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I’m working with many of our clients in reviewing their existing or evolving Red Flags Identity Theft Prevention Programs. While the majority of them appear to be buttoned up from the perspective of identifying covered accounts and applicable Red Flag conditions, as well as establishing detection methodologies, I often still see too much subjectivity in their response and reconciliation procedures. Here are a few reasons why the “response” portion of a strong Red Flags Identity Theft Prevention program needs to employ consistent and objective process, decisioning, and actions: 1. Inconsistent or subjectively varied responses and actions greatly reduce the ability to measure process effectiveness over time. It becomes increasingly difficult for retro-analysis to identify which processes and specific steps in those processes were successful in either positively or negatively reconciling potential fraudulent activity. Subsequently, it clouds any ability to make effective or necessary changes to specific activities that may not be working well. 2. Examiners may focus heavily on the response portion of your program. During operational side by sides, or even written program reviews, the less ambiguity and inconsistency identified or perceived, the better. A quick rule of thumb for any examination: preempt any questions with exhaustive information and clarity. Examiners that don’t need to ask many, or any, questions are happy examiners. 3. Objective and consistent process allows for more manageable staff training. It is much easier to educate your staff around a justified and effective uniform process than around intuitive and haphazard procedures and consumer interactions. It is tough to set expectations with your staff if there are gaping holes in the activities they are expected to execute. 4. Customer experience will certainly be more positive, and less of a worry for managers, as inequity of treatment is removed from the equation. It is better to have each customer progress through similar steps toward authentication than varied ones from the perspective of time, perception, effectiveness, and convenience. Now, certainly, a risk-based approach allows for varied treatment based on that risk. The point here is more toward the need to apply those varied techniques consistently. 5. Social engineering. Fraudsters are pretty good at figuring out if an operational process is open to interpretation and manipulation. They’ll continue to engage in a process with the goal of landing with the right associate who may be following a more easily penetrable fraud detection method. Bottom line: keep the walls around your business the same height throughout. Until next time, best of luck as you continue to develop and improve your Red Flags programs.
The pendulum has definitely swung back in favor of the credit discipline within financial institutions. The free wheeling credit standards of the past have proven once again to be problematic. So, things like cost of credit, credit risk modeling, and scoring models are back in fashion. The trouble that we have created is that, in an effort to promote greater emphasis on the sales role, we centralized the underwriting function. This centralization allowed the sales team to focus on business development and underwriting, on credit. The unintended result, however, is that we removed the urgent need to develop credit professionals. Instead, we pushed for greater efficiencies and productivity in underwriting — further stalling any consideration for the development of the credit professional. Now we find ourselves with more problem credits than we have seen in the past 20 years and the pool of true credit professionals is nearly gone. Once this current environment is corrected, let's be sure to keep balance in mind. Again, soundness, profitability and growth — in that order of priority.
As someone heavily engaged with the market and our clients discussing Red Flag Rule compliance, Red Flag guidelines, etc…this question has come up over and over again. You’d think by now I’d have a simple, clever, and strategically created product name to throw out there. Well, I don’t, and here’s why: we had Red Flag relevant products before Red Flags were in vogue. So, why didn’t we just rename them under the Red Flag brand? Because honestly, that would border on irresponsibility. Let me explain briefly… If you recall, the Red Flags Rule requires that covered institutions employ a written and operational Program that addresses the four mandatory elements of: • Identifying Red Flags applicable to covered accounts and incorporating them into the Program; • Detecting and evaluating the Red Flags included in the Program; • Responding to the Red Flags detected in a manner that is appropriate to the degree of risk they pose; and • Updating the Program to address changes in the risks to customers, and to the financial institution’s or creditor’s safety and soundness, from identity theft. You read in these requirements words like “applicable” and “appropriate” and “degree of risk.” You don’t read words like “use this tool” or “detect this specific set of conditions.” My point here is that, over the past year, we’ve been working with our clients to map in the “appropriate” and “applicable” set of products and services to allow them to become Red Flag compliant. These products and services range in data leverage and provision, predictive power, decisioning, and of course, cost. That is a good thing, as our clients require individualized tool sets and processes based on their serviced market, gathered information, consumer relationships, products offered, and risk associated with all of those factors. We don’t offer an unlimited or overwhelming number of Red Flag relevant products, but we do offer a diverse enough set that has afforded our clients an opportunity to select the best fit. Whether you choose to adopt Experian as your Red Flag partner or another service provider, keep in mind that one size does not fit all, and be wary of those claiming to be just that. As Red Flag examinations start rolling out in the coming months, there will be a focus on ensuring that your programs are comprehensive and effective. Examiners will be looking at your programs, not your service provider. Be sure to collaborate with your partners to meticulously apply the best solution. At Experian, we’ve taken this collaborative approach with each of our clients, and have employed products ranging from our robust Precise ID SM consumer authentication platform to our Fraud Shield SM risk warning product. Time spent up front in identifying your Red Flag requirements and working with your service provider to determine the best course of action will pay dividends down the road, and ensure you implement a compliant process once….not twice.
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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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