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Red Flags Rule I've heard more than one institution claim that they may limit and even reduce the identity elements (perhaps down to just name and address) that are captured during consumer applications or other transactions. Their rationale is that the fewer identity elements they request or require during these processes, the less information they will need to authenticate as part of their Red Flags Identity Theft Prevention Program. While this argument seems logical on the surface, I would suggest that if securely gathered/stored and appropriate to the nature of your business, additional data elements such as Social Security Number (SSN), date of birth and phone number can actually allow you to accomplish a few things to your benefit. 1. Analysis of our consumer authentication products shows that contributing SSN, date of birth, and phone (in addition to name and address) to an authentication process, will actually improve your ability to positively authenticate a consumer via an overall risk-based strategy. 2. The use of additional data elements, such as the phone number, can unlock additional data sources for use in verifying not only that phone number, but the inquiry name and address as well. 3. Just because you don't capture certain identity elements, doesn't mean the risk goes away. In providing additional identity elements for authentication, you can gain a more holistic view of a consumer – be that good, bad or ugly. It’s better to figure this out up front versus down the road when bills go unpaid and the bad guys scatter.

By: Prince Varma Hello. My name is Prince Varma and I’ve spent the better part of the last 16 years helping financial institutions (FI) successfully improve their in business development, portfolio growth and client relationship management practices. So, since the focus of this blog is to speak to readers about risk management, many of you are probably wondering what a “sales and business development” guy is doing writing a piece related to mitigating and managing risk? Great question! The simple fact is that the traditional or prevailing sentiment or definition related to risk management – mitigating credit risk — is incomplete. A more accurate and comprehensive approach would be to recognize, acknowledge and address that “risk” cuts across the entire client relationship spectrum of: client penetration/growth; client retention; and client credit risk mitigation. How do penetration and retention count as “risk factors”? (this is where the sales guy stuff comes in) From a penetration perspective, the failure to recognize potential opportunities either within the existing client base or in the operating market, introduces revenue growth risk (meaning we aren’t keeping our eye on the top line). Ultimately it impacts the FI’s ability to add assets (either deposits or loans) and also has a direct affect on efficiency and deposit to loan ratios. From a retention perspective, the risk is even more obvious. Our most valued clients are the ones that we must continuously engage in a proactive manner. Let’s face it. In even the smallest markets, there are no less than four to six other institutions waiting to jump on your client in the event that you grow complacent. There is a huge difference between selection and satisfaction. And, if we aren’t focused on keeping a client after securing them, our net portfolio growth targets will be impossible to achieve. Considering the current market environment, now more than ever, effectively managing these three elements of “risk/exposure to the FI” is crucial to an institutions success both practically and pragmatically. Everyone internally at the bank is focused on the “credit risk mitigation” piece. The conversations that are occurring outside of the bank’s walls however are focused on the “L” word or liquidity and getting credit flowing again. How many times have we read or more frankly been beaten with this comment from business owners “…there’s no one making loans anymore…” or “…its impossible to get credit…?” That should be read as … penetration and retention Striking a balance between effective and appropriate credit risk exposure and deepening or growing the portfolio has been a challenge facing those of us in the front office for as long as I can remember. The “sales revolution” is effectively over. We’ve learned the critical lesson that we need to evolve beyond being strictly a credit officer (you did learn that right??!!). And, you didn’t/shouldn’t become a “banking products generalist” with no analytical depth. Knowing all this, it is important that we return to the guiding principles of effective lending which include: – evaluating the scope of the opportunity; – isolating the risk and identifying a reasonable and realistic recovery/mitigation remedy; – determining what other alternatives the borrower might be considering; and – being willing to let the “bad deals” walk. In subsequent blogs, I’ll provide you with specific tactics aimed at optimizing penetration and retention efforts and implementing effective and practical client management strategies. After all what would you expect from a business development guy…

When you begin thinking about financial risk management, you must begin with a vision for your loan portfolio and the similarity of a loan portfolio to that of an investment portfolio. Now that you have that vision in place, we can focus on the overall strategy to achieve that vision. A valuable first step in loan portfolio monitoring is to establish a targeted value by a certain time (say, our targeted retirement age). Similarly, it’s important that we establish our vision for the loan portfolio regarding overall diversification, return and the management of risk levels. The next step is to create a strategy to achieve the targeted state. By focusing on the gaps between our current state and the vision state we have created, we can develop an action plan for achieving the future/vision state. I am going to introduce some rather unique ideas here. Consider which of your portfolio segments are overweight? One that comes to mind would be the commercial real estate portfolio. The binge that has taken place over the past five plus years has resulted in an unhealthy concentration of loans in the commercial real estate segment. In this one area alone, we will face the greatest challenge of right-sizing our portfolio mix and achieving the appropriate risk model per our vision. We have to assess our overall credit risk in the portfolios next. For small business and consumer portfolios, this is relatively easy using the various credit scores that are available to assess the current risk. For the larger commercial and industrial portfolios and the commercial real estate portfolios, we must employ some more manual processes to assess risk. Unfortunately, we have to perform appropriate risk assessments (current up-to-date risk assessments) in order to move on to the next stage of this overall process (which is to execute on the strategy). Once we have the dollar amounts of either growth or divestiture in various portfolio segments, we can employ the risk assessment to determine the appropriate execution of either growth or divestiture.
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