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By: Kari Michel Most lenders use a credit scoring model in their decision process for opening new accounts; however, between 35 and 50 million adults in the US may be considered unscoreable with traditional credit scoring models. That is equivalent to 18-to-25 percent of the adult population. Due to recent market conditions and shrinking qualified candidates, lenders have placed a renewed interest in assessing the risk of this under served population. Unscoreable consumers could be a pocket of missed opportunity for many lenders. To assess these consumers, lenders must have the ability to better distinguish between consumers with a clear track record of unfavorable credit behaviors versus those that are just beginning to develop their credit history and credit risk models. Unscoreable consumers can be divided into three populations: • Infrequent credit users: Consumers who have not been active on their accounts for the past six months, and who prefer to use non-traditional credit tools for their financial needs. • New entrants: Consumers who do not have at least one account with more than six months of activity; including young adults just entering the workforce, recently divorced or widowed individuals with little or no credit history in their name, newly arrived immigrants, or people who avoid the traditional system by choice. • Thin file consumers: Consumers who have less than three accounts and rarely utilize traditional credit and likely prefer using alternative credit tools and credit score trends. A study done by VantageScore® Solutions, LLC shows that a large percentage of the unscoreable population can be scored with the VantageScore® credit score* and a portion of these are credit-worthy (defined as the population of consumers who have a cumulative likelihood to become 90 days or more delinquent is less than 5 percent). The following is a high-level summary of the findings for consumers who had at least one trade: Lenders can review their credit decisioning process to determine if they have the tools in place to assess the risk of those unscoreable consumers. As with this population there is an opportunity for portfolio expansion as demonstrated by the VantageScore® study. *The VantageScore® credit score model is a generic credit scoring model introduced to meet the market demands for a highly predictive consumer score. Developed as a joint venture among the three major credit reporting companies (CRCs) – Equifax, Experian and TransUnion.

Well, here we are nearly at the beginning of November and the Red Flags Rule has been with us for nearly two years and the FTC’s November 1, 2009 enforcement date is upon us as well (I know I’ve said that before). There is little value in me chatting about the core requirements of the Red Flags Rule at this point. Instead, I’d like to shed some light on what we are seeing and hearing these days from our clients and industry experts related to this initiative: Red Flags Rule responses clients 1. Most clients have a solid written and operational Identity Theft Prevention Program in place that arguably meets their interpretation of the Red Flags Rule requirements. 2. Most clients have a solid written and operational Identity Theft Prevention Program in place that creates a boat-load of referrals due to the address mismatches generated in their process(es) and the requirement to do something with them. 3. Most clients are now focusing on ways in which to reduce the number of referrals generated and procedures to clear the remaining referrals via a cost-effective and automated manner…of course, while preventing fraud and staying compliant to Red Flags Rule. In 2008, a key focus at Experian was to help educate the market around the Red Flags Rule concepts and requirements. The concentration in 2009 has nearly fully shifted to assisting the market in creating risk-based authentication programs that leverage holistic views of a consumer, flexible tools that are pointed to a consumer based on that person’s authentication and risk profile. There is also an overall decisioning strategy that balances risk, compliance, and resource constraints. Spirit of Red Flags Rule The spirit of the Red Flags Rule is intended to ensure all covered institutions are employing basic identity theft prevention procedures (a pretty good idea). I believe most of these institutions (even those that had very robust programs in place years before the rule was introduced) can appreciate this requirement that brings all institutions up to speed. It is now, however, a matter of managing process within the realities of, and costs associated with, manpower, IT resources, and customer experience sensitivities.

Recent findings on vintage analysis Source: Experian-Oliver Wyman Market Intelligence Reports Analyzing recent vintage analysis provides insights gleaned from cursory review Analyzing recent trends from vintages published in the Experian-Oliver Wyman Market Intelligence Reports, there are numerous insights that can be gleaned from just a cursory review of the results. Mortgage vintage analysis trends As noted in an earlier posting, recent mortgage vintage analysis' show a broad range of behaviors between more recent vintages and older, more established vintages that were originated before the significant run-up of housing prices seen in the middle of the decade. The 30+ delinquency levels for mortgage vintages in 2005, 2006, and 2007 approach and in two cases exceed 10 percent of trades in the last 12 months of performance, and have spiked from historical trends, beginning almost immediately after origination. On the other end of the spectrum, the vintages from 2003 and 2002 have barely approached or exceeded 5 percent for the last 6 or 7 years. Bandcard vintage analysis trends As one would expect, the 30+ delinquency trends demonstrated within bankcard vintage analysis are vastly different from the trends of mortgage vintages. Firstly, card delinquencies show a clear seasonal trend, with a more consistent yearly pattern evident in all vintages, resulting from the revolving structure of the product. The most interesting trends within the card vintages do show that the more recent vintages, 2005 to 2008, display higher 30+ delinquency levels, especially the Q2 2007 vintage, which is far and away the underperformer of the group. Within each vintage pool, an analysis can extend into the risk distribution and details of the portfolio and further segment the pool by credit score, specifically the VantageScore® credit score. In other words, the loans in this pool are only for the most creditworthy customers at the time of origination. The noticeable trend is that while these consumers were largely resistant to deteriorating economic conditions, each vintage segment has seen a spike in the most recent 9-12 months. Given that these consumers tend to have the highest limits and lowest utilization of any VantageScore® credit score band, this trend encourages further account management consideration and raises flags about overall bankcard performance in coming months. Even a basic review of vintage analysis pools and the subsequent analysis opportunities that result from this data can be extremely useful. This vintage analysis can add a new perspective to risk management, supplementing more established analysis techniques, and further enhancing the ability to see the risk within the risk. Purchase a complete picture of consumer credit trends from Experian’s database of over 230 million consumers with the Market Intelligence Brief.
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