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By: Tom Hannagan Apparently my last post on the role of risk management in the pricing of deposit services hit some nerve ends. That’s good. The industry needs its “nerve ends” tweaked after the dearth of effective risk management that contributed to the financial malaise of the last couple of years. Banks, or any business, can prosper by simply following their competitors’ marketing strategies and meeting or slightly undercutting their prices. The actions of competitors are an important piece of intelligence to consider, but not necessarily optimal for your bank to copy. One question is regarding the “how-to” behind risk-based pricing (RBP) of deposits. The answer has four parts. Let’s see. First, because of the importance and size of the deposit business (yes, it’s a line of business) as a funding source, one needs to isolate the interest rate risk. This is done by transfer pricing, or in a sense, crediting the deposit balances for their marginal value as an offset to borrowing funds. This transfer price has nothing to do with the earnings credit rate used in account analysis – that is a merchandising issue used to generate fee income. Fees, resulting from account analysis, when not waived, affect the profitability of deposit services, but are not a risk element. Two things are critical to the transfer of funding credit: 1) the assumptions regarding the duration, or reliability of the deposit balances and 2) the rate curve used to match the duration. Different types of deposit behave differently based on changes in rates paid. Checking account deposit funds tend to be very loyal or “sticky” – they don’t move around a lot (or easily) because of rate paid, if any. At the other extreme, time deposits tend to be very rate-sensitive and can move (in or out) for small incremental gains. Savings, money market and NOW accounts are in-between. Since deposits are an offset (ultimately) to marginal borrowing, just as loans might (ultimately) require marginal borrowing, we recommend using the same rate curve for both asset and liability transfer pricing. The money is the same thing on both sides of the balance sheet and the rate curve used to fund a loan or credit a deposit should be the same. We believe this will help, greatly, to isolate IRR. It is also seems more fair when explaining the concept to line management. Secondly, although there is essentially no credit risk associated with deposits, there is operational risk. Deposit make up most of the liability side of the balance sheet and therefore the lion’s share of institutional funding. Deposits are also a major source of operational expense. The mitigated operational risks such as physical security, backup processing arrangements, various kinds of insurance and catastrophe plans, are normal expenses of doing business and included in a bank’s financial statements. The costs need to be broken down by deposit category to get a picture of the risk-adjusted operating expenses. The third major consideration for analyzing risk-adjusted deposit profitability is its revenue contribution. Deposit-related fee income can be a very significant number and needs to be allocated to particular deposit category that generates this income. This is an important aspect of the return, along with the risk-adjusted funding value of the balances. It will vary substantially for various deposit types. Time deposits have essentially zero fee income, whereas checking accounts can produce significant revenues. The fourth major consideration is capital. There are unexpected losses associated with deposits that must be covered by risk-based capital – or equity. The unexpected losses include: unmitigated operational risks, any error in transfer pricing the market risk, and business or strategic risk. Although the unexpected losses associated with deposit products are substantially less than found in the lending products, they needs to be taken into account to have a fully risk-adjusted view. It is also necessary to be able to compare the risk-adjusted profit and profitability of such diverse services as found within banking. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization, on a risk-adjusted performance basis. Otherwise it is impossible to decide on the allocation of resources, including precious capital. Without this risk management view of deposits (just as with loans) it is impossible to price the services in a completely knowledgeable fashion. Good entity governance, asset and liability posturing, and competent line of business management, all require more and better risk-based profit considerations to be an important part of the intelligence used to optimally price deposits.

Meat and potatoes Data are the meat and potatoes of fraud detection. You can have the brightest and most capable statistical modeling team in the world. But if they have crappy data, they will build crappy models. Fraud prevention models, predictive scores, and decisioning strategies in general are only as good as the data upon which they are built. How do you measure data performance? If a key part of my fraud risk strategy deals with the ability to match a name with an address, for example, then I am going to be interested in overall coverage and match rate statistics. I will want to know basic metrics like how many records I have in my database with name and address populated. And how many addresses do I typically have for consumers? Just one, or many? I will want to know how often, on average, we are able to match a name with an address. It doesn’t do much good to tell you your name and address don’t match when, in reality, they do. With any fraud product, I will definitely want to know how often we can locate the consumer in the first place. If you send me a name, address, and social security number, what is the likelihood that I will be able to find that particular consumer in my database? This process of finding a consumer based on certain input data (such as name and address) is called pinning. If you have incomplete or stale data, your pin rate will undoubtedly suffer. And my fraud tool isn’t much good if I don’t recognize many of the people you are sending me. Data need to be fresh. Old and out-of-date information will hurt your strategies, often punishing good consumers. Let’s say I moved one year ago, but your address data are two-years old, what are the chances that you are going to be able to match my name and address? Stale data are yucky. Quality Data = WIN It is all too easy to focus on the more sexy aspects of fraud detection (such as predictive scoring, out of wallet questions, red flag rules, etc.) while ignoring the foundation upon which all of these strategies are built.

In a continuation of my previous entry, I’d like to take the concept of the first-mover and specifically discuss the relevance of this to the current bank card market. Here are some statistics to set the stage: • Q2 2009 bankcard origination levels are now at 54 percent of Q2 2008 levels • In Q2 2009, bankcard originations for subprime and deep-subprime were down 63 percent from Q2 2008 • New average limits for bank cards are down 19 percent in Q2 2009 from peak in Q3 2008 • Total unused limits continued to decline in Q3 2009, decreasing by $100 billion in Q3 2009 Clearly, the bank card market is experiencing a decline in credit supply, along with deterioration of credit performance and problematic delinquency trends, and yet in order to grow, lenders are currently determining the timing and manner in which to increase their presence in this market. In the following points, I’ll review just a few of the opportunities and risks inherent in each area that could dictate how this occurs. Lender chooses to be a first-mover: • Mining for gold – lenders currently have an opportunity to identify long-term profitable segments within larger segments of underserved consumers. Credit score trends show a number of lower-risk consumers falling to lower score tiers, and within this segment, there will be consumers who represent highly profitable relationships. Early movers have the opportunity to access these consumers with unrealized creditworthiness at their most receptive moment, and thus have the ability to achieve extraordinary profits in underserved segments. • Low acquisition costs – The lack of new credit flowing into the market would indicate a lack of competitiveness in the bank card acquisitions space. As such, a first-mover would likely incur lower acquisitions costs as consumers have fewer options and alternatives to consider. • Adverse selection – Given the high utilization rates of many consumers, lenders could face an abnormally high adverse selection issue, where a large number of the most risky consumers are likely to accept offers to access much needed credit – creating risk management issues. • Consumer loyalty – Whether through switching costs or loyalty incentives, first-movers have an opportunity to achieve retention benefits from the development of new client relationships in a vacant competitive space. Lender chooses to be a secondary or late-mover: • Reduced risk by allowing first-mover to experience growing pains before entry. The implementation of new acquisitions and risk-based pricing management techniques with new bank card legislation will not be perfected immediately. Second-movers will be able to read and react to the responses to first movers’ strategies (measuring delinquency levels in new subprime segments) and refine their pricing and policy approaches. • One of the most common first-mover advantages is the presence of switching costs by the customer. With minimal switching costs in place in the bank card industry, the ability for second-movers to deal with an incumbent is not one where switching costs are significant issues – second-movers would be able to steal market share with relative ease. • Cherry-picked opportunities – as noted above, many previously attractive consumers will have been engaged by the first-mover, challenging the second-mover to find remaining attractive segments within the market. For instance, economic deterioration has resulted in short-term joblessness for some consumers who might be strong credit risks, given the return of capacity to repay. Once these consumers are mined by the first-mover, the second-mover will likely incur greater costs to acquire these clients. Whether lenders choose to be first to market, or follow as a second-mover, there are profitable opportunities and risk management challenges associated with each strategy. Academics and bloggers continue to debate the merits of each, (1) but it is the ultimately lenders of today that will provide the proof. [1] http://www.fastcompany.com/magazine/38/cdu.html
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