1 77% of Americans have smartphones.2 50 million consumers who are unbanked or underbanked use smartphones.3 The MOBILE Act doesn’t require any regulatory implementation. Banks can access this real-time electronic process directly or through vendors. Read all you need to know about the MOBILE Act here. Find out more about a better way to manage fraud and identity services. References 1Mobile Ecosystem Forum, MEF Mobile Money Report (https://mobileecosystemforum.com/mobile-money-report/), Feb. 5, 2018. 2Pew Research Center, Mobile Fact Sheet (http://www.pewinternet.org/fact-sheet/mobile/), Jan. 30, 2017. 3The Federal Reserve System, Consumers and Mobile Financial Services 2015 (https://www.federalreserve.gov/econresdata/consumers-and-mobile-financial-services-report-201503.pdf), March 2015.
Customer Identification Program (CIP) solution through CrossCore® Every day, I work closely with clients to reduce the negative side effects of fraud prevention. I hear the need for lower false-positive rates; maximum fraud detection in populations; and simple, streamlined verification processes. Lately, more conversations have turned toward ID verification needs for Customer Information Program (CIP) administration. As it turns out, barriers to growth, high customer friction and high costs dominate the CIP landscape. While the marketplace struggles to manage the impact of fraud prevention, CIP routinely disrupts more than 10 percent of new customer acquisitions. Internally at Experian, we talk about this as the biggest ID problem our customers aren’t solving. Think about this: The fight for business in the CIP space quickly turned to price, and price was defined by unit cost. But what’s the real cost? One of the dominant CIP solutions uses a series of hyperlinks to connect identity data. Every click is a new charge. Their website invites users to dig into the data — manually. Users keep digging, and they keep paying. And the challenges don’t stop there. Consider the data sources used for these solutions. The winners of the price fight built CIP solutions around credit bureau header data. What does that do for growth? If the identity wasn’t sufficiently verified when a credit report was pulled, does it make sense to go back to the same data source? Keep digging. Cha-ching, cha-ching. Right about now, you might be feeling like there’s some sleight of hand going on. The true cost of CIP administration is much more than a single unit price. It’s many units, manual effort, recycled data and frustrated customers — and it impacts far more clients than fraud prevention. CIP needs have moved far beyond the demand for a low-cost solution. We’re thrilled to be leading the move toward more robust data and decision capabilities to CIP through CrossCore®. With its open architecture and flexible decision structure, our CrossCore platform enables access to a diverse and robust set of data sources to meet these needs. CrossCore unites Experian data, client data and a growing list of available partner data to deliver an intelligent and cost-conscious approach to managing fraud and identity challenges. The next step will unify CIP administration, fraud analytics and a range of verification treatment options together on the CrossCore platform as well. Spoiler alert. We’ve already taken that step.
As more financial institutions express interest and leverage alternative credit data sources to decision and assess consumers, lenders want to be assured of how they can best utilize this data source and maintain compliance. Experian recently interviewed Philip Bohi, Vice President for Compliance Education for the American Financial Services Association (AFSA), to learn more about his perspective on this topic, as well as to gain insights on what lenders should consider as they dive into the world of alternative credit data. Alternative data continues to be a hot topic in the financial services space. How have you seen it evolve over the past few years? It’s hard to pinpoint where it began, but it has been interesting to observe how technology firms and people have changed our perceptions of the value and use of data in recent years. Earlier, a company’s data was just the information needed to conduct business. It seems like people are waking up to the realization that their business data can be useful internally, as well as to others. And we have come to understand how previously disregarded data can be profoundly valuable. These insights provide a lot of new opportunities, but also new questions. I would also say that the scope of alternative credit data use has changed. A few years ago, alternative credit data was a tool to largely address the thin- and no-file consumer. More recently, we’ve seen it can provide a lift across the credit spectrum. We recently conducted a survey with lenders and 23% of respondents cited “complying with laws and regulations” as the top barrier to utilizing alternative data. Why do you think this is the case? What are the top concerns you hear from lenders as it relates to compliance on this topic? The consumer finance industry is very focused on compliance, because failure to maintain compliance can kill a business, either directly through fines and expenses, or through reputation damage. Concerns about alternative data come from a lack of familiarity. There is uncertainty about acquiring the data, using the data, safeguarding the data, selling the data, etc. Companies want to feel confident that they know where the limits are in creating, acquiring, using, storing and selling data. Alternative data is a broad term. When it comes to utilizing it for making a credit decision, what types of alternative data can actually be used? Currently the scope is somewhat limited. I would describe the alternative data elements as being analogous to traditional credit data. Alternative data includes rent payments, utility payments, cell phone payments, bank deposits, and similar records. These provide important insights into whether a given consumer is keeping up with financial obligations. And most importantly, we are seeing that the particular types of obligations reflected in alternative data reflect the spending habits of people whose traditional credit files are thin or non-existent. This is a good thing, as alternative data captures consumers who are paying their bills consistently earlier than traditional data does. Serving those customers is a great opportunity. If a lender wants to begin utilizing alternative credit data, what must they know from a compliance standpoint? I would begin with considering what the lender’s goal is and letting that guide how it will explore using alternative data. For some companies, accessing credit scores that include some degree of alternative data along with traditional data elements is enough. Just doing that provides a good business benefit without introducing a lot of additional risk as compared to using traditional credit score information. If the company wants to start leveraging its own customer data for its own purposes, or making it available to third parties, that becomes complex very quickly. A company can find itself subject to all the regulatory burdens of a credit-reporting agency very quickly. In any case, the entire lifecycle of the data has to be considered, along with how the data will be protected when the data is “at rest,” “in use,” or “in transit.” Alternative data used for credit assessment should additionally be FCRA-compliant. How do you see alternative credit data evolving in the future? I cannot predict where it will go, but the unfettered potential is dizzying. Think about how DNA-based genealogy has taken off, telling folks they have family members they did not know and providing information to solve old crimes. I think we need to carefully balance personal privacy and prudent uses of customer data. There is also another issue with wide-ranging uses of new data. I contend it takes time to discern whether an element of data is accurately predictive. Consider for a moment a person’s utility bills. If electricity usage in a household goes down when the bills in the neighborhood are going up, what does that tell us? Does it mean the family is under some financial strain and using the air conditioning less? Or does it tell us they had solar panels installed? Or they’ve been on vacation? Figuring out what a particular piece of data means about someone’s circumstances can be difficult. About Philip Bohi Philip joined AFSA in 2017 as Vice President, Compliance Education. He is responsible for providing strategic direction and leadership for the Association’s compliance activities, including AFSA University, and is the staff liaison to the Operations and Regulatory Compliance Committee and Technology Task Forces. He brings significant consumer finance legal and compliance experience to AFSA, having served as in-house counsel at Toyota Motor Credit Corporation and Fannie Mae. At those companies, Philip worked closely with compliance staff supporting technology projects, legislative tracking, and vendor management. His private practice included work on manufactured housing, residential mortgage compliance, and consumer finance matters at McGlinchey Stafford, PLLC and Lotstein Buckman, LLP. He is a member of the Virginia State Bar and the District of Columbia Bar. Learn more about the array of alternative credit data sources available to financial institutions.
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