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.        

By: Staci Baker As more people have become underwater on their mortgage, the decision to stay or not stay in their home has evolved to consider a number of influences that impact consumer credit decisions.  Research is revealing that much of an individual’s decision to meet his credit obligations is based on his trust in the economy, moral obligation, and his attitude about delinquency and the effect it will have on his credit score. Recent findings suggest that moral obligation keeps the majority of homeowners from walking away from their homes.  According to the 2009 Fannie Mae National Housing Survey (i) – “Nearly nine in ten Americans (88%), including seven in ten who are delinquent on their own mortgages, do not believe it is acceptable for people to stop making payments on an underwater mortgage, while 8% believe it is acceptable.”  It appears that there is a sense of owning up to one’s responsibilities; having signed a contract and the presumed stigma of walking away from that obligation. Maintaining strong creditworthiness by continuing to make payments on an underwater mortgage is motivation to sustain mortgage payments.  “Approximately 74% of homeowners believe it is very important to maintain good credit and this can be a factor in encouraging them not to walk away (ii).”  Once a homeowner defaults on their mortgage, their credit score can drop 150 to 250 points (iii), and the cost of credit in the future becomes much higher via increased interest rates once credit scores trend down. Although consumers expect to keep investing in the housing market (70% said buying a home continues to be one of the safest investments available (iv)) they will surely continue optimizing decisions that consider both the moral and credit implications of their decisions. i     December, 2009, Fannie Mae National Housing Survey ii  4/30/10, Financial Trust Index at 23% While Strategic Defaults Continue to Rise, The Chicago Booth/Kellogg School Financial Trust Index iii  http://www.creditcards.com/credit-card-news/mortgage-default-credit-scores-1270.php iv  December, 2009, Fannie Mae National Housing Survey