Credit Lending

With the raising of the U.S. debt ceiling and its recent ramifications consuming the headlines over the past month, I began to wonder what would happen if the general credit consumer had made a similar argument to their credit lender. Something along the lines of, “Can you please increase my credit line (although I am maxed out)? I promise to reduce my spending in the future!” While novel, probably not possible. In fact, just the opposite typically occurs when an individual begins to borrow up to their personal “debt ceiling.” When the amount of credit an individual utilizes to what is available to them increases above a certain percentage, it can adversely affect their credit score, in turn affecting their ability to secure additional credit. This percentage, known as the utility rate is one of several factors that are considered as part of an individual’s credit score calculation. For example, the utilization rate makes up approximately 23% of an individual’s calculated VantageScore® credit score. The good news is that consumers as a whole have been reducing their utilization rate on revolving credit products such as credit cards and home equity lines (HELOCs) to the lowest levels in over two years. Bankcard and HELOC utilization is down to 20.3% and 49.8%, respectively according to the Q2 2011 Experian – Oliver Wyman Market Intelligence Reports. In addition to lowering their utilization rate, consumers are also doing a better job of managing their current debt, resulting in multi-year lows for delinquency rates as mentioned in my previous blog post. By lowering their utilization and delinquency rates, consumers are viewed as less of a credit risk and become more attractive to lenders for offering new products and increasing credit limits. Perhaps the government could learn a lesson or two from today’s credit consumer.

The following article was originally posted on August 15, 2011 by Mike Myers on the Experian Business Credit Blog. Last time we talked about how credit policies are like a plant grown from a seed. They need regular review and attention just like the plants in your garden to really bloom. A credit policy is simply a consistent guideline to follow when decisioning accounts, reviewing accounts, collecting and setting terms. Opening accounts is just the first step. Here are a couple of key items to consider in reviewing  accounts: How many of your approved accounts are paying you late? What is their average days beyond terms? How much credit have they been extended? What attributes of these late paying accounts can predict future payment behavior? I recently worked with a client to create an automated credit policy that consistently reviews accounts based on predictive credit attributes, public records and exception rules using the batch account review decisioning tools within BusinessIQ. The credit team now feels like they are proactively managing their accounts instead of just reacting to them.   A solid credit policy not only focuses on opening accounts, but also on regular account review which can help you reduce your overall risk.

By: John Straka Unsurprisingly, Washington deficit hawks have been eyeing the “sacred cows” of tax preferences for homeownership for some time now. Policymakers might even unwind or eliminate the mortgage interest deductions and capital-gains exemptions on home appreciation that have been in place in the U.S for many decades. There is an economic case to be made for doing this—more efficient resource allocation of capital, other countries have high ownership rates without such tax preferences, etc. But if you call or email or tweet Congress, and you choose this subject, my advice is to tell them that they should wait unti it’s 2005. In other words, now—or even the next few years most likely—is definitely not a good time at all to eliminate these housing tax preferences. We need to wait until it’s something like “2005”—when housing markets are much stronger again (hopefully) and state and local government finances are far from their relatively dire straits at present. If we don’t do this right, and insist on making big changes here now, then housing will take an immediate hit, and so will employment from both the housing sector and state and local governments (with further state and local service cutbacks also, due to budget shortfalls). The reason for this, of course, is that most homeowners today have not really benefited much, and won’t, from those well-established tax preferences. Why not? Because these preferences have been in place for so long now that the economic value (expected present discounted value) of these tax savings was long ago baked into the level of home prices that most homeowners paid when they bought their homes. Take the preferences away now, and the value of homes will immediately drop, and therefore so will property tax revenues collected by local governments across the U.S. This strategy will thus further bash the state- and-local sector in order to plump up some (we hope) our federal tax revenues by the value of the tax preferences. Housing will become a further drag on economic growth, and so will the resulting employment losses from both construction and local government services. As a result, it’s possible that on net the federal government may actually lose revenue from making this kind of change at precisely the wrong time. It may very well never be quite like “2005” again. But waiting for greater housing and local government strength to change long-standing housing tax preferences should make the macroeconomic impact smaller, less visible, and more easily absorbed.

A surprising occurrence is happening in the consumer credit markets. Bank card issuers are back in acquisition mode, enticing consumers with cash back, airline points and other incentives to get a share of their wallet. And while new account originations are nowhere near the levels seen in 2007, recent growth in new bank card accounts has been significant; 17.6% in Q1 2011 when compared to Q1 2010. So what is accounting for this resurgence in the credit card space while the economy is still trying to find its footing and credit is supposedly still difficult to come by for the average consumer? Whether good or bad, the economic crisis over the past few years appears to have improved consumers debt management behavior and card issuers have taken notice. Delinquency rates on bank cards are lower than at any time over the past five years and when compared to the start of 2009 when bank card delinquency was peaking; current performance has improved by over 40%. These figures have given bank card issuers the confidence to ease their underwriting standards and re-establish their acquisition strategies. What’s interesting however is the consumer segments that are driving this new growth. When analyzed by VantageScore, new credit card accounts are growing the fastest in the VantageScore D and F tiers with 46% and 53% increases year over year respectively. For comparison, VantageScore A and B tiers saw 5% and 1% increases during the same time period respectively.   And although VantageScore D and F represent less than 10% of new bank card origination volume ($ limits), it is still surprising to see such a disparity in growth rates between the risk categories. While this is a clear indication that card issuers are making credit more readily available for all consumer segments, it will be interesting to see if the debt management lessons learned over the past few years will stick and delinquency rates will continue to remain low. If these growth rates are any indication, the card issuers are counting on it.

By: Staci Baker The Durbin Amendment, according to Wikipedia, gave the Federal Reserve the power to regulate debit card interchange fees. The amendment, which will have a profound impact on banks, merchants and anyone who holds a debit card will take effect on October 1, 2011 rather than the originally announced July 21, 2011, which will allow banks additional time to implement the new regulations. The Durbin Amendment states that card networks, such as Visa and Mastercard, will include an interchange fee of 21 cents per transaction, and must allow debit cards to be processed on at least two independent networks. This will cost banks roughly $9.4 billion annually according to CardHub.com. As stipulated in the Amendment, institutions with less than $10 billion in assets are exempt from the cap. In preparation for the Durbin Amendment, several banks have begun to impose new fees on checking accounts, end reward programs, raise minimum balance requirements and have threatened to cap transaction amounts for debit card transactions at $50 to $100 in order to recoup some of the earnings they are expected to lose. These new regulations will be a blow to already hurting consumers as their out of wallet expenses keep increasing. As you can see, The Durbin Amendment, which is meant to help consumers, will instead have the cost from the loss of interchange fees passed along in other forms. And, the loss of revenue will greatly impact the bottom line of banking institutions. Who will be the bigger winner with this new amendment - the consumer, merchants or the banks? Will banks be able to lower the cost of credit to an amount that will entice consumers away from their debit cards and to use their credit cards again? I think it is still far too soon to tell. But, I think over the next few months, we will see consumers use payment methods in a new way as both consumers and banks come to a middle ground that will minimize risk levels for all parties. Consumers will still need to shop and bankers will still need their tools utilized. What are you doing to prepare for The Durbin Amendment?

By: Kennis Wong On the surface, it’s not difficult to define existing account fraud. Obviously, it is fraud perpetrated against an existing account. But the way I see it, existing account fraud can be broken down into four types. The first type is account takeover fraud, which is what most organizations think as the de facto existing account fraud. This is when a real consumer using his or her own identity to open a legitimate account, but the account later on get taken over by an identity fraudster. The idea is that when the account was first established, it was created by the rightful person. But somewhere along the way, the account and identity information were compromised.  The fraudster uses the compromised information to engineer their way into the account. The second type is impersonation. Impersonation is somewhat similar to account takeover in the sense that it is also misusing the victim’s account. But the difference is that impersonation is more of a one or few times misuses of the account. Examples are a fraudulent use of a credit card or wire transfer. These are the obvious categories. But I think we should also think about these other categories. My definition of existing account fraud also includes this third type – identity fraud that was undetected during application. In other words, an account is established based on stolen identity.  Many organizations call this “new account fraud”, which I don’t have a problem with. But I think it’s really also existing account fraud, because –  is this existing account? The answer is yes. Is this fraud? Absolutely. It’s not that difficult, is it? Similarly, I am including first-party fraud in existing account fraud as well. A consumer can use his or her own identity to open an account, with an intention to default after the account is established. Example is bust out fraud. You see that this is an expanded definition of existing account fraud, because my focus is on detection. No matter at what point and how identity fraud comes in, it becomes an account in your organization, and that is where we need to discover the fraud. But at the end of the day, it’s not too important how to categorize or name the fraud - whether it's application fraud, existing account fraud, first party fraud or third party fraud, as long as organizations understand them enough and have a good way to detect them. Read more blog posts on existing account fraud.

For communications companies, acquiring new accounts is an ongoing challenge. However, it is critical to remember that managing new and existing accounts – and their respective risks – is of tremendous importance. A holistic view of the entire customer lifecycle is something every communications organization can benefit from. The following article was originally posted by Mike Myers on the Experian Business Credit blog. Most of us are pretty familiar with credit reports and scores, but how many of you are aware of the additional tools available to help you manage the entire credit risk lifecycle? I talk to credit managers everyday and as we’re all trying to do more with less, it’s easy to forget that opening accounts is just the first step. Managing risk on these accounts is as critical, if not more so, than opening them. While others may choose to “ship and chase”, you don’t need to. Proactive alert/monitoring services, regular portfolio scoring and segmentation are key components that a successful credit department needs to employ in the constant battle against “bad” accounts. Use these tools to proactively adjust credit terms and limits, both positively and negatively. Inevitably some accounts will go bad, but using collection research tools for skip tracing and targeting services for debt collection will put you first in line for collections. A journey of 1,000 miles begins with a single step; we have tools that can help you with that journey and all can be accessed online.

By: Tracy Bremmer Score migration has always been a topic of interest among financial institutions. I can remember doing score migration analyses as a consultant at Experian for some of the top financial institutions as far back as 2004, prior to the economic meltdown. Lenders were interested in knowing if I could approve a certain number of people above a particular cut-off, and how many of them will be below that cutoff within five or more years. Or conversely, of all the people I’ve rejected because they were below my cut-off, how many of them would have qualified a year later or maybe even qualified the following month. We’ve done some research recently to gain a better understanding of the impact of score migration, given the economic downturn. What we found was that in aggregate, there is not a ton of change going on. Because as consumers move up or down in their score, the overall average shift tends to be minimal. However, when we’ve tracked this on a quarterly basis into score bands or even at a consumer level, the shift is more meaningful. The general trend is that the VantageScore® credit score “A” band, or best scorers, has been shrinking over time, while the VantageScore® credit score “D” & “F” bands, lower scorers, has grown over time. For instance, in 2010 Q4, the amount of consumers in VantageScore® credit score A was the lowest it has been in the past three years. Conversely, the number of consumers falling into the VantageScore® credit score “D” & “F” bands are the highest they have been during that same time period. This constant shift in credit scores, driven by changes in a consumer’s credit file, can impact risk levels beyond the initial point of applicant approval. For this reason, we recommend updating and refreshing scores on a very regular basis, along with regular scorecard monitoring, to ensure that risk propensity and the offering continue to be appropriately aligned with one another.

By: Kari Michel On March 18th 2011 the Federal Reserve Board approved a rule amending Regulation Z (Truth in Lending) to clarify portions of the final rules implementing the Credit CARD Act of 2009. Specific to ability to pay requirements, the new rule states that credit card applications generally cannot request a consumer's "household income" because that term is too vague to allow issuers to properly evaluate the consumer's ability to pay. Instead, issuers must consider the consumer's individual income or salary. The new ruling will be effective October 2011. Given the new direction outlined in the latest rules, we've been hard at work on developing 2 income models to support these regulatory obligations and enhance the underwriting and risk assessment process - Income InsightSM and Income Insight W2SM.  Both income models estimate an individual’s income based on an individual credit report and can be used in acquisition strategies, account management review and collection processes.  Why two models? Income InsightSM estimates the consumer’s total income, including wages, investments, rentals and other income. Income Insight W2SM estimates wages only.  Check them out - and let us know what you think! We want to hear from you.

By: Staci Baker It seems like every time I turn on the TV there is another natural disaster. Tsunami in Japan, tornadoes and flooding in the Mid-West United States, earthquakes and forest fires – everywhere; and these disasters are happening worldwide. They are not confined to one location. If a disaster were to happen near any of your offices, would you be prepared? Living in Southern California, this is something I think of often. Especially, since we are supposed to have had “the big one” for the past several years now. When developing a preparedness plan for a company, there are several things to take into consideration. Some are obvious, such as how to keep employees safe, developing steps for IT  to take to ensure data is protected , including an identity theft prevention program, and establishing contingency business plans in case a disaster directly hits your business and doors need to remain closed for several days, weeks, or …. But, what about the non-obvious items that should be included in a disaster preparedness plan? When a natural disaster hits, there is an increase in fraud. So much so, that after Hurricane Katrina battered the Gulf, the Hurricane Katrina Fraud Task Force, now known as the National Center for Disaster Fraud, was created. In addition to the items listed above, I recommend including the following. Create a plan that will put fraud alerts in place to minimize fraud.  Fraud alerts are not just to notify your clients when there is fraudulent activity on their accounts. Alerts should also be put in place to let you know when there is fraudulent activity within your own business as well. Depending on the type of disaster, delinquency rates may increase, since borrower funds may be diverted to other needs. Implement a disaster collections strategy, which may include modifying credit terms, managing credit risk, and loan loss provisioning. Although these are only a few things to be considered when developing a disaster preparedness plan, I hope it gets you thinking about what your company needs to do to be prepared. What are some things you have already done, or that are on your to do list to prepare your company for the next big event that may affect you?

Unless you’ve been hiding under a rock, you are undoubtedly aware that the 4G ship has sailed into port. The 4G network is a completely different technology as compared to 3G, the network it is replacing. 3G was fast, but 4G will set the world on fire. It’s kind of like the difference between a farm tractor and a Lamborghini. Rather than just being able to check email and (slowly) surf the net (as with 3G), 4G users will be able to watch live television and rip through online content like nobody’s business. So what does this mean for communications companies? Change device, change carrier? The big question for wireless providers is whether or not customers will change carriers as they upgrade to new, 4G-supported devices. The simple answer is, it depends. Customers who are currently under contract will not likely jump ship for the simple fact that it will cost too much. For example, let’s say I want to upgrade five devices. I can probably buy these less expensively by changing carriers (due to attractive introductory offers). However, if I have to cancel three contracts prior to term end to do it, it may cost me upwards of $1,000—probably more than I can save by changing carriers. For customers who are at the end of a contract term, upgrading to 4G presents a golden opportunity to change providers, if that’s something they’ve been considering. Wireless providers will obviously need to contact these customers well before their contracts are up and make them an offer they simply can’t refuse. Other concerns for wireless providers Obviously, key players in the market have invested a significant amount of money to develop the 4G infrastructure, and sooner or later they’re going to want to recoup those costs. Introductory offers will motivate many to upgrade to 4G, but will all these new/upgrade customers be able to pay the higher monthly bills that will likely come with their new 4G devices? While locking in all these new contracts will positively affect sales quotas, it will be more important than ever to assess these customers’ cash flow situations and credit-worthiness, so they don’t end up negatively affecting the bottom line. Concerns for other telecommunications companies One other interesting aspect to consider is this: With a 4G device, consumers can effectively create their own “hot spot.” So the question is, just as many people are dropping their landlines in favor of wireless, will 4G device users decide to drop their Internet providers? How about their cable television service? I intend to revisit this topic in 3-6 months to see whether early 4G adopters are in fact jumping to different carriers and/or dropping other services. What do you think might happen as 4G becomes the new normal? Leave a comment and share your thoughts.

Last week I attended the Merchant Risk Council’s 2011 MRC Annual e-Commerce Payments & Risk Conference.  I presented a session titled “Efficiency and Empowerment in Risk-based Authentication” with a client who has been able to use knowledge based authentication as a sales enabler - Home Shopping Network.  You might be wondering what I mean by this.  It is actually pretty simple:  Home Shopping Network already has a fraud prevention program in place and utilizes risk based authentication to send a percentage of orders to an outsort queue.  By using knowledge based authentication to further verify the true consumer, Home Shopping Network has been able to release an increased portion of those orders for shipping, increasing both revenue and the customer experience.  The paradigm shift was thinking of knowledge based authentication as a sale enabler, rather than just a fraud tool.  It was a great experience, to help share the story of this client’s success.   If you are interested in the Merchant Risk Council:  The Merchant Risk Council (MRC) is a merchant-led trade association focused on electronic commerce risk and payments.  They lead industry networking, education, benchmarking and advocacy programs to make electronic commerce more efficient, safe and profitable. For more information on the Home Shopping Network, visit: http://www.hsn.com

By: Kristan Frend I was recently pleased to see that the state I reside in, Minnesota finished in the bottom third of a state ranking.  Luckily the rankings weren’t about overall health (#6), high school graduation (#3), or SAT scores (#2); instead it was the Federal Trade Commission’s state identity theft complaint ranks.  Minnesota has just 49.2 complaints per 100,000 population, whereas the highest ranked state, Florida, as 114.8 complaints per 100,000 population.   The top three states leading identity theft consumer complaints (per 100,000 population) included Florida, Arizona, and California.   Besides warm sunshine and top-tier golf courses, what do these three states have in common?  According to the February 2011 RealtyTrac U.S. Foreclosure Market Report™, all three rank in the top 5 states for foreclosure, and two of the three (Florida and California) rank #49 and #50 in unemployment rates, according to a March 2011 report released by the Bureau of Labor Statistics.    On a national level unemployment rates and identity fraud incidence rates both improved from 2009 to 2010.  From 2009 to 2010, unemployment rates went from 10.0% to 9.4% while according to Javelin’s 2010 Annual Identity Fraud Survey Report, identity fraud incidence rates fell from 4.8% to 3.5%.    While it may be inaccurate to state that economic distress causes higher rates of identity fraud, there does seem to be a natural correlation between economic downswings and fraudulent activity.   As we move further into 2011, it will be interesting to see if identity fraud incidence rates will continue to decrease as unemployment and economic outlook is on the upward swing. 

I love a good analogy, and living in Southern California, lately I’ve been thinking a lot about earthquakes, and how lenders might want to start thinking like seismologists when considering the risk levels in their portfolios. Currently, scientists that study earthquakes review mountains of data around fault movement, tidal forces, even animal behavior, all in an attempt to find a concrete predictor of ‘the big one’. Small tremors are inputs, but the focus is on predicting and preparing for the large shock and impact of large earthquakes. Credit risk modeling, conversely, seems to focus on predicting the tremors, (risk scores that predict the risk of individual default) and less so the large-shock risk to the portfolio. So what are lenders doing to forecast ‘the big one’?  Lenders are building sophisticated models that contemplate the likelihood of the big event – developing risk models and econometric models that look at loan repayment, house prices, unemployment rates – all in an attempt to be ahead of the credit version of ‘the big one’.  This type of model and perspective is at a nascent stage for many lenders, but like the issues facing the people of Southern California, preparing for the big-one is an essential part of every lender’s planning in today’s economy.

As our newly elected officials begin to evaluate opportunities to drive economic growth in 2011, it seems to me that the role of lenders in motivating consumer activity will continue to be high on the list of both priorities and actions that will effectively move the needle of economic expansion. From where I sit, there are a number of consumer segments that each hold the potential to make a significant impact in this economy. For instance, renters with spotless credit, but have not been able or confident enough to purchase a home, could move into the real estate market, spurring growth and housing activity. Another group, and one I am specifically interested in discussing, are the so called ‘fallen angels’ - borrowers who previously had pristine track records, but have recently performed poorly enough to fall from the top tiers of consumer risk segments. I think the interesting quality of ‘fallen angels’ is not that they don’t possess the motivation needed to push economic growth, but rather the supply and opportunity for them to act does not exist. Lenders, through the use of risk scores and scoring models, have not yet determined how to easily identify the ‘fallen angel’ amongst the pool of higher-risk borrowers whose score tiers they now inhabit. This is a problem that can be solved though – through the use of credit attributes and analytic solutions, lenders can uncover these up-side segments within pools of potential borrowers – and many lenders are employing these assets today in their efforts to drive growth. I believe that as tools to identify and lend to untapped segments such as the ‘fallen angels’ develop, these consumers will inevitably turn out to be key contributors to any form of economic recovery.