Tag: regulatory compliance
Since 2002, lenders have been aware of the importance of Know Your Customer (KYC) and the associated Customer Identification Program (CIP) requirements. As COVID-19 has changed procedures and priorities for businesses and consumers across the board, it’s more important than ever for institutions to ensure their CIP process includes ongoing monitoring of identity risk. What is CIP? Standard KYC programs include a Customer Identification Program to verify and validate identities along with due diligence to assess the risks associated with each identity. CIP defines the process by which a business collects data to establish a reasonable belief that the identity is valid, and that the individual is eligible to participate in our financial system. While this process works in conjunction with other fraud mitigation tactics, they serve different purposes. A good CIP program emphasizes the customer experience, regulatory compliance, cost control, and smart growth. Fraud mitigation focuses on ensuring that an eligible identity is being presented by its true owner, rather than as part of a scheme to acquire goods and services with intent to default on repayment obligations. Businesses who focus on solely on fraud mitigation rather than complying with KYC and CIP regulations run the risk of potential harm to business reputation, and of course, financial penalties. Fenergo found that as of the end of 2019, global penalties for AML and KYC non-compliance totaled $36 billion. CIP vs. Fraud Mitigation Many financial institutions equate a CIP program with efforts to mitigate fraud. It’s understandable, as both processes include emphasis on the accuracy of an identity as it’s presented by a consumer. It is assumed that only the true owner of the identity would possess the detailed information necessary to meet CIP requirements and therefore would not likely be committing fraud. There was a time—prior to large scale thefts of stored information, personal details shared through social media and other behavior changes that made personal information very public—when this would have been true. Unfortunately, those days have passed and even an amateur criminal with limited experience and resources could find current, accurate identity information for sale online, information good enough to pass the CIP test and be considered a legitimate consumer. The real challenge is that when they go through CIP, many real consumers may inadvertently provide true information that doesn’t meet the verification standard. This is a result of consumer lifestyle changes outpacing the sources of data used to verify the information they’ve provided. It makes sense; in most years roughly 13% of American adults change their address. New homes, job changes and changes in marital status impact a large number of people every day. Adding to the confusion—it’s life’s changes that prompt people to borrow and purchase. The result is that many of the people that are more likely to fail CIP verification are the very people trying to legitimately access financial services. The result is that CIP verification often isn’t a challenge for those intending to commit fraud, but it can be for genuine consumers. The challenges of CIP In a recent internal study, Experian reviewed the ability to pass a standard CIP strategy that assessed the accuracy of the name, current address, date of birth and Social Security number provided by a large sample of consumers. We then compared legitimate consumers to those later confirmed to have been identity thieves impersonating a victim. Consistently, the identity thieves were at least as proficient at passing CIP as their true-consumer counterparts. In a second step, we applied a fraud score that looked for identity theft by assessing the past uses of the identities, their consistency, velocity and many other characteristics unrelated to the accuracy of the data. The difference between CIP verification and a fraud risk assessment was striking. Across the entire range of fraud risk, the percentage of records that passed CIP verification remained the same. That said, CIP still plays a very important role in risk mitigation. In fact, CIP and fraud prevention are inextricable in financial services. Just as a CIP verified identity can still be fraud, a record that may appear to be low fraud risk may not pass CIP. Since both processes have existed side by side for nearly two decades, each presumes that the other is in place and both are necessary to detect and prevent fraud. Striking a balance CIP verification and fraud mitigation strategies are both necessary and important to protecting assets and the broader financial system from fraud. It’s important to leverage a layered approach where both eligibility and risk are assessed, and next steps for verification include resolution of identity discrepancies alongside verification that ensures an identity is not being misused for fraud. Experian can help you confidently verify customer identities, understand and anticipate customer activities, and implement ongoing monitoring. If you’d like to set up a review of your current strategy or learn more about how we can help you with CIP and fraud mitigation to strengthen your ability to know your customer compliantly, let us know. Contact us
According to Experian’s latest Global Insights Report, 38% of consumers expect to increase their online activity in the next 12 months. The report also found that consumers continue to have high expectations for their online experience, and businesses are re-imagining the customer journey to reflect that need. This January, Experian surveyed 3,000 consumers and 900 businesses to explore the changes in consumer behavior and business strategy pre- and post-COVID-19. As consumers have embraced life online, they’ve continued to emphasize their feelings regarding the importance of protecting their information. More than half of consumers still consider security to be the most important factor in their digital experience – the same experience they have such high expectations of. Business are acting in turn, with more than half investing in fraud detection methods or software to reduce friction in the customer experience. Digital transformation is also highlighting the need to: Manage regulatory compliance Integrate security measures Ensure access to AI models Attract and manage customers Integrate automation solutions Download the report to get all the latest insights into consumer desires and business behaviors, and keep visiting the Insights blog for a deeper dive into US-specific findings. Download report
2020 is finally over – been there, done that. And while it seems safe to say most everyone is all too eager to kick off a new calendar year, the reality is we’re still reeling – and will continue to reel – through the economic impacts of the COVID-19 global pandemic. As we inch closer to the one year marker of when many businesses were sent home – across all industries, including those tech-inclined and those less so – the understatement of the year is that the world has since changed as have consumer communication preferences, how businesses and customers interact, tweaked definitions of privacy, and new (heightened) expectations of evolving a positive customer experience with minimal friction and maximum security. While last year’s predictions of entering a new set of Roaring 20’s may not have panned out the way we had initially imagined, many of the trends thought to evolve over the last 365 days did. As we all look toward a post-pandemic world, here are six top trends to keep tabs on throughout 2021. 1. Data Data as a commodity and as a business differentiating factor has reached an all-time high. It’s doing more across the entire customer lifecycle and can elevate businesses to best prep for growth, especially as consumers begin to look for more financial products (whether looking for financial assistance as the CARES Act accommodation period ends, or to take advantage of the booming mortgage industry, etc.). Data can also give more insights into consumers than ever before. Far beyond just credit scores and financial data, today’s data sets can reveal consumers’ lifestyle preferences, their preferred communication channels, their rental histories, and so much more. With alternative credit data and non-traditional data (including consumer-permissioned data), businesses can get a holistic picture of their customers’ payment behaviors. That streaming media service monthly payment may seem minimal, but now could increase your credit score through Experian Boost. Experian is still making big strides in all efforts to use data for good. As of December 31, 2020, Experian Boost has “boosted” Americans’ credit scores nearly 47 million points. Additionally, throughout 2020, Experian worked with financial institutions and credit furnishers to continue to put consumers first and serve as the consumer’s bureau. Coming up in 2021? Using data for differentiation, which can ultimately drive business growth. From instant prescreens to identifying your best customers (and offering them cross-sell and upsell opportunities to increase retention and customer loyalty) to helping customers that may be on the brink of financial distress and connecting them with management solutions to help them get back on their feet, data can help businesses – and their customers – get there. 2. Fraud and Friction (And the Reduction of Both) With the pandemic, fraud saw increases across the board. Here are just some quick stats: 200% increase in first-time online banking usage immediately following shelter-in-place orders (Aite Group, “Workplace Distancing: Adapting Fraud and AML Operations to COVID-19,” April 2020) 652% year-over-year increase in records found on the dark web (Experian CyberAgent technology) 50% increase in human farming – real people being hired for purposes of fraud – month-over-month in March 2020 (Arkose Labs) And, unsurprisingly, consumer and business sentiments toward fraud are also evolving with these increasing trends. For example, according to Experian’s North America Trends Report, half of consumers continue to site security as the most important factor of their online experience. Additionally, there’s been an increase in the percentage of businesses who have recently increased or are planning to increase fraud budget from 76% in 2019 to 89% as of Sept. 2020. More complex phishing schemes and increased fraudster activity is due in part to numerous industries having to shift to online processes and business transactions overnight. Adoption for mobile wallets has jumped 11% since July 2020, according to the 2020 Global Insights Report. Systems and technology that were not ready or not armed with the necessary infrastructure left critical access points open that could be exploited by fraudsters. Fraud exists across the customer lifecycle, at every access point. And while fraud is complex, with Experian as your partner, solving it isn’t. Innovative technology enables businesses to prevent fraud by identifying credible customers and applying the correct treatment to the riskiest consumer and business accounts. We can help you develop a layered risk management strategy so you can focus resources on growing and protecting your customer relationships. 3. A New Administration – Changing of the Guards on the Regulatory Front With the new year enters the inauguration of a new president and administration. Though there is still much to be determined, certain areas are drawing a lot of attention with this changing of the guards. The highlights? The CFPB. Priorities and leadership could change. With COVID-19 top of mind, it is likely there will be aggressive agendas put forth to help protect the millions of consumers who have suffered economic distress and harm as a result of the pandemic. Data Portability. With an increased consumer appetite to port their data, questions and concerns around data security – and how to verify for a third party asking for the data – are also on the rise. There are a number of issues facing financial institutions around data portability, one of the largest being defining the line between consumer account information and proprietary data. All things privacy – state vs. national bills. The debate continues on how to move forward (whether privacy legislation will be handled by the states or at the national level), but for now it seems there is more progress at the state level. California was the first state to push through state-level privacy legislation in the form of the California Consumer Privacy Act of 2018. Twenty-four states are considering legislation that would require consent before collecting or disclosing personal information with third parties. 4. Analytics + Digitalization – Smarter, Better, Faster COVID-19 accelerated digital transformation for many. Some companies were ready, having already started making the headway in years prior, while others struggled – and some continue to struggle. The pandemic – and its corresponding recovery – is reason now, more than ever, to get some of your digital transformation priorities checked off of your list. Your customers demand it and your business needs it. Tackling analytics and digitalization not only brings your business up to speed, but improves your decisioning, enhances your offerings, and enables better platforms and data usage. In addition to digitalization, artificial intelligence for credit decisioning and personalized banking can also be expected to be a top trend, especially AI that is ethical and explainable, as will the increasing adoption and implementation of cloud computing. As consumer experience continues to reign supreme, any and all technology to enhance and improve that experience – think chatbots and virtual assistants – will also likely increase in presence. 5. Verification & Identity Identity has been a trending topic over the last few years, brought on by increasingly digital lifestyles and the intersection of personalization, frictionless transactions and adequate security. Identity verification and verification of other information such as income, employment and the like are increasingly needed in a today’s pandemic and tomorrow’s post-pandemic world. Leveraged across the lifecycle and during critical customer interactions, the need is especially heightened for insights, data accuracy, and diversification of data sets – to name a few. And while it was already established that identity verification is not just for marketing services, there are now even greater needs for financial institutions to be able to confidently know that their customers are who they say they are. Some areas to keep your eye on in 2021? Identity, income, assets and employment. 6. Redefining the Modern Mortgage As has been a common trend, spurred by the disruption caused by COVID-19, the mortgage industry is one of the many to have a magnifying glass brought to its areas for improvement. Some of those areas include operational efficiency, digital adoption and transparency. In line with the better and faster needs that lenders are continually trying to pace with, the need for speed is hitting mortgage originations, with an ideal situation outlined as closing in 30 days or less. Creating operational efficiencies through faster, fresher data can be the key for lenders to more accurately assess a borrower’s ability to pay upfront. Additionally, now, as most mortgage lenders are breaking previous origination records by a landslide (thanks pandemic), there’s new focus on other performance indicators. With such impetus, the modern mortgage is constantly evolving, incorporating customer-centric facets including a seamless digital process, providing meaningful customer experiences and leveraging the latest and greatest technology to better future-proof the industry through scalable technology, while aiming to reduce costs. For all your needs in 2021 and beyond, Experian has you covered. Learn More
When running a credit report on a new applicant, you must ensure Fair Credit Reporting Act (FCRA) compliance before accessing, using and sharing the collected data. The Coronavirus Aid, Relief, and Economic Security (CARES) Act has impacted credit reporting under the FCRA, as has new guidance from the Consumer Financial Protection Bureau (CFPB). Recent updates include: The CARES Act amended the FCRA to require furnishers who agree to an “accommodation,”1 to report the account as current, although it is permitted to continue to report the account as delinquent if the account was delinquent before the accommodation was made. Although not legally obligated, data furnishers should continue furnishing information to the credit reporting agencies (CRAs) during the COVID-19 crisis, and make sure that information reported is complete and accurate. Below is a brief FCRA-related compliance overview2 covering various FCRA requirements3 when requesting and using consumer credit reports for an extension of credit permissible purpose. For more information regarding your responsibilities under the FCRA as a user of consumer reports, please consult your Legal Counsel and the Notice to Users of Consumer Reports: Obligations of Users Under the FCRA handbook located on our website. Before obtaining a consumer report you have… Reviewed your federal and state regulations and laws related to consumer reports, scores, decisions, etc. Made sure you have a valid permissible purpose for pulling the consumer report. Certified compliance to the CRA from which you are getting the consumer report. You have certified that you complied with all the federal and state requirements. After you take an adverse action based on a consumer report you… Provide the consumer with an oral, written or electronic notice of the adverse action. Provide written or electronic disclosure of the numerical credit score used to take the adverse action, or when providing a “risk-based pricing” notice. Provide the consumer with an oral, written or electronic notice, which includes the below information: Name, address and telephone number of CRA that supplied the report, if nationwide. A statement that the CRA did not make the adverse decision and therefore can’t explain why the decision was made. Notice of the consumer’s right to a free copy of their report from the CRA, if requested within 60 days. Notice of the consumer’s right to dispute with the CRA the accuracy or completeness of any information in a consumer report provided by the CRA. Provide the consumer with a “risk-based pricing” notice if credit was granted but on less favorable terms based on information in their consumer report. We understand how challenging it is to understand and meet all your obligations as a data furnisher – we’re here to make it a little easier. Click below to speak with a representative and gain more insight on how the CARES Act impacts FCRA reporting. Download overview Speak with a representative 1An “accommodation” is defined as “an agreement to defer one or more payments, make a partial payment, forbear any delinquent amounts, modify a loan or contract, or any other assistance or relief” granted to a consumer affected by COVID-19 during the covered period. 2This FCRA overview is not legal guidance and does not enumerate all your requirements under the FCRA as a user of consumer reports. Additionally, this FCRA Overview is not intended to provide legal advice or counsel you regarding your obligations under the FCRA or any other federal or state law or regulation. Should you have any questions about your institution’s specific obligations under the FCRA or any other federal or state law or regulation, you should consult with your Legal Counsel. 3This FCRA overview is intended to be used solely by financial service providers when extending credit to consumers and does not include all FCRA regulatory obligations. You are responsible for regulatory compliance when requesting and using consumer reports, which includes adhering to all applicable federal and state statutes and regulations and ensuring that you have the correct policies and procedures in place.
One of the most difficult parts of combating fraud is the ability to distinguish between the variety of fraud types. To properly manage your fraud efforts, you need to be able to differentiate between first party fraud and third party fraud so you can determine the best treatment. After all, if you’re treating first party fraud as though it’s third party fraud, the customer you’re contacting for verification will give whatever information they need to in order to continue their criminal actions. So how do you verify each type of fraud without adding additional overhead or increasing the friction experienced by your customers? Combating Fraud During an Economic Downturn Particularly in times of economic uncertainty, the ability to detect and identify individual fraud types allows you to work to prevent them in the future. Through proper identification, you can also apply the correct treatments to maximize the effectiveness of your fraud response teams, since the treatment for first and third party fraud is different. During the economic upswing, first party fraud was a secondary concern. Businesses were easing friction to help continue growth. Now, the same customers that businesses thought would drive growth are hurting and unable to help offset the losses caused by bad actors. Now is the time to revisit existing fraud prevention and mitigation strategies to ensure that fraud is properly identified, and the correct treatments are applied. Introducing Precise ID® Model Suite Experian’s Precise ID Model Suite combines identity analytics with advanced fraud risk models to: Protect the entire customer journey again fraud – across account opening, login, maintenance and transactions Distinguish first-party, third-party, and synthetic identity fraud to determine the best next action Enable agility during changing market conditions Maintain regulatory compliance (including: KYC, CIP, GLBA, FCRA, FFIEC, PATRIOT Act, FACTA, and more) Improve overall fraud management strategies and reduce losses Precise ID Model Suite allows you to detect and distinguish types of fraud with a single call – enabling your business to maximize efficiency and eliminate redundancy across your fraud prevention teams. By accurately recognizing risk, and in particular, recognizing that first party fraud is in fact a type of fraud distinct from credit risk, you’re able to protect your portfolio and your customers. Learn more
With new legislation, including the Coronavirus Aid, Relief, and Economic Security (CARES) Act impacting how data furnishers will report accounts, and government relief programs offering payment flexibility, data reporting under the coronavirus (COVID-19) outbreak can be complicated. Especially when it comes to small businesses, many of which are facing sharp declines in consumer demand and an increased need for capital. As part of our recently launched Q&A perspective series, Greg Carmean, Experian’s Director of Product Management and Matt Shubert, Director of Data Science and Modelling, provided insight on how data furnishers can help support small businesses amidst the pandemic while complying with recent regulations. Check out what they had to say: Q: How can data reporters best respond to the COVID-19 global pandemic? GC: Data reporters should make every effort to continue reporting their trade experiences, as losing visibility into account performance could lead to unintended consequences. For small businesses that have been negatively affected by the pandemic, we advise that when providing forbearance, deferrals be reported as “current”, meaning they should not adversely impact the credit scores of those small business accounts. We also recommend that our data reporters stay in close contact with their legal counsel to ensure they follow CARES Act guidelines. Q: How can financial institutions help small businesses during this time? GC: The most critical thing financial institutions can do is ensure that small businesses continue to have access to the capital they need. Financial institutions can help small businesses through deferral of payments on existing loans for businesses that have been most heavily impacted by the COVID-19 crisis. Small Business Administration (SBA) lenders can also help small businesses take advantage of government relief programs, like the Payment Protection Program (PPP), available through the CARES Act that provides forgiveness on up to 75% of payroll expenses and 25% of other qualifying expenses. Q: How do financial institutions maintain data accuracy while also protecting consumers and small businesses who may be undergoing financial stress at this time? GC: Following bureau recommendations regarding data reporting will be critical to ensure that businesses are being treated fairly and that the tools lenders depend on continue to provide value. The COVID-19 crisis also provides a great opportunity for lenders to educate their small business customers on their business credit. Experian has made free business credit reports available to every business across the country to help small business owners ensure the information lenders are using in their credit decisioning is up-to-date and accurate. Q: What is the smartest next play for financial institutions? GC: Experian has several resources that lenders can leverage, including Experian’s COVID-19 Business Risk Index which identifies the industries and geographies that have been most impacted by the COVID crisis. We also have scores and alerts that can help financial institutions gain greater insights into how the pandemic may impact their portfolios, especially for accounts with the greatest immediate exposure and need. MS: To help small businesses weather the storm, financial institutions should make it simple and efficient for them to access the loans and credit they need to survive. With cash flow to help bridge the gap or resume normal operations, small businesses can be more effective in their recovery processes and more easily comply with new legislation. Finances offer the support needed to augment currently reduced cash flows and provide the stability needed to be successful when a return to a more normal business environment occurs. At Experian, we’re closely monitoring the updates around the coronavirus outbreak and its widespread impact on both consumers and businesses. We will continue to share industry-leading insights to help data furnishers navigate and successfully respond to the current environment. Learn more About Our Experts Greg Carmean, Director of Product Management, Experian Business Information Services, North America Greg has over 20 years of experience in the information industry specializing in commercial risk management services. In his current role, he is responsible for managing multiple product initiatives including Experian’s Small Business Financial Exchange (SBFE), domestic and international commercial reports and Corporate Linkage. Recently, he managed the development and launch of Experian’s Global Data Network product line, a commercial data environment that provides a single source of up to date international credit and firmographic information from Experian commercial bureaus and Tier 1 partners across the globe. Matt Shubert, Director of Data Science and Modelling, Experian Data Analytics, North America Matt leads Experian’s Commercial Data Sciences Team which consists of a combination of data scientists, data engineers and statistical model developers. The Commercial Data Science Team is responsible for the development of attributes and models in support of Experian’s BIS business unit. Matt’s 15+ years of experience leading data science and model development efforts within some of the largest global financial institutions gives our clients access to a wealth of knowledge to discover the hidden ROI within their own data.
Article written by Alex Lintner, Experian\'s Group President of Consumer Information Services and Sandy Anderson, Experian\'s Senior Vice President of Client and Sales Operations Many consumers are facing financial stress due to unemployment and other hardships related to the COVID-19 pandemic. Not surprisingly, data scientists at Experian are looking into how consumers’ credit scores may be impacted during the COVID-19 national emergency period as financial institutions and credit bureaus follow guidance from financial regulators and law established in Section 4021 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In a nutshell, Experian finds that if consumers contact their lenders and are granted an accommodation, such as a payment holiday or forbearance, and lenders report the accommodation accordingly, consumer scores will not be materially affected negatively. It’s not just Experian’s findings, but also those of the major credit scoring companies, FICO® and VantageScore®. FICO has reported that if a lender provides an accommodation and payments are reported on time consistent with the CARES Act, consumers will not be negatively impacted by late payments related to COVID-19. VantageScore has also addressed this issue and stated that its models are designed to mitigate the impact of missed payments from COVID-19. At the same time, if as predicted, lenders tighten underwriting standards following 11 consecutive years of economic growth, access to credit for some consumers may be curtailed notwithstanding their score because their ability to repay the loan may be diminished. Regulatory guidance and law provide a robust response Recently, the Federal Reserve, along with the federal and state banking regulators, issued a statement encouraging mortgage servicers to work with struggling homeowners affected by the COVID-19 national emergency by allowing borrowers to defer mortgage payments up to 180-days or longer. The Federal Deposit Insurance Corporation stated that financial institutions should “take prudent steps to assist customers and communities affected by COVID-19.” The Office of the Comptroller of the Currency, which regulates nationally chartered banks, encouraged banks to offer consumers payment accommodations to avoid delinquencies and negative credit bureau reporting. This regulatory guidance was backed by Congress in passing the CARES Act, which requires any payment accommodations to be reported to a credit bureau as “current.” The Consumer Financial Protection Bureau, which has oversight of all financial service providers, reinforced the regulatory obligation in the CARES Act. In a statement, the Bureau said “the continuation of reporting such accurate payment information produces substantial benefits for consumers, users of consumer reports and the economy as a whole.” Moreover, the consumer reporting industry has a history of successful coordination during emergency circumstances, like COVID-19, and we’ve provided the support necessary for lenders to report accurately and consistent with regulatory guidance. For example, when a consumer faces hardship, a lender can add a code that indicates a customer or borrower has been “affected by natural or declared disaster.” If a lender uses this or a similar code, a notification about the disaster or other event will appear in the credit report with the trade line for the customer’s account and will remain on the trade line until the lender removes it. As a result, the presence of the code will not negatively impact the consumer credit score. However, other factors may impact a consumer’s score, such as an increase in a consumer’s utilization of their credit lines, which is a likely scenario during a period of financial stress. Suppression or Deletion of late payments will hurt, not help, credit scores In response to the nationwide impact of COVID-19, some lawmakers have suggested that lenders should not report missed payments or that credit bureaus should delete them. The presumption is that these actions would hold consumers harmless during the crisis caused by this pandemic. However, these good intentions end up having a detrimental impact on the whole credit ecosystem as consumer credit information is no longer accurately reflecting consumers’ specific situation. This makes it difficult for lenders to assess risk and for consumers to obtain appropriately priced credit. Ultimately, the best way to help is a consumer-specific solution, meaning one in which a lender reaches an accommodation with each affected individual, and accurately reflects that person’s unique situation when reporting to credit bureaus. When a consumer misses a payment, the information doesn’t end up on a credit report immediately. Most payments are monthly, so a consumer’s payment history with a financial institution is updated on a similar timeline. If, for example, a lender was required to suppress reporting for three months during the COVID-19 national emergency, the result would be no data flowing onto a credit report for three months. A credit report would therefore show monthly payments and then three months of no updates. The same would be true if a credit reporting agency were required to suppress or delete payment information. The lack of data, due to suppression or deletion, means that lenders would be blinded when making credit decisions, for example to increase a credit limit to an existing customer or to grant a new line of credit to a prospective customer. When faced with a blind spot, and unable to assess the real risk of a consumer’s credit history, the prudential tendency would be to raise the cost of credit, or to decrease the availability of credit, to cover the risk that cannot be measured. This could effectively end granting of credit to new customers, further stifling economic recovery and consumer financial health at a time when it’s needed most. Beyond the direct impact on consumers, suppression or deletion of credit information could directly affect the safety and soundness of the nation’s consumer and small business lending system. With missing data, lenders and their regulators would be flying blind as to the accurate information about a consumer’s risk and could result in unknowingly holding loan portfolios with heightened risk for loss. Too many unexpected losses threaten the balance of the financial system and could further seize credit markets. Experian is committed to helping consumers manage their credit and working with lenders on how best to report consumer-specific solutions. To learn more about what consumers can do to manage credit during the COVID-19 national emergency, we’ve provided resources on our website. For individuals looking to explore options their lenders may offer, we’ve included links to many of the companies and update them continuously. With good public policy and consumer-specific solutions, consumers can continue to build credit and help our economy grow.
Over the years, businesses have gathered a plethora of datasets on their customers. However, there is no value in data alone. The true value comes from the insights gained and actions that can be derived from these datasets. Advanced analytics is the key to understanding the data and extracting the critical information needed to unlock these insights. AI and machine learning in particular, are two emerging technologies with advanced analytics capabilities that can help companies achieve their business goals. According to an IBM survey, 61% of company executives indicated that machine learning and AI are their company’s most significant data initiatives in 2019. These leaders recognize that advanced analytics is transforming the way companies traditionally operate. It is no longer just a want, but a must. With a proper strategy, advanced analytics can be a competitive differentiator for your financial institution. Here are some ways that advanced analytics can empower your organization: Provide Personalized Customer Experiences Business leaders know that their customers want personalized, frictionless and enhanced experiences. That’s why improving the customer experience is the number one priority for 80 percent of executives globally, according to an Experian study. The data is already there – companies have insights into what products their customers like, the channels they use to communicate, and other preferences. By utilizing the capabilities of advanced analytics, companies can extract more value from this data and gain better insights to help create more meaningful, personalized and profitable lending decisions. Reduce Costs Advanced analytics allows companies to deploy new models and strategies more efficiently – reducing expenses associated with managing models for multiple lending products and bureaus. For example, OneMain Financial, was able to successfully drive down risk modeling expenses after implementing a solution with advanced analytics capabilities. Improve Accuracy and Speed to Market To stay ahead of the competition, companies need to maintain fast-moving environments. The speed, accuracy and power of a company’s predictive models and forecasts are crucial for success. Being able to respond to changing market conditions with insights derived from advanced analytics is a key differentiator for future-forward companies. Advanced analytic capabilities empower companies to anticipate new trends and drive rapid development and deployment, creating an agile environment of continual improvement. Drive Growth and Expand Your Customer Base With the rise of AI, machine learning and big data, the opportunities to expand the credit universe is greater than ever. Advanced analytic capabilities allow companies to scale datasets and get a bird’s eye view into a consumer’s true financial position – regardless of whether they have a credit history. The insights derived from advanced analytics opens doors for thin file or credit invisible customers to be seen – effectively allowing lenders to expand their customer base. Meet Compliance Requirements Staying on top of model risk and governance should always remain top of mind for any institution. Analytical processing aggregates and pulls new information from a wide range of data sources, allowing your institution to make more accurate and faster decisions. This enables lenders to lend more fairly, manage models that stand up to regulatory scrutiny, and keep up with changes in reporting practices and regulations. Better, faster and smarter decisions. It all starts with advanced analytics. Businesses must take advantage of the opportunities that come with implementing advanced analytics, or risk losing their customers to more future-forward organizations. At Experian, we believe that using big data can help power opportunities for your company. Learn how we can help you leverage your data faster and more effectively. Learn More
To provide consumers with clear-cut protections against disturbance by debt collectors, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) to implement the Fair Debt Collection Practices Act (FDCPA) earlier this year. Among many other things, the proposal would set strict limits on the number of calls debt collectors may place to reach consumers weekly and clarify requirements for consumer-facing debt collection disclosures. A bigger discussion Deliberation of the debt collection proposal was originally scheduled to begin on August 18, 2019. However, to allow commenters to further consider the issues raised in the NPRM and gather data, the comment period was extended by 20 days to September 18, 2019. It is currently still being debated, as many argue that the proposed rule does not account for modern consumer preferences and hinders the free flow of information used to help consumers access credit and services. The Association of Credit and Collection Professionals (ACA International) and US House lawmakers continue to challenge the proposal, stating that it doesn’t ensure that debt collectors’ calls to consumers are warranted, nor does it do enough to protect consumers’ privacy. Many consumer advocates have expressed doubts about how effective the proposed measures will be in protecting debtors from debt collector harassment and see the seven-calls-a-week limit on phone contact as being too high. In fact, it’s difficult to find a group of people in full support of the proposal, despite the CFPB stating that it will help clarify the FDCPA, protect lenders from litigation and bring consumer protection regulation into the 21st century. What does this mean? Although we don’t know when, or if, the proposed rule will go into effect, it’s important to prepare. According to the Federal Register, there are key ways that the new regulation would affect debt collection through the use of newer technologies, required disclosures and limited consumer contact. Not only will the proposed rules apply to debt collectors, but its provisions will also impact creditors and servicers, making it imperative for everyone in the financial services space to keep watch on the regulation’s status and carefully analyze its proposed rules. At Experian, our debt collection solutions automate and moderate dialogues and negotiations between consumers and collectors, making it easier for collection agencies to connect with consumers while staying compliant. Our best-in-class data and analytics will play a key role in helping you reach the right consumer, in the right place, at the right time. Learn more
Earlier this year, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM) to implement the Fair Debt Collection Practices Act (FDCPA). The proposal, which will go into deliberation in September and won\'t be finalized until after that date at the earliest, would provide consumers with clear-cut protections against disturbance by debt collectors and straightforward options to address or dispute debts. Additionally, the NPRM would set strict limits on the number of calls debt collectors may place to reach consumers weekly, as well as clarify how collectors may communicate lawfully using technologies developed after the FDCPA’s passage in 1977. So, what does this mean for collectors? The compliance conundrum is ever present, especially in the debt collection industry. Debt collectors are expected to continuously adapt to changing regulations, forcing them to spend time, energy and resources on maintaining compliance. As the most recent onslaught of developments and proposed new rules have been pushed out to the financial community, compliance professionals are once again working to implement changes. According to the Federal Register, here are some key ways the new regulation would affect debt collection: Limited to seven calls: Debt collectors would be limited to attempting to reach out to consumers by phone about a specific debt no more than seven times per week. Ability to unsubscribe: Consumers who do not wish to be contacted via newer technologies, including voicemails, emails and text messages must be given the option to opt-out of future communications. Use of newer technologies: Newer communication technologies, such as emails and text messages, may be used in debt collection, with certain limitations to protect consumer privacy. Required disclosures: Debt collectors will be obligated to send consumers a disclosure with certain information about the debt and related consumer protections. Limited contact: Consumers will be able to limit ways debt collectors contact them, for example at a specific telephone number, while they are at work or during certain hours. Now that you know the details, how can you prepare? At Experian, we understand the importance of an effective collections strategy. Our debt collection solutions automate and moderate dialogues and negotiations between consumers and collectors, making it easier for collection agencies to reach consumers while staying compliant. Powerful locating solution: Locate past-due consumers more accurately, efficiently and effectively. TrueTraceSM adds value to each contact by increasing your right-party contact rate. Exclusive contact information: Mitigate your compliance risk with a seamless and unparalleled solution. With Phone Number IDTM, you can identify who a phone is registered to, the phone type, carrier and the activation date. If you aren’t ready for the new CFPB regulation, what are you waiting for? Learn more Note: Click here for an update on the CFPB\'s proposal.
Have you seen the latest Telephone Consumer Protection Act (TCPA) class action lawsuit? TCPA litigations in the communications, energy and media industries are dominating the headlines, with companies paying up to millions of dollars in damages. Consumer disputes have increased more than 500 percent in the past five years, and regulations continue to tighten. Now more than ever, it’s crucial to build effective and cost-efficient contact strategies. But how? First, know your facts. Second, let us help. What is the TCPA? As you’re aware, TCPA aims to safeguard consumer privacy by regulating telephone solicitations and the use of prerecorded messages, auto-dialed calls, text messages and unsolicited faxes. The rule has been amended and more tightly defined over time. Why is TCPA compliance important? Businesses found guilty of violating TCPA regulations face steep penalties – fines range from $500 to $1500 per individual infraction! Companies have been delivered hefty penalties upwards of hundreds of thousands, and in some cases, millions of dollars. Many have questions and are seeking to understand how they might adjust their policies and call practices. How can you protect yourself? To help avoid risk for compliance violations, it’s integral to assess call strategies and put best practices in place to increase right-party contact rates. Strategies to gain compliance and mitigate risk include: Focus on right and wrong-party contact to improve customer service: Monitoring and verifying consumer contact information can seem like a tedious task, but with the right combination of data, including skip tracing data from consumer credit data, alternative and other exclusive data sources, past-due consumers can be located faster. Scrub often for updated or verified information: Phone numbers can continuously change, and they’re only one piece of a consumer’s contact information. Verifying contact information for TCPA compliance with a partner you can trust can help make data quality routine. Determine when and how often you dial cell phones: Or, given new considerations proposed by the CFPB, consider looking at collections via your consumers’ preferred communication channel – online vs. over the phone. Provide consumers user-friendly mechanisms to opt-out of receiving communications At Experian, our TCPA solutions can help you monitor and verify consumer contact information, locate past-due consumers, improve your right-party contact rates and automate your collections process. Get started
Financial institutions preparing for the launch of the Financial Accounting Standard Board’s (FASB) new current expected credit loss model, or CECL, may have concerns when it comes to preparedness, implications and overall impact. Gavin Harding, Experian’s Senior Business Consultant and Jose Tagunicar, Director of Product Management, tackled some of the tough questions posed by the new accounting standard. Check out what they had to say: Q: How can financial institutions begin the CECL transition process? JT: To prepare for the CECL transition process, companies should conduct an operational readiness review, which includes: Analyzing your data for existing gaps. Determining important milestones and preparing for implementation with a detailed roadmap. Running different loss methods to compare results. Once losses are calculated, you’ll want to select the best methodology based on your portfolio. Q: What is required to comply with CECL? GH: Complying with CECL may require financial institutions to gather, store and calculate more data than before. To satisfy CECL requirements, financial institutions will need to focus on end-to-end management, determine estimation approaches that will produce reasonable and supportable forecasts and automate their technology and platforms. Additionally, well-documented CECL estimations will require integrated workflows and incremental governance. Q: What should organizations look for in a partner that assists in measuring expected credit losses under CECL? GH: It’s expected that many financial institutions will use third-party vendors to help them implement CECL. Third-party solutions can help institutions prepare for the organization and operation implications by developing an effective data strategy plan and quantifying the impact of various forecasted conditions. The right third-party partner will deliver an integrated framework that empowers clients to optimize their data, enhance their modeling expertise and ensure policies and procedures supporting model governance are regulatory compliant. Q: What is CECL’s impact on financial institutions? How does the impact for credit unions/smaller lenders differ (if at all)? GH: CECL will have a significant effect on financial institutions’ accounting, modeling and forecasting. It also heavily impacts their allowance for credit losses and financial statements. Financial institutions must educate their investors and shareholders about how CECL-driven disclosure and reporting changes could potentially alter their bottom line. CECL’s requirements entail data that most credit unions and smaller lenders haven’t been actively storing and saving, leaving them with historical data that may not have been recorded or will be inaccessible when it’s needed for a CECL calculation. Q: How can Experian help with CECL compliance? JT: At Experian, we have one simple goal in mind when it comes to CECL compliance: how can we make it easier for our clients? Our Ascend CECL ForecasterTM, in partnership with Oliver Wyman, allows our clients to create CECL forecasts in a fraction of the time it normally takes, using a simple, configurable application that accurately predicts expected losses. The Ascend CECL Forecaster enables you to: Fulfill data requirements: We don’t ask you to gather, prepare or submit any data. The application is comprised of Experian’s extensive historical data, delivered via the Ascend Technology PlatformTM, economic data from Oxford Economics, as well as the auto and home valuation data needed to generate CECL forecasts for each unsecured and secured lending product in your portfolio. Leverage innovative technology: The application uses advanced machine learning models built on 15 years of industry-leading credit data using high-quality Oliver Wyman loan level models. Simplify processes: One of the biggest challenges our clients face is the amount of time and analytical effort it takes to create one CECL forecast, much less several that can be compared for optimal results. With the Ascend CECL Forecaster, creating a forecast is a simple process that can be delivered quickly and accurately. Q: What are immediate next steps? JT: As mentioned, complying with CECL may require you to gather, store and calculate more data than before. Therefore, it’s important that companies act now to better prepare. Immediate next steps include: Establishing your loss forecast methodology: CECL will require a new methodology, making it essential to take advantage of advanced statistical techniques and third-party solutions. Making additional reserves available: It’s imperative to understand how CECL impacts both revenue and profit. According to some estimates, banks will need to increase their reserves by up to 50% to comply with CECL requirements. Preparing your board and investors: Make sure key stakeholders are aware of the potential costs and profit impacts that these changes will have on your bottom line. Speak with an expert
What is CECL? CECL (Current Expected Credit Loss) is a new credit loss model, to be leveraged by financial institutions, that estimates the expected loss over the life of a loan by using historical information, current conditions and reasonable forecasts. According to AccountingToday, CECL is considered one of the most significant accounting changes in decades to affect entities that borrow and lend money. To comply with CECL by the assigned deadline, financial institutions will need to access much more data than they’re currently using to calculate their reserves under the incurred loss model, Allowance for Loan and Lease Losses (ALLL). How does it impact your business? CECL introduces uncertainty into accounting and growth calculations, as it represents a significant change in the way credit losses are currently estimated. The new standard allows financial institutions to calculate allowances in a variety of ways, including discounted cash flow, loss rates, roll-rates and probability of default analyses. “Large banks with historically good loss performance are projecting increased reserve requirements in the billions of dollars,” says Experian Advisory Services Senior Business Consultant, Gavin Harding. Here are a few changes that you should expect: Larger allowances will be required for most products As allowances will increase, pricing of the products will change to reflect higher capital cost Losses modeling will change, impacting both data collection and modeling methodology There will be a lower return on equity, especially in products with a longer life expectancy How can you prepare? “CECL compliance is a journey, rather than a destination,” says Gavin. “The key is to develop a thoughtful, data-driven approach that is tested and refined over time.” Financial institutions who start preparing for CECL now will ultimately set their organizations up for success. Here are a few ways to begin to assess your readiness: Create a roadmap and initiative prioritization plan Calculate the impact of CECL on your bottom line Run altered scenarios based on new lending policy and credit decision rules Understand the impact CECL will have on your profitability Evaluate current portfolios based on CECL methodology Run different loss methods and compare results Additionally, there is required data to capture, including quarterly or monthly loan-level account performance metrics, multiple year data based on loan product type and historical data for the life of the loan. How much time do you have? Like most accounting standards, CECL has different effective dates based on the type of reporting entity. Public business entities that file financial statements with the Security and Exchange Commission will have to comply by 2020, non-public entity banks must comply by 2022 and non-SEC registered companies have until 2023 to adopt the new standard. How can we help: Complying with CECL may require you to gather, store and calculate more data than before. Experian can help you comply with CECL guidelines including data needs, consulting and loan loss calculation. Experian industry experts will help update your current strategies and establish an appropriate timeline to meet compliance dates. Leveraging our best-in-class industry data, we will help you gain CECL compliance quickly and effectively, understand the impacts to your business and use these findings to improve overall profitability. Learn more
Federal legislation makes verifying an individual’s identity by scanning identity documents during onboarding legal in all 50 states Originally posted on Mitek blog The Making Online Banking Initiation Legal and Easy (MOBILE) Act officially became law on May 24, 2018, authorizing a national standard for banks to scan and retain information from driver’s licenses and identity cards as part of a customer online onboarding process, via smartphone or website. This bill, which was proposed in 2017 with bipartisan support, allows financial institutions to fully deploy mobile technology that can make digital account openings across all states seamless and cost efficient. The MOBILE Act also stipulates that the digital image would be destroyed after account opening to further ensure customer data security. As an additional security measure, section 213 of the act mandates an update to the system to confirm matches of names to social security numbers. “The additional security this process could add for online account origination was a key selling point with the Equifax data breach fresh on everyone’s minds,” Scott Sargent, of counsel in the law firm Baker Donelson’s financial service practice, recently commented on AmericanBanker.com. Read the full article here. Though digital banking and an online onboarding process has already been a best practice for financial institutions in recent years, the MOBILE Act officially overrules any potential state legislation that, up to this point, has not recognized digital images of identity documents as valid. The MOBILE Act states: “This bill authorizes a financial institution to record personal information from a scan, copy, or image of an individual’s driver’s license or personal identification card and store the information electronically when an individual initiates an online request to open an account or obtain a financial product. The financial institution may use the information for the purpose of verifying the authenticity of the driver’s license or identification card, verifying the identity of the individual, or complying with legal requirements.” Why adopt online banking? The recently passed MOBILE Act is a boon for both financial institutions and end users. The legislation: Enables and encourages financial institutions to meet their digital transformation goals Makes the process safe with digital ID verification capabilities and other security measures Reduces time, manual Know Your Customer (KYC) duties and costs to financial institutions for onboarding new customers Provides the convenient, on-demand experience that customers want and expect The facts: 61% of people use their mobile phone to carry out banking activity.1 77% of Americans have smartphones.2 50 million consumers who are unbanked or underbanked use smartphones.3 The MOBILE Act doesn’t require any regulatory implementation. Banks can access this real-time electronic process directly or through vendors. Read all you need to know about the MOBILE Act here. Find out more about a better way to manage fraud and identity services. References 1Mobile Ecosystem Forum, MEF Mobile Money Report (https://mobileecosystemforum.com/mobile-money-report/), Feb. 5, 2018. 2Pew Research Center, Mobile Fact Sheet (http://www.pewinternet.org/fact-sheet/mobile/), Jan. 30, 2017. 3The Federal Reserve System, Consumers and Mobile Financial Services 2015 (https://www.federalreserve.gov/econresdata/consumers-and-mobile-financial-services-report-201503.pdf), March 2015.
Customer Identification Program (CIP) solution through CrossCore® Every day, I work closely with clients to reduce the negative side effects of fraud prevention. I hear the need for lower false-positive rates; maximum fraud detection in populations; and simple, streamlined verification processes. Lately, more conversations have turned toward ID verification needs for Customer Information Program (CIP) administration. As it turns out, barriers to growth, high customer friction and high costs dominate the CIP landscape. While the marketplace struggles to manage the impact of fraud prevention, CIP routinely disrupts more than 10 percent of new customer acquisitions. Internally at Experian, we talk about this as the biggest ID problem our customers aren’t solving. Think about this: The fight for business in the CIP space quickly turned to price, and price was defined by unit cost. But what’s the real cost? One of the dominant CIP solutions uses a series of hyperlinks to connect identity data. Every click is a new charge. Their website invites users to dig into the data — manually. Users keep digging, and they keep paying. And the challenges don’t stop there. Consider the data sources used for these solutions. The winners of the price fight built CIP solutions around credit bureau header data. What does that do for growth? If the identity wasn’t sufficiently verified when a credit report was pulled, does it make sense to go back to the same data source? Keep digging. Cha-ching, cha-ching. Right about now, you might be feeling like there’s some sleight of hand going on. The true cost of CIP administration is much more than a single unit price. It’s many units, manual effort, recycled data and frustrated customers — and it impacts far more clients than fraud prevention. CIP needs have moved far beyond the demand for a low-cost solution. We’re thrilled to be leading the move toward more robust data and decision capabilities to CIP through CrossCore®. With its open architecture and flexible decision structure, our CrossCore platform enables access to a diverse and robust set of data sources to meet these needs. CrossCore unites Experian data, client data and a growing list of available partner data to deliver an intelligent and cost-conscious approach to managing fraud and identity challenges. The next step will unify CIP administration, fraud analytics and a range of verification treatment options together on the CrossCore platform as well. Spoiler alert. We’ve already taken that step.
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