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With the Oct. 3, 2016 compliance date upon us, many lenders continue to debate how they would like to solve for the Military Lending Act (MLA). With new enhancements, more protections have been granted to members of the military and their dependents when it comes to “consumer credit” products, specifically around the 36% cap on the MAPR. The key then becomes how to identify these individuals. At origination, how can the lender know if an individual is a member of the military, or a service member’s dependent? The answer, of course, lies in verification. Under the new Department of Defense (DOD) rule, lenders will have to check each credit applicant to confirm that they are not a service member, spouse, or the dependent of a service member. The final rule includes a “safe harbor” from liability for lenders who verify the MLA status of a consumer through a nationwide Credit Reporting Agency (CRA) or the DOD’s own database, known as the DMDC. Obviously, lenders will want to have this “safe harbor,” so the question becomes do you opt for the direct or indirect solution? The direct solution is to have the lender access the DMDC on their own. With this option, expected turnaround time is 24 hours for batch searches. The DMDC expects the volume of searches to their servers to increase from 220 million a week to 1.9 billion a week. For some, this feels like a more manual process, but it can be done. The indirect solution involves the CRA accessing the DMDC data on the lender’s behalf. In Experian’s case, this would translate into lenders seeing the MLA indicator on the credit report at point of origination or making a call out for just the MLA indicator. The process is integrated into the credit-pull cycle, so no manual effort is required on the lender’s end. MLA status is simply flagged. The rule also permits the consumer report to be obtained from a reseller that obtains such a report from a nationwide consumer reporting agency. Required data to perform a search includes full legal name, address, social security number and date of birth. This applies to both the credit report add-on and Experian’s standalone solutions. If any of this data is missing from the inquiry, Experian is unable to perform the MLA search. Credit card lenders have until Oct. 3, 2017 to adhere to the new standards, but all other applicable lenders must act now and build out their compliance standards and solutions. Direct or indirect? That is the question. To learn more about MLA or how Experian can help, visit our dedicated-MLA site.

Miami ranked as an overall top city for both shipping and billing e-commerce fraud Houston, Texas is the top ZIP Code for billing fraud and Eudora, Kansas ranked as top ZIP Code for shipping fraud The question of whether we’re in Kansas anymore is appropriate with the latest release of Experian® fraud attack data from across the United States. Eudora, Kan., is home to the highest e-commerce billing fraud ZIP CodeTM. Accounting for 5 percent of the total billing fraud so far in 2016, the town is among the top 25 riskiest ZIPTM codes, illustrating that fraud is not confined to larger cities. Download Experian’s bi-annual 2016 Top 100 riskiest billing ZIPTM codes rankings Experian analyzed millions of e-commerce transactions from the first six months of 2016 to identify the latest fraud attack rates for shipping and billing locations across the United States. Fraud attack rates are calculated using bad transactions in relation to the total number of transactions. Billing fraud rates are associated with the address of the purchaser, typically the fraud victims. Shipping fraud rates are associated with the address where purchased goods are sent. The one-year anniversary of the EMV chip technology rollout for consumers and merchants in the United States is approaching. The rollout utilizes chip technology on credit cards to protect in-store payments making it harder to counterfeit cards, and helping eliminate in-store fraud. However, the 2016 e-commerce fraud attack rates appear to be at least 15 percent higher than last year’s total. This suggests that card-not-present fraud is increasing as e-commerce fraud is often an indicator that other fraud activities have already happened — a credit card has been stolen, identity fraud has occurred or personal credentials have been compromised. The increase in e-commerce fraud is not surprising as e-commerce sales in the U.S. during the second quarter of 2016 increased nearly 16 percent year-over-year (YoY) according to the U.S. Department of Commerce. This was the greatest YoY increase since Q3 2014. At the same time, the Federal Trade Commission stated earlier this year that credit card fraud complaints had the highest reported numbers in 10 years, with a 41 percent increase in 2015 versus 2014. “Fraudsters continue to exploit new vulnerabilities, and perpetrate card-not-present fraud against businesses using stolen consumer identity and payment data,” said Adam Fingersh, Experian general manager and senior vice president of Fraud and Identity Solutions. “This reinforces the need for aggressive fraud prevention strategies and adoption of open technology platforms to prepare for the latest emerging cyber security threats. Fraudsters have what they need to quickly capitalize on compromised data, so businesses need to be prepared.” According to Experian’s rankings of top 100 riskiest billing ZIP codes , e-commerce fraud attack rates for the first half of 2016 show: 44% of e-commerce billing fraud came from three states among the top 100 riskiest billing fraud ZIP codes – Florida, California and New York – based on the sum of fraud attacks. Florida is the top-ranked state for billing fraud, with Miami home to 12 of the riskiest ZIP codes. New York ranked second, with Brooklyn home to six of the riskiest ZIP codes. Houston, Texas, (77036) has the riskiest ZIP Code for billing fraud as ranked by fraud attack rate. Eudora, Kan. (66025) has the next riskiest ZIP Code for billing fraud as ranked by fraud attack rate, followed by two ZIP codes in Miami (33192 and 33166) and one in Homer, Alaska (99603). 52% of e-commerce shipping fraud came from three states among the top 100 riskiest shipping fraud zip codes – Florida, New York, and California – based on the sum of attacks. Florida is home to 26 of the riskiest 100 shipping fraud ZIP codes, with 17 from Miami. Eudora, Kan., has the overall riskiest shipping ZIP Code (66025 as ranked by fraud attack rate. The next four riskiest shipping ZIP codes as ranked by fraud attack rate are located in Miami (33195, 33192 and 33116) and Nettleton, Miss. (38858). Many of the higher-risk ZIP codes and cities are located near a large port-of-entry city or airport, making them ideal locations for reshipping fraudulent goods. This includes Miami, Houston, New York City, and Los Angeles, perhaps allowing criminals to move stolen goods more effectively. All those cities are ranked among the riskiest cities for both measures of fraud attacks. Download the 2016 Experian top 100 fraud attack rate ZIP Code rankings.

In this age of content and increasing financial education available to all, most entities are familiar with credit bureaus, including Experian. They are known for housing enormous amounts of data, delivering credit scores and helping businesses decision on credit. On the consumer side, there are certainly myths about credit scores and the credit report. But myths exist among businesses as well, especially as it pertains to the topic of reporting credit data. How does it work? Who’s responsible? Does reporting matter if you’re a small lender? Let’s tackle three of the most common myths surrounding credit reporting and shine a light on how it really is essential in creating a healthy credit ecosystem. Myth No. 1: Reporting to one bureau is good enough. Well, reporting to one bureau is definitely better than reporting to none, but without reporting to all three bureaus, there could be gaps in a consumer’s profile. Why? When a lender pulls a consumer’s profile to evaluate it for extending additional credit, they ideally would like to see a borrower’s complete credit history. So, if one of their existing trades is not being reported to one bureau, and the lender makes a credit pull from a different bureau to use for evaluation purposes, no knowledge of that trade exists. In cases like these, credit grantors may offer credit to your customer, not knowing the customer already has an obligation to you. This may result in your customer getting over-extended and negatively impacting their ability to pay you. On the other side, in the cases of a thin-file consumer, not having that comprehensive snapshot of all trades could mean they continue to look “thin” to other lenders. The best thing you can do for a consumer is report to all three bureaus, making their profile as robust as it can be, so lenders have the insights they need to make informed credit offers and decisions. Some believe the bureaus are regional, meaning each covers a certain part of the country, but this is false. Each of the bureaus are national and lenders can report to any and all. Myth No. 2: Reporting credit data is hard. Yes, accurate and timely data reporting requires a few steps, but after you get familiar with Metro 2, the industry standard format for consumer data reporting, choose a strategy, and register for e-Oscar, the process is set. The key is to do some testing, and also ensure the data you pass is accurate. Myth No. 3: Reporting credit data is a responsibility for the big institutions –not smaller lenders and companies. For all lenders, credit bureau data is vitally important in making informed risk determinations for consumer and small business loans. Large financial institutions have been contributing to the ecosystem forever. Many smaller regional banks and credit unions have reported consistently as well. But just think how much stronger the consumer credit profile would be if all lenders, utility companies and telecom businesses reported? Then you would get a true, complete view into the credit universe, and consumers benefit by having the most comprehensive profile — Bottom line is that when comprehensive data on consumer credit histories is readily available, it’s a good thing for consumers and lenders. And the truth is all businesses – big and small – can make this a reality.
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