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Last Friday, I attended a private session on FinTech at the White House – alongside a few others in the financial services ecosystem – Founders, Investors, Academics, a handful of Financial institutions and Regulators. Titled “The White House FinTech Summit” – the intent was to promote a discussion, sans media, on what could be done better to progress innovation in financial services, as well as communicate the administration’s own perspective on topics such as Financial inclusion, Regulatory arbitrage, Cyber Security, and Big Data. I am only writing down what resonated most, with me – so this isn’t meant to be a complete account of the half day event. Startups and Regulation: The need for a radically simpler engagement model I wasn’t surprised that this view was articulated half an hour into the summit – by Bruce Wallace of SVB, on a panel hosted by Secretary Penny Pritzker of the US Department of Commerce. Asked what the Govt role in fostering an environment for innovation, should be: Bruce summarized it best (and I am paraphrasing): “A FinTech startup has only a limited amount of time and scope to focus on the myriad state and federal agencies and regulators on understanding and interpreting policy. We need a radically simpler and transparent engagement model.” On this topic of “what should we be doing more to encourage startups to come to US” I would have liked Stripe to chime in here, with what they are likely to have learned from launching Atlas – I call it “Company in a Box” – which is a suite of services including banking and payment processing to enable entrepreneurs to maintain a presence in the US and sell to the US consumer. Regulatory Sandbox to Test, Proves and if need be – Fail Unsurprisingly, the incumbents echoed much of the same view, and Adam Carson of Chase suggested that “the regulatory climate is making it hard for FIs to experiment, collaborate – and where applicable, fail quickly. And thus, we should be advocating for a sandbox of sorts – that allows institutions to not have to be burdened so much by regulation as they attempt to test and learn – before worrying about scale and burdensome regulation”. Adam is absolutely right in that consumers no longer compare their banking experience on Chase’s platform to that of Capital One or Citi or BofA – they compare those digital experiences to that on Facebook, Amazon, Google, Apple, and Uber. I have written before on the same topic (see below): “As banking moves from branch to app – from a wholly owned and curated experience inside a branch – TO – an app that vies for space in a “democratized” and crowded home screen, banks must realize that they no longer own the entire canvas. Instead they merely follow the design principles set by the most-used apps on our phones. I no longer compare my bank app with that of another bank, I compare it against the services I use often – Facebook, Twitter, Gmail, Apple Pay, Uber etc. And if who you compete with on this platform has been redrawn to include brands who have nothing to do with managing money – then you have to try as hard not to be boxed in as a bank. Having both the talent required to design these new experiences, and the capital to acquire them will only serve to further differentiate banks that have this focus as a priority vs those who will in the end get wrapped.” Risk of Algorithmic bias as FinTech ingests alternative data Representatives from a couple of agencies – were a bit more cautionary in their approach to the topic of FinTech, scaling distribution and the focus around Big data, with Urban affairs asking FinTech firms to be cognizant of algorithmic bias in their models – because the data that drives decisions could be slanted or skewed towards a particular demographic – and used civil rights as an example. Playing fast and loose with consumer data Anjan Mukherjee of Treasury focused on Cybersecurity – and Chris Carroll (from John Hopkins) warned of a potential “Asteroid impact” manifesting in a data breach involving one or more FinTech firms – which could cause an inexorable exodus of trust away from the upstarts towards the incumbents. I understand the sentiment, and we have had a couple of examples where a couple of the startups have invited criticism around data handling and security – and this topic invites further scrutiny in light of EU PSD2 as well as the banking incumbents clamping down on access to customer account data. There is much agreement that screen scraping and sharing customer credentials with personal finance apps and aggregators is inadvisable – but to not consider that these rather poor approaches emerged only in the absence of a genuine, bank approved framework or API, would be a missed opportunity to understand why these exist in the first place. We do need secure methods for consumers to transfer customer data to 3rd party platforms or aggregators to extract more value out of the interactions with their bank. And we need guidelines to make it easy and transparent – so that consumers can make an informed decision after having considered the apparent cost and benefits involved. I hope we will sort this out soon – between Banks, Startups, Consumer Advocates and Regulators – not just because a systems breach is inevitable that will sweep up millions of unsafely stored consumer banking credentials – but the opportunity to create standards, improve security and create a level playing field for all will be the only desirable outcome to discussions such as the one on last Friday. Much thanks to Adrienne Harris at the White House, for hosting this event and inviting us to join this debate.
Part four in our series on Insights from Vision 2016 fraud and identity track It was a true honor to present alongside Experian fraud consultant Chris Danese and Barbara Simcox of Turnkey Risk Solutions in the synthetic and first-party fraud session at Vision 2016. Chris and Barbara, two individuals who have been fighting fraud for more than 25 years, kicked off the session with their definition of first-party versus third-party fraud trends and shared an actual case study of a first-party fraud scheme. The combination of the qualitative case study overlaid with quantitative data mining and link analysis debunked many myths surrounding the identification of first-party fraud and emphasized best practices for confidently differentiating first-party, first-pay-default and synthetic fraud schemes. Following these two passionate fraud fighters was a bit intimidating, but I was excited to discuss the different attributes included in first-party fraud models and how they can be impacted by the types of data going into the specific model. There were two big “takeaways” from this session for me and many others in the room. First, it is essential to use the correct analytical tools to find and manage true first-party fraud risk successfully. Using a credit score to identify true fraud risk categorically underperforms. BustOut ScoreSM or other fraud risk scores have a much higher ability to assess true fraud risk. Second is the need to for a uniform first-party fraud bust-out definition so information can be better shared. By the end of the session, I was struck by how much diversity there is among institutions and their approach to combating fraud. From capturing losses to working cases, the approaches were as unique as the individuals in attendance This session was both educational and inspirational. I am optimistic about the future and look forward to seeing how our clients continue to fight first-party fraud.
On June 2, the Consumer Financial Protection Bureau (CFPB) proposed a rule aimed at “payday lending” that will apply to virtually all lenders, with request for comments by Sept. 14. Here is a summary of the basic provisions of the proposed rule. However, with comments, the proposal is more than 1,300 pages in length, and the proposed rule and examples are more than 200 pages long. It is necessary to review the details of the proposed rule to understand its potential impact on your products and processes fully. You may wish to review your current and future offerings with your institution’s counsel and compliance officer to determine the potential impact if major provisions of this proposed rule are finalized by the CFPB. Coverage The proposal generally would cover two categories of loans. First, the proposal generally would cover loans with a term of 45 days or less. Second, the proposal generally would cover loans with a term greater than 45 days, provided that they have an all-in annual percentage rate greater than 36 percent and either are repaid directly from the consumer’s account or income or are secured by the consumer’s vehicle. Ability to repay For both categories of covered loans, the proposal would identify it as an abusive and unfair practice for a lender to make a covered loan without reasonably determining that the consumer has the ability to repay the loan. Or if the lender does not determine if the consumer can make payments due, as well as meet major financial obligations and basic living expenses during and for 30 days after repayment. Lenders would be required to verify the amount of income that a consumer receives, after taxes, from employment, government benefits or other sources. In addition, lenders would be required to check a consumer’s credit report to verify the amount of outstanding loans and required payments. “Safe Harbor” The proposed rule would provide lenders with options to make covered loans without satisfying the ability-to-repay and payment notice requirements, if those loans meet certain conditions. The first option would be offering loans that generally meet the parameters of the National Credit Union Administration “payday alternative loans” program, where interest rates are capped at 28 percent and the application fee is no more than $20. The other option would be offering loans that are payable in roughly equal payments with terms not to exceed two years and with an all-in cost of 36 percent or less, not including a reasonable origination fee, so long as the lender’s projected default rate on these loans is 5 percent or less. The lender would have to refund the origination fees any year that the default rate exceeds 5 percent. Lenders would be limited as to how many of either type of loan they could make per consumer per year. Outstanding loans The proposal also would impose certain restrictions on making covered loans when a consumer has — or recently had — certain outstanding loans. These provisions are extensive and differ between short- and long-term loans. For example: Payday and single-payment auto title: If a borrower seeks to roll over a loan or returns within 30 days after paying off a previous short-term debt, the lender would be restricted from offering a similar loan. Lenders could only offer a similar short-term loan if a borrower demonstrated that their financial situation during the term of the new loan would be materially improved relative to what it was since the prior loan was made. The same test would apply if the consumer sought a third loan. Even if a borrower’s finances improved enough for a lender to justify making a second and third loan, loans would be capped at three in succession followed by a mandatory 30-day cooling-off period. High-cost installment loans: For consumers struggling to make payments under either a payday installment or auto title installment loan, lenders could not refinance the loan into a loan with similar payments. This is unless a borrower demonstrated that their financial situation during the term of the new loan would be materially improved relative to what it was during the prior 30 days. The lender could offer to refinance if that would result in substantially smaller payments or would substantially lower the total cost of the consumer’s credit. Payments Furthermore, it would be defined as an unfair and abusive practice to attempt to withdraw payment from a consumer’s account for a covered loan after two consecutive payment attempts have failed, unless the lender obtains the consumer’s new and specific authorization to make further withdrawals from the account. The proposal would require lenders to provide certain notices to the consumer before attempting to withdraw payment for a covered loan from the consumer’s account unless exempt under one of the “safe harbor” options. Registered information systems Finally, the proposed rule would require lenders to use credit reporting systems to report and obtain information about loans made under the full-payment test or the principal payoff option. These systems would be considered consumer reporting companies, subject to applicable federal laws and registered with the CFPB. Lenders would be required to report basic loan information and updates to that information. The proposed regulation may be found here.
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With the National Automobile Dealers Association (NADA) Show set to kickoff later this week, it seemed fitting to explore how the shifting dynamics of the used vehicle market might impact dealers and buyers over the coming year. Shedding light on some of the registration and finance trends, as well as purchasing behaviors, can help dealers and manufacturers stay ahead of the curve. And just like that, the Special Report: Automotive Consumer Trends Report was born. As I was sifting through the data, one of the trends that stood out to me was the neck-and-neck race between Millennials and Gen X for supremacy in the used vehicle market. Five years ago, in 2019, Millennials were responsible for 33.3% of used retail registrations, followed by Gen X (29.5%) and Baby Boomers (26.8%). Since then, Baby Boomers have gradually fallen off, and Gen X continues to close the already minuscule gap. Through October 2024, Millennials accounted for 31.6%, while Gen X accounted for 30.4%. But trends can turn on a dime if the last year offers any indication. Over the last rolling 12 months (October 2023-October 2024), Gen X (31.4%) accounted for the majority of used vehicle registrations compared to Millennials (30.9%). Of course, the data is still close, and what 2025 holds is anyone’s guess, but understanding even the smallest changes in market share and consumer purchasing behaviors can help dealers and manufacturers adapt and navigate the road ahead. Although there are similarities between Millennials and Gen X, there are drastic differences, including motivations and preferences. Dealers and manufacturers should engage them on a generational level. What are they buying? Some of the data might not come as a surprise but it’s a good reminder that consumers are in different phases of life, meaning priorities change. Over the last rolling 12 months, Millennials over-indexed on used vans, accounting for more than one-third of registrations. Meanwhile, Gen X over-indexed on used trucks, making up nearly one-third of registrations, and Gen Z over-indexed on cars (accounting for 17.1% of used car registrations compared to 14.6% of overall used vehicle registrations). This isn’t surprising. Many Millennials have young families and may need extra space and functionality, while Gen Xers might prefer the versatility of the pickup truck—the ability to use it for work and personal use. On the other hand, Gen Zers are still early in their careers and gravitate towards the affordability and efficiency of smaller cars. Interestingly, although used electric vehicles only make up a small portion of used retail registrations (less than 1%), Millennials made up nearly 40% over the last rolling 12 months, followed by Gen X (32.2%) and Baby Boomers (15.8%). The market at a bird’s eye view Pulling back a bit on the used vehicle landscape, over the last rolling 12 months, CUVs/SUVs (38.9%) and cars (36.6%) accounted for the majority of used retail registrations. And nearly nine-in-ten used registrations were non-luxury vehicles. What’s more, ICE vehicles made up 88.5% of used retail registrations over the same period, while alternative-fuel vehicles (not including BEVs) made up 10.7% and electric vehicles made up 0.8%. At the finance level, we’re seeing the market shift ever so slightly. Since the beginning of the pandemic, one of the constant narratives in the industry has been the rising cost of owning a vehicle, both new and used. And while the average loan amount for a used non-luxury vehicle has gone up over the past five years, we’re seeing a gradual decline since 2022. In 2019, the average loan amount was $22,636 and spiked $29,983 in 2022. In 2024, the average loan amount reached $28,895. Much of the decline in average loan amounts can be attributed to the resurgence of new vehicle inventory, which has resulted in lower used values. With new leasing climbing over the past several quarters, we may see more late-model used inventory hit the market in the next few years, which will most certainly impact used financing. The used market moving forward Relying on historical data and trends can help dealers and manufacturers prepare and navigate the road ahead. Used vehicles will always fit the need for shoppers looking for their next vehicle; understanding some market trends will help ensure dealers and manufacturers can be at the forefront of helping those shoppers. For more information on the Special Report: Automotive Consumer Trends Report, visit Experian booth #627 at the NADA Show in New Orleans, January 23-26.
The automotive industry is constantly changing. Shifting consumer demands and preferences, as well as dynamic economic factors, make the need for data-driven insights more important than ever. As we head into the National Automobile Dealers Association (NADA) Show this week, we wanted to explore some of the trends in the used vehicle market in our Special Report: State of the Automotive Finance Market Report. Packed with valuable insights and the latest trends, we’ll take a deep dive into the multi-faceted used vehicle market and better understand how consumers are financing used vehicles. 9+ model years grow Although late-model vehicles tend to represent much of the used vehicle finance market, we were surprised by the gradual growth of 9+ model year (MY) vehicles. In 2019, 9+MY vehicles accounted for 26.6% of the used vehicle sales. Since then, we’ve seen year-over-year growth, culminating with 9+MY vehicles making up a little more than 30% of used vehicle sales in 2024. Perhaps more interesting though, is who is financing these vehicles. Five years ago, prime and super prime borrowers represented 42.5% of 9+MY vehicles, however, in 2024, those consumers accounted for nearly 54% of 9+MY originations. Among the more popular 9+MY segments, CUVs and SUVs comprised 36.9% of sales in 2024, up from 35.2% in 2023, while cars went from 44.3% to 42.9% year-over-year and pickup trucks decreased from 15.9% to 15.6%. 2024 highlights by used vehicle age group To get a better sense of the overall used market, the segments were broken down into three age groups—9+MY, 4-8MY, and current +3MY—and to no surprise, the finance attributes vary widely. While we’ve seen the return of new vehicle inventory drive used vehicle values lower, it could be a sign that consumers are continuing to seek out affordable options that fit their lifestyle. In fact, the average loan amount for a 9+MY vehicle was $19,376 in 2024, compared to $24,198 for a vehicle between 4-8 years old and $32,381 for +3MY vehicle. Plus, more than 55% of 9+MY vehicles have monthly payments under $400. That’s not an insignificant number for people shopping with the monthly payment in mind. In 2024, the average monthly payment for a used vehicle that falls under current+3MY was $608. Meanwhile, 4-8MY vehicles came in at an average monthly payment of $498, and 9+MY vehicles had a $431 monthly payment. Taking a deeper dive into average loan amounts based on specific vehicle types—as of 2024, current +3MY cars came in at $28,721, followed by CUVs/SUVs ($31,589) and pickup trucks ($40,618). As for 4-8MY vehicles, cars came in with a loan amount of $22,013, CUVs/SUVs were at $23,133, and pickup trucks at $31,114. Used 9+MY cars had a loan amount of $19,506, CUVs/SUVs came in at $17,350, and pickup trucks at $22,369. With interest rates remaining top of mind for most consumers as we’ve seen them increase in recent years, understanding the growth from 2019-2024 can give a holistic picture of how the market has shifted over time. For instance, the average interest rate for a used current+3MY vehicle was 8.0% in 2019 and grew to 10.2% in 2024, the average rate for a 4-8MY vehicle went from 10.3% to 12.9%, and the average rate for a 9+MY vehicle increased from 11.4% to 13.8% in the same time frame. Looking ahead to the used vehicle market It’s important for automotive professionals to understand and leverage the data of the used market as it can provide valuable insights into trending consumer behavior and pricing patterns. While we don’t exactly know where the market will stand in a few years—adapting strategies based on historical data and anticipating shifts can help professionals better prepare for both challenges and opportunities in the future. As used vehicles remain a staple piece of the automotive industry, making informed decisions and optimizing inventory management will ensure agility as the market continues to shift. For more information, visit us at the Experian booth (#627) during the NADA Show in New Orleans from January 23-26.
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