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I recently attended a conference where Credit Union managers spoke of the many changes facing their industry in the wake of the real estate crisis and economic decline that has impacted the US economy over the past couple of years. As these managers weighed in on the issues facing their businesses today, several themes began to emerge – tighter lending standards & risk management practices, increased regulatory scrutiny, and increased competition resulting in tighter margins for their portfolios. Across these issues, another major development was discussed – increased Credit Union mergers and acquisitions. As I considered the challenges facing these lenders, and the increase in M&A activity, it occurred to me that these lenders might have a common bond with an unexpected group –American family farms. Overall, Credit Unions are facing the challenge of adding significant fixed costs (more sophisticated lending platforms & risk management processes) all the while dealing with increased competition from lenders like large banks and captive automotive lenders. This challenge is not unlike the challenges faced by the family farm over the past few decades – small volume operators having to absorb significant fixed costs from innovation & increased corporate competition, without the benefit of scale to spread these costs over to maintain healthy lending margins. Without the benefit of scale, the family farm basically disappeared as large commercial operators acquired less-efficient (and less profitable) operators. Are Credit Unions entering into a similar period of competitive disadvantage? It appears that the Credit Union model will have to adjust in the very near future to remain viable. With high infrastructure expectations, many credit unions will have to develop improved decisioning strategies, become more proficient in assessing credit risk –implementing risk-based pricing models, and executing more efficient operational processes in order to sustain themselves when the challenges of regulation and infrastructure favor economies of scale. Otherwise, they are facing an uphill challenge, just as the family farm did (and does); to compete and survive in a market that favors the high-volume lender.

Well, in my last blog, I was half right and half wrong. I said that individual trade associations and advocacy groups would continue to seek relief from Red Flag Rules ‘coverage’ and resultant FTC enforcement. That was right. I also said that I thought the June 1 enforcement date would ‘stick’. That was wrong. Said FTC Chairman Jon Leibowitz, “Congress needs to fix the unintended consequences of the legislation establishing the Red Flag Rule – and to fix this problem quickly. We appreciate the efforts of Congressmen Barney Frank and John Adler for getting a clarifying measure passed in the House, and hope action in the Senate will be swift. As an agency we’re charged with enforcing the law, and endless extensions delay enforcement.” I think the key words here are ‘unintended consequences’. It seems to me that the unintended consequences of the Red Flag Rules reach far beyond just which industries are covered or not covered (healthcare, legal firms, retailers, etc). Certainly, the fight was always going to be brought on by non-financial institutions that generally may not have had a robust identity authentication practice in place as a general baseline practice. What continues to be lost on the FTC is the fact that here we are a few years down the road, and I still hear so much confusion from our clients as to what they have to do when a Red Flag compliance condition is detected. It’s easy to be critical in hindsight, yes, but I must argue that if a bit more collaboration with large institutions and authentication service providers in all markets had occurred, creating a more detailed and unambiguous Rule, we may have seen the original enforcement date (or at least one of the first or second postponement dates) ‘stick’. At the end of the day, the idea of mandating effective and market defined identity theft protection programs makes a lot of sense. A bit more intelligence gathering on the front end of drafting the Rule may, however, have saved time and energy in the long run. Here’s hoping that December 31st ‘sticks’…I’m done predicting.

By: Kristan Frend I recently gave a presentation on small business fraud at the annual National Association of Credit Managers (NACM) Credit Congress. Following the session, several B2B credit professionals shared recent fraud issues The attendees confirmed what we’ve been hearing from our customers: fraudsters are shifting from consumer to business/commercial fraud and they’re stepping up their game. One of the schemes mentioned by an attendee included fraudsters obtaining parcel provider’s tracking numbers to reroute shipments meant for their B2B customer. The perpetrator calls the business’s call center, impersonates the legitimate business customer to place an order, obtains the tracking number, and then calls back with the tracking number to request that the shipment be rerouted. Often the new shipping location is a residential address where an individual has been recruited for a work-at-home employment opportunity. The individual is instructed to sign for deliveries and then reship merchandise to a freight company within the country or directly to destinations outside the United States. The fraud is uncovered once the legitimate B2B customer receives an invoice for goods which they never ordered or received. I encourage you to take a look at your business’s policies and procedures on handling change of address shipment requests. What tools do you employ to verify the individual making the request? Are you verifying who the new address belongs to? You may also want to ask your parcel provider about account setting options available for when your employees submit reroute requests. While a shipping reroute request isn’t always indicative of fraud, I recommend you assess your fraud risk and consider whether your fraud-related business processes need refining. Keep an eye out here for postings on these topics: known fraud, bust out fraud, and how best to minimize fraud loss.
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