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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.

Part twoImproved collector productivity and cash flow is the concept of doing more work with existing staff or doing the same amount of work with fewer human resources. In its most simplistic form, the associated metric is the number of cases worked per employee in a given amount of time. While the definition of cases worked can be open to interpretation, the most common qualifier is that an action from a pre-defined list must be executed and documented for each account.When leveraging modern technology to achieve these results, the first objective is to channel the accounts that benefit the most from human intervention. Real-time segmentation that considers the most current status of the case is a key feature in new systems that ensure accounts are placed in the right place at the right time. This makes certain that accounts find their way to the most appropriate skill level so that less experienced staff are not overwhelmed and more experienced staff are not tasked with easier activities that distract them from solving more complex situations. Context-sensitive screens and menus can further improve the productivity gains when collectors are working accounts. When collectors have the data they need to perform a task or make a decision without having to sift through irrelevant information, handling time is significantly reduced. Refreshing the screens and menus in real time as an account status changes is another key feature in today’s technology that ensures the appropriate information is always presented to the collector.Real-time scriptingReal-time scripting that is capable of being updated along with the changing situation is another productivity contributor, as is user-friendly screens. Not only is handling time further reduced, but gains can be found in significantly shorter training time for new staff members. Enabling the business users to change screen content, scripting, menus and visual aids on the fly is a powerful benefit of next generation collections systems. The ability to support champion / challenger testing for any visual or screen content changes further enables the organization to test and validate work stream improvements. In addition to the benefits mentioned above, advanced scripting and on-line help can significantly assist an organization to adhere to legal and compliance requirements.Real-time segmentationReal-time segmentation, coupled with context sensitive screens that refresh as the account situation changes (even in the midst of a negotiation) facilitate more effective negotiations. This lets collectors send more appropriate and relevant messaging to customers. Further improvements can be attributed to enabling a holistic view of the customer relationship and the relevance and effectiveness will be more consistent across the organization. The net effect is collecting more dollars per negotiation from the same population of customers that will be contacted in a faster manner.Real-time segmentation of accounts also provides the added benefit of keeping accounts in an active status and as a result makes your collections work stream more efficient. Not being dependent upon a batch process to update and route accounts ensures that each case is always in the right place at the right time and never in a holding pattern awaiting a transfer between work queues or departments. As a result, the organization will see more efficient case handling and a faster collection of debt.Improved productivity and real-time dashboardingImproved productivity reporting and real-time dashboarding enable line managers to provide appropriate feedback to collectors to make certain that Key Performance Indicators (KPI) goals are met on a regular basis. The resources in need of coaching or training can be identified before the substandard performance significantly reduces team objectives and collectors that excel can be provided with timely and accurate positive reinforcement.Gains in productivityWhen migrating to modern technology, it is very common that organizations experience at least a 20 percent gain in productivity improvement initially. This equates to the possibility of 20 fewer headcount in a team of 100 to handle the same workload. Alternatively, the existing team could handle 20 percent more accounts with approximately the same average results per account. Assuming a fully loaded cost of $50,000 a year per headcount, a 20 percent productivity boost in this example would roughly translate to a million dollars annually in financial benefit. When considering the additional benefit of reduced cost of training, this number will be even higher.Thanks for coming back. My next two blogs will provide additional details on the benefits of next generation collections systems including reduced operational and overhead costs and improved change management process.Stay tuned!


