
In this article…
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Phasellus at nisl nunc. Sed et nunc a erat vestibulum faucibus. Sed fermentum placerat mi aliquet vulputate. In hac habitasse platea dictumst. Maecenas ante dolor, venenatis vitae neque pulvinar, gravida gravida quam. Phasellus tempor rhoncus ante, ac viverra justo scelerisque at. Sed sollicitudin elit vitae est lobortis luctus. Mauris vel ex at metus cursus vestibulum lobortis cursus quam. Donec egestas cursus ex quis molestie. Mauris vel porttitor sapien. Curabitur tempor velit nulla, in tempor enim lacinia vitae. Sed cursus nunc nec auctor aliquam. Morbi fermentum, nisl nec pulvinar dapibus, lectus justo commodo lectus, eu interdum dolor metus et risus. Vivamus bibendum dolor tellus, ut efficitur nibh porttitor nec.
Pellentesque habitant morbi tristique senectus et netus et malesuada fames ac turpis egestas. Maecenas facilisis pellentesque urna, et porta risus ornare id. Morbi augue sem, finibus quis turpis vitae, lobortis malesuada erat. Nullam vehicula rutrum urna et rutrum. Mauris convallis ac quam eget ornare. Nunc pellentesque risus dapibus nibh auctor tempor. Nulla neque tortor, feugiat in aliquet eget, tempus eget justo. Praesent vehicula aliquet tellus, ac bibendum tortor ullamcorper sit amet. Pellentesque tempus lacus eget aliquet euismod. Nam quis sapien metus. Nam eu interdum orci. Sed consequat, lectus quis interdum placerat, purus leo venenatis mi, ut ullamcorper dui lorem sit amet nunc. Donec semper suscipit quam eu blandit. Sed quis maximus metus. Nullam efficitur efficitur viverra. Curabitur egestas eu arcu in cursus.
H1
H2
H3
H4
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Vestibulum dapibus ullamcorper ex, sed congue massa. Duis at fringilla nisi. Aenean eu nibh vitae quam auctor ultrices. Donec consequat mattis viverra. Morbi sed egestas ante. Vivamus ornare nulla sapien. Integer mollis semper egestas. Cras vehicula erat eu ligula commodo vestibulum. Fusce at pulvinar urna, ut iaculis eros. Pellentesque volutpat leo non dui aliquet, sagittis auctor tellus accumsan. Curabitur nibh mauris, placerat sed pulvinar in, ullamcorper non nunc. Praesent id imperdiet lorem.
H5
Curabitur id purus est. Fusce porttitor tortor ut ante volutpat egestas. Quisque imperdiet lobortis justo, ac vulputate eros imperdiet ut. Phasellus erat urna, pulvinar id turpis sit amet, aliquet dictum metus. Fusce et dapibus ipsum, at lacinia purus. Vestibulum euismod lectus quis ex porta, eget elementum elit fermentum. Sed semper convallis urna, at ultrices nibh euismod eu. Cras ultrices sem quis arcu fermentum viverra. Nullam hendrerit venenatis orci, id dictum leo elementum et. Sed mattis facilisis lectus ac laoreet. Nam a turpis mattis, egestas augue eu, faucibus ex. Integer pulvinar ut risus id auctor. Sed in mauris convallis, interdum mi non, sodales lorem. Praesent dignissim libero ligula, eu mattis nibh convallis a. Nunc pulvinar venenatis leo, ac rhoncus eros euismod sed. Quisque vulputate faucibus elit, vitae varius arcu congue et.
Ut convallis cursus dictum. In hac habitasse platea dictumst. Ut eleifend eget erat vitae tempor. Nam tempus pulvinar dui, ac auctor augue pharetra nec. Sed magna augue, interdum a gravida ac, lacinia quis erat. Pellentesque fermentum in enim at tempor. Proin suscipit, odio ut lobortis semper, est dolor maximus elit, ac fringilla lorem ex eu mauris.
- Phasellus vitae elit et dui fermentum ornare. Vestibulum non odio nec nulla accumsan feugiat nec eu nibh. Cras tincidunt sem sed lacinia mollis. Vivamus augue justo, placerat vel euismod vitae, feugiat at sapien. Maecenas sed blandit dolor. Maecenas vel mauris arcu. Morbi id ligula congue, feugiat nisl nec, vulputate purus. Nunc nec aliquet tortor. Maecenas interdum lectus a hendrerit tristique. Ut sit amet feugiat velit.
- Test
- Yes

Just as with diet recommendations, moderation needs to be the new motto for credit risk management. Diets provide for the occasional bag of chips or dessert after dinner, but these same food items become problems if the small quantity or occasional indulgence suddenly becomes the norm. Similarly, we, in our risk management efforts, put forth guidelines that establish limitations on certain loan types or categories that have been deemed risky should the numbers or quantity become too large a part of the overall portfolio. Unfortunately, we have a tendency to allow earnings or portfolio growth to cloud our judgment and take an attitude of “just one more.” In the past several years, we have experienced excesses in commercial real estate, residential development and subprime mortgages. It is now these excesses that are creating the problems that we are dealing with today. Bringing back these limitations – in other words, reestablishing the discipline in our portfolio risk management – will go a long way in avoiding these same problems in the future. As I learned early in my banking career: “…soundness, profitability and growth…in that order.”

By: Tom Hannagan The problem in the 2005 to 2007 home lending frenzy was not just granting credit to anyone who applied. It was giving loans to everyone at essentially the same price range regardless of normal credit risk scrutiny. While “selling” financial services may be largely an art form, appropriate risk-based pricing is more of a science. Although the financial press seemed to have discovered sub-prime lending in the last year or so, such high-risk lending isn’t new at all. It has been (and is still being) done since finance and money were invented. And, importantly, sub-prime lending has been done profitably by many lenders all along. The secret to their success, not surprisingly, has always been risk-based pricing — even if they didn’t call it that until recent times. Sub-prime funding has been available in many forms and from many sources. Providers range from venture capitalists to pawn shops. It includes pay-day lenders, micro loans, tax refund loans, consumer finance companies, and even dates to Shakespeare’s merchant of Venice. We often hear complaints that the effective rates (prices) on loans from such sources are unfairly high and predatory. The cost of that credit is high, but so is the risk of that credit. Without these kinds of sources, and their high rates, there would not be any credit granted from for-profit sources to high-risk borrowers. Listed firms that regularly provide pay-day loans or cash advances to sub-prime borrowers have very high gross margins and very high credit charge-offs, compared to banks. They also have much higher risk-based capital (or equity) positions that range from 40 percent to 60 percent of their average assets. This risk-based capital burden is much higher than the 8 to 10 percent found at commercial banks. So the sub-prime lenders have a significantly larger capital cushion than banks. Most of these financial results and ratios are examples of successful risk management where the credit risks are identified, managed, priced and backed by sufficient capital. Then…along came the rose-colored greed of the housing bubble that resulted in aggressive building and selling of homes, loan originations to all (no-down, no-income, no-assets, no-problem mortgages), securities packaging and attractive ratings, and global leveraged investing — all by prime-oriented entities and all at prime-oriented prices. Well, obviously, it didn’t work. Risk-based pricing of mortgages would have dissuaded many home buyers to begin with… but what would we have done with all of those shiny new homes? Realistic credit models (that took into account a full credit cycle and a huge proportion of sub-prime credits) would not have rated mortgage-backed securities as AAA. Regulators that were still focused on earnings correctness (the last major snafu) should have been looking into realistic net asset values. And highly compensated investment bankers, with 30-to-1 leverage ratios, would not have gone overboard with intuitively dodgy investments. Few of these players took risk management seriously. The new danger is that banks are doing the whole thing in reverse. They are tightening lending standards — which is, of course, a euphemism for shutting off credit. The danger has nothing to do with so-called credit standards. It’s the general over-reaction of shutting off credit to all borrowers, again, without regard to relative risk. The latest Federal Reserve Board survey of senior loan officers paints a picture of rapid tightening to record levels. We feel that credit standards should always improve AND that loan pricing should always proportionately reflect risk-adjusted rates and terms. Opening the flood gates and then slamming them shut is a very pro-cyclical behavior pattern on the part of bankers that doesn’t reflect a measured approach, borrower-by-borrower, using reasonable risk management at the client relationship level.

One of the more significant operational concerns around Red Flags compliance centers on the management of resultant referral volumes, i.e., the potential that the account origination or maintenance process will get bogged down due to a significant number of red flags detected. These concerns are not without merit, and are arguably the most frequently discussed Red Flag issue with our client base. Organizations may be able to control referral volumes through the use of automated tools that evaluate the level of identity theft risk in a given transaction. For example, customers with a low-risk authentication score can be moved quickly through the account origination process absent any additional red flags detected in the ordinary course of the application or transaction. In fact, using such tools may allow organizations to speed up the origination process for these customers and identify and focus resources on those transactions that pose the greatest potential for identity theft. A risk-based approach to Red Flags compliance affords an institution the ability to reconcile the majority of detected Red Flag conditions efficiently, consistently and with minimal consumer impact. Detection of Red Flag conditions is literally only half the battle. In fact, responding to those Red Flag conditions is a substantial problem to solve for most institutions. A response policy that incorporates scoring, alternate data sources and flexible decisioning can reduce the vast majority of referrals to real-time approvals without staff intervention or customer hardship. Rather than implementing a “rules-based” program (one in which particular Red Flags are identified, detected and used in isolation or near isolation in decisioning), many institutions are opting to approach Red Flag compliance from a “risk-based” perspective. This “risk-based” approach assumes that no single Red Flag Rule or even set of rules provides a comprehensive view of a consumer’s identity and associated fraud risk. Instead, a “risk-based” systematic approach to consumer authentication employs a process by which an appropriately comprehensive set of consumer data sources can provide the foundation for highly effective fraud prediction models in combination with detailed consumer authentication conditions (such as address mismatches or Social Security number inconsistencies). A risk-based fraud detection system allows institutions to make consumer relationship and transactional decisions based not on a handful of rules or conditions in isolation, but on a holistic view of a consumer’s identity and predicted likelihood of associated identity theft. Many, if not all, of the suggested Rules in the published guidelines are not “silver bullets” that ensure the presence or absence of identity theft. A substantial ratio of false positives will comprise the set of consumers and accounts being reviewed as having met one or more of the suggested Red Flag rule conditions. These rules and guidelines are intended neither to prevent legitimate consumers from establishing relationships with institutions nor create a burdensome and prohibitive volume of consumer “referrals.” While those rules incorporated into an institution’s Program must be addressed when detected, a risk-based system allows for an operationally efficient method of reconciliation in tandem with identity theft mitigation.


