Back during World War I, the concept of “triage” was first introduced to the battlefield.  Faced with massive casualties and limited medical resources, a system was developed to identify and select those who most needed treatment and who would best respond to treatment.  Some casualties were tagged as terminal and received no aid; others with minimal injuries were also passed over.  Instead, medical staff focused their attentions on those who required their services in order to be saved.  These were the ones who needed and would respond to appropriate treatment. Our clients realize that the collections battlefield of today requires a similar approach.  They have limited resources to face this mounting wave of delinquencies and charge offs.  They also realize that they can’t throw bodies at this problem. They need to work smarter and use data and decisioning more effectively to help them survive this battle.Some accounts will never “cure” no matter what you do.  Others will self-cure with minimal or no active effort. Taking the right actions on the right accounts, with the right resources, at the right time is best accomplished with advanced segmentation that employs behavioral scoring, bureau-based scores and other relevant account data. The actual data and scores that should be used depend on the situation and account status, and there is no one-size-fits-all approach.Future related articles will dive deeper into the various segmentation approach options and explain how advanced decisioning provides additional benefit over the score-only methods. 

Here are a few more frequently asked questions. 1. Am I a “creditor” under the rule? The term “creditor” has the same meaning as under the Equal Credit Opportunity Act (ECOA) and is defined as a person who regularly participates in credit decisions, including, for example, a mortgage broker, a person who arranges credit or a servicer of loans who participates in “workout” decisions. The term “credit” is defined, as in the ECOA, as the right granted by a creditor to defer payment for goods or services. It is important to note that commercial, as well as consumer, credit accounts may be covered by the Rule. 2. We are an insurance company that uses credit reports to underwrite insurance. Does the Red Flags Rule apply to us? The Red Flag Rule applies to creditors and depository institutions and should not apply to an insurer when engaged in activities related to insurance underwriting. To the extent that you extend credit, however, you may be covered. For example, you may wish to examine whether you permit consumers to finance their premiums; whether you extend credit to vendors, independent agents or other business partners; or whether you extend credit in connection with your investment activities, including real-estate investments. 3. I am an auto dealer. Does the rule apply to me? If the business extends auto credit to consumers or arranges auto credit for consumers, the Red Flag guidelines may apply.  

By: Tom Hannagan Part 3 I believe it is quite important to compare your bank or your investment plans in a financial institution to the results of peer group averages. Not all banks are the same, believe it or not. In this column, we use the averages. Again, look for the differences in your target institution. About half of them beat certain performance numbers, while the other half are naturally worse. It can tell a useful story. This continues the updated review of results from the Uniform Bank Performance Reports (UBPR), courtesy of the FDIC, for 2008. The UBPR is based on the quarterly required Call Reports submitted by insured banks. The FDIC compiles peer averages for various bank size groupings. Here are the findings for the two largest groups that cover 494 reporting banks. I wanted to see how the various profit performance components compare to the costs of credit risk discussed in my previous post. It is even more apparent than it was in early 2008 that banks still have a ways to go to be fully pricing loans for both expected and unexpected risk. Peer Group 1 (PG1) is made up of the largest 189 reporting banks or those with over $3 billion in average total assets for 2008. Interest income was 5.25 percent of average total assets for the period. This is down, as we might expect, based on last year’s decline in the general level of interest rates from 6.16 percent in 2007. Net Interest Expense was also down from 2.98 percent in 2007 to 2.06 percent average for the year. Net Interest Margin, the difference between the two metrics, was down from 3.16 percent in 2007 to 3.11 percent as a percentage of total assets. It should be noted that Net Interest Margins have been in a steady, chronic decline for at least 10 years, with a torturous regular drop of 2 to 5 basis points per annum in recent years. Last year’s drop of five basis points is in line with that progression and it does add to continuing difficulty in generating bottom-line profits. To find out a bit more about why margins dropped, especially in light of the steady increase in lending over the same past decade, we looked first at loan pricing yields. For PG1 these averaged 6.12 percent for 2008, down (again, expectedly) from 7.32 percent in 2007. This is a drop of 120 basis points or a decline of 16 percent. Meanwhile, rates paid on interest-earning deposits dropped from 3.41 percent in 2007 to 2.39 percent in 2008. This 102 basis point decline represents a 30 percent lower interest expense on interest-bearing deposits. Based only on these two metrics, it seems like margins should have improved and not declined for these banks. Check my next blog for more on the reasons for Peer Group 1’s drop in margins and an analysis of the fee income and operating expenses for these institutions.