Last week, a group of us came together for a formal internal forum where we had the opportunity to compare notes with colleagues, hear updates on the challenges clients are facing and brainstorm solutions to client business problems across the discipline areas of analytics, fraud and software.   As usual, fraud prevention and fraud analytics were key areas of discussion but what was also notable was how big a role compliance is playing as a business driver.  First party fraud and identity theft detection are important components, sure, but as the Consumer Financial Protection Bureau (CFPB) gains momentum and more teeth, the demand for compliance accommodation and consistency grows critical as well.  The role of good fraud management is to help accomplish regulatory compliance by providing more than just fraud risk scores, it can help to: Know Your Customer (KYC) or Customer Information Program (CIP) details such as the match results and level of matching across name, address, SSN, date of birth, phone, and Driver’s License. Understand the results of checks for high risk identity conditions such as deceased SSN, SSN more frequently used by another, address mismatches, and more. Perform a check against the Office of Foreign Asset Control’s SDN list and the details of any matches. And while some fraud solutions out there make use of these types of comparisons when generating a score or decision, they may not pass these along to their customers.  And just think how valuable these details can be for both consistent compliance decisions and creating an audit trail for any possible audits.  

The Fed’s Comprehensive Capital Analysis and Review (CCAR) and Capital Plan Review (CapPR) stress scenarios depict a severe recession that, although unlikely, the largest U.S. banks must now account for in their capital planning process.  The bank holding companies’ ability to maintain adequate capital reserves, while managing the risk levels of growing portfolios are key to staying within the stress test parameters and meeting liquidity requirements. While each banks’ portfolios will perform differently, as a whole, the delinquency performance of major products such as Auto, Bankcard and Mortgage continues to perform well.   Here is a comparison between the latest quarter results and two years ago from the Experian – Oliver Wyman Market Intelligence Reports.   Although not a clear indication of how well a bank will perform against the hypothetical scenario of the stress tests, measures such as Probability of Default, Loss Given Default and Exposure at Default to indicate a bank’s risk may be dramatically improved from just a few years ago given recent delinquency trends in core portfolios. Recently we released a white paper that provides an introduction to Basel III regulation and discusses some of its impact on banks and the banking system.  We also present a real business case showing how organizations turn these regulatory challenges into buisness opportunities by optimizing their credit strategies.   Download the paper - Creating value in challenging times: An innovative approach to Basel III compliance.  

By: Shannon Lois These are challenging times for large financial institutions. Still feeling the impact from the financial crisis of 2007, the banking industry must endure increased oversight, declining margins, and fierce competition—all in a lackluster economy. Financial institutions are especially subject to closer regulatory scrutiny. As part of this stepped-up oversight, the Federal Reserve Board (FRB) conducts annual assessments, including  “stress tests”, of the capital planning processes and capital adequacy of BHCs to ensure that these institutions can continue operations in the event of economic distress. The Fed expects banks to have credible plans, which are evaluated across a range of criteria, showing that they have adequate capital to continue to lend, even under adverse economic conditions. Minimum capital standards are governed by both the FRB and under Basel III. The International Basel Committee established the Basel accords to provide revised safeguards following the financial crisis, as an effort to ensure that banks met capital requirements and were not overly leveraged. Using input data provided by the BHCs themselves, FRB analysts have developed stress scenario methodology for banks to follow. These models generate loss estimates and post-stress capital ratios. The CCAR includes a somewhat unnerving hypothetical scenario that depicts a severe recession in the U.S. economy with an unemployment rate of 13%, a 50% drop in equity prices, and 21% decline in housing market. Stress testing is intended to measure how well a bank could endure this gloomy picture. Between meeting the compliance requirements of both BASEL III and the Federal Reserve’s Comprehensive Capital Analysis and Review (CCAR), financial institutions commit sizeable time and resources to administrative tasks that offer few easily quantifiable returns. Nevertheless—in addition to ensuring they don’t suddenly discover themselves in a trillion-dollar hole—these audit responsibilities do offer some other benefits and considerations.

You’ve heard of the websites that can locate sex offenders near you. Maybe you’ve even used them to scope out your neighborhood. But are those websites giving you the full picture? What if some sex offenders are flying under the radar? According to a recently released study from Utica College, more than 16 percent of sex offenders attempt to avoid mandatory monitoring by manipulating their identity. They use multiple aliases, use various personal identifying information such as social security numbers or date of birth, steal identity information from family members, manipulate their name, use family or friends’ addresses, alter their physical appearance or move to states with less stringent laws. Finding ways to slide under the radar means registered sex offenders could live near schools and playgrounds, or even gain unapproved employment. In one case, 29-year-old Neil Rodreick enrolled in at least four schools in Arizona, posing as a 12-year-old boy. He was finally caught when one school was unable to verify the information on his paperwork. A parallel study conducted by Utica demonstrated that awareness of identity manipulation of sex offenders is low. Of 223 law enforcement agencies surveyed in 46 states, only five percent knew of an identity manipulation case within their jurisdiction. Close to half (40 percent) of respondents said that they had zero cases, indicating that some may not even be aware of this issue. Clearly, additional monitoring is needed. Experian offers sex offender monitoring that conducts an in-depth search of sex offender registries in all 50 states, Washington D.C., Puerto Rico and Guam to help find and identify sex offenders. It also provides notifications when a sex offender is living in or moves to a customer’s neighborhood, or if a sex offender registers under a different name using a customer’s address. Monitoring identity and credit information is also another way to stay aware of sex offenders using one’s personal credentials. Do you feel that current sex offender tracking is working? Are there other tools or systems states should be using to track them? Visit our website for more information on identity protection products you can offer your customers.

Consumers want to hear about data breaches - Eighty five percent of respondents in a recent study say learning about the loss of their data is pertinent to them. However, when they do, 72 percent indicated that they are dissatisfied with the notification letters they receive. Companies need to take note of these findings because more than one-third of consumers who receive a notification letter contemplate ending their relationship with the company. Providing affected individuals with a membership in an identity protection product is extremely important since 58 percent of consumers consider identity protection to be favorable compensation after a breach. Learn five pitfalls to avoid in your notification letters and how Experian Data Breach Resolution can help. Source: Download the complete 2012 consumer study on data breach notification.

2011 was the 12th consecutive year that identity theft topped the list of FTC consumer complaints. Florida had the highest rate of complaints, followed by Georgia and California. Rank State Complaints per 100,000 population 1 Florida 179 2 Georgia 120 3 California 104 Learn how to detect and manage fraud activity while meeting regulatory requirements. Source: Consumer info.com infographic and FTC's Consumer Sentinel Network Data Book for January-December 2011.

The CFPB, the FTC and other regulatory authorities have been building up their presence in debt collections. Are you in the line of fire, or are you already prepared to effectively manage your riskiest accounts?  This year’s collections headlines show an increased need to manage account risk. Consumers have been filing suits for improper collections under the Fair Debt Collection Practices Act (FDCPA), the Servicemembers Civil Relief Act (SCRA), and the Telephone Consumer Protection Act (TCPA), to name a few. Agencies have already paid millions in fines due to increased agency scrutiny.   One collections mistake could cost thousands or even millions to your business—a cost any collector would hate to face. So, what can you do about better managing your regulatory risk?  1.       First of all, it is always important to understand and follow the collection regulations associated with your accounts. 2.       Secondly, follow the headlines and pay close attention to your regulatory authorities.  3.       Lastly, leverage data filtering tools to identify accounts in a protected status. The best solution to help you is a streamlined tool that includes filters to identify multiple types of regulatory risk in one place. At minimum, you should be able to identify the following types of risk associated with your accounts: Bankruptcy status and details Deceased indicator and dates Military indicator Cell phone type indicator Fraud indicators Litigious consumers Why wait? Start identifying and mitigating your risk as early in your collections efforts as possible. 

The FDIC has proposed a new rule that will change the way large lenders define and calculate risk for their FDIC Deposit Insurance Assessment. The revised definitions in the proposed rule rely on "probability of default" and eliminate all references to the traditional three-digit credit score used to calculate subprime exposure -- changing the way large banks calculate their FDIC assessments. This new ruling will allow lenders to uniformly assess risk in their portfolios--regardless of the scoring models they use. View a recent webinar to hear from a panel of experts on the "The New Subprime Definition: Who is subprime now?" Source: FDIC Proposed Ruling Announcement

Contributed by: David Daukus As the economy is starting to finally turn around albeit with hiccups and demand for new credit picking up, creditors are loosening their lending criteria to grab market share. However, it is important for lenders to keep lessons from the past to avoid the same mistakes. With multiple government agencies such as the CFPB, OCC, FDIC and NCUA and new regulations, banking compliance is more complex than ever. That said, there are certain foundational elements, which hold true. One such important aspect is keeping a consistent and well-balanced risk management approach.  Another key aspect is around concentration risk. This is where a significant amount of risk is focused in certain portfolios across specific regions, risk tiers, etc. (Think back to 2007/2008 where some financial institutions focused on making stated-income mortgages and other riskier loans.) In 2011, the Federal Reserve Board of Governors released a study outlining the key reasons for bank failures. This review focused mainly on 20 bank failures from June 29, 2009 thru June 30, 2011 where more in-depth reporting and analysis had been completed after each failure. According to the Federal Reserve Board of Governors, here are the four key reasons for the failed banks: (1) Management pursuing robust growth objectives and making strategic choices that proved to be poor decisions; (2) Rapid loan portfolio growth exceeding the bank’s risk management capabilities and/or internal controls; (3) Asset concentrations tied to commercial real estate or construction, land, and land development (CLD) loans; (4) Management failing to have sufficient capital to cushion mounting losses. So, what should be done? Besides adherence to new regulations, which have been sprouting up to save us all from another financial catastrophe, diversification of risk maybe the name of the game. The right mix of the following is needed for a successful risk management approach including the following steps: Analyze portfolios and needs Predict high risk accounts Create comprehensive credit policies Decision for risk and retention Refresh scores/attributes and policies So, now is a great time to renew your focus. Source: Federal Reserve Board of Governors: Summary Analysis of Failed Bank Reviews  (9/2011)

a.wpbutton:hover {text-decoration: none !important;} Please select from the below list of recent Experian white papers to gain more insight into topics relevant to your business needs and goals. Converting Information to Intelligence - Current Trends in Mitigating Small-Business Risk Through Analytics Download Now As former Chrysler CEO Lee Iacocca put it, “Even a correct decision is wrong when taken too late.” Portfolio managers who oversee small-business risks know this well. They realize it when they make a decision about approving or rejecting a loan request and recognize later the correct decision would have been clearer if they could have weighed additional data and used improved analytics. This white paper presents some of these latest trends affecting the small-business lending landscape. Specifically, it illuminates how companies are using the new robust data sources and analytic tools – from consortium data to rapid model customization – to maximize their interactions with small-business clients with greater accuracy. Creating Value In Challenging Times: An Innovative Approach To Basel III Compliance Download Now In this paper, we will provide an introduction to Basel III regulation and discuss some of its impact on banks and the banking system. We also will present a real business case showing how organizations turn these regulatory challenges into business opportunities by optimizing their credit strategies. Turning the Tide - Managing Troubled Portfolios Download Now The economy may be recovering and the credit picture improving, but lending institutions still find themselves coping with some troubled portfolios. Plus, they always need to be prepared to identify high-risk accounts. What they can discover is that turning around a challenged loan portfolio requires taking just a few basic steps. This white paper explores how in Arizona Federal Credit Union reversed its misfortunes to emerge from the economic crisis prosperous and with $30 million in profits, illuminating what lenders can do to manage troubled portfolios and reverse poor performance. Get To Know Your Customers: Account Linking and Advanced Customer Management For Utility Providers Download Now In this paper, we will explore the practice of customer management and key capabilities to improve effectiveness in a complex business environment. It will specifically look at opportunities within the utilities marketplace for account linking and deploying customer-level decisions to the business to help drive portfolio performance retain and grow profitability and strengthen customer relationships.   State of the U.S. Credit Markets - At Last, Signs of Real Recovery Download Now The economy’s recovery from the Great Recession may have started slowly, but it is accelerating – and it’s genuine. Economic indicators tell the story of improving business prospects. As the recovery begins to take shape, many consumers are now turning the corner with it and will present as viable candidates to grow your portfolio profitably. It’s difficult to find any solace in a recession, yet it can serve as an opportunity. 2012 will be the year for lenders to return to pre-recession strategies if they are to grow significantly. This economic rebound is real, and savvy lenders – just like those marathon runners and Tour de France bicyclists – recognize that it’s in the uphill stage of the race that the lead changes.   Home Equity Indicators with New Credit Data Methods for Improved Mortgage Risk Analytics This whitepaper describes new improvements in local housing market indicators and analytics derived from local-area credit and local real estate information. In the run up to the U.S. housing downturn and financial crisis, perhaps the greatest single risk management shortfall was poorly predicted home prices and borrower home equity. Understanding Automotive Loan Charge-off Patterns Can Help Mitigate Lender Risk Loan delinquency rates are one of the most important statistics to track in the automotive finance industry. If consumers are not repaying loans on time, it puts billions of dollars at risk. When high dollar volumes are at risk, it is a negative for everyone in the lending world, including consumers, automotive retailers and lenders themselves. While conditions have improved considerably the past few years, lenders still need to remain vigilant about where delinquencies are most likely to occur. It’s an unavoidable fact that some loans will have to be charged off. Understanding where and how these charge offs occur provides important learning for the industry. Experian Automotive has found several clear patterns that can help lenders better understand the root cause of loan delinquencies. Strategic Customer Management for Business Banking Portfolios Download Now This white paper explores business banking customer management and the benefits that can be realized from introducing a strategic approach. It will look at the features of a leading-edge approach to business banking customer management and provide practical insights on key areas.   Universe Expansion - Growth Strategies in the Evolving Consumer Market Download Now As the economy gains strength, lenders are engaging in an increasingly fierce competition to entice the best candidates to their portfolios and to grow their lending business. In waging this battle, however, many lenders are concentrating on the super-prime and prime consumer segments. Prospecting strategies currently in use often do not identify the right subpopulations within the near-prime segment. Specifically, there are prospects within the near-prime segment that exhibit low bad rates compared with the broader near-prime consumer base. It is imperative that lenders redefine their targeting/underwriting strategies to prospect and acquire in the near prime space. A variety of prospecting strategies are now available that compliment and expand on a lender’s current growth initiatives – now is the time to ensure that optimal strategies are in place and that opportunities within near-prime are not overlooked. Interested in more thought leadership? Visit our Business Resources page on  Experian.com

By: Stacy Schulman Earlier this week the CFPB announced a final rule addressing its role in supervising certain credit reporting agencies, including Experian and others that are large market participants in the industry. To view this original content, Experian and the CFPB - Both Committed to Helping Consumers. During a field hearing in Detroit, CFPB Director Richard Cordray’s spoke about a new regulatory focus on the accuracy of the information received by the credit reporting companies, the role they play in assembling and maintaining that information, and the process available to consumers for correcting errors. We look forward to working with CFPB on these important priorities. To read more about how Experian prioritizes these information essentials for consumers, clients and shareholders, read more on the Experian News blog. Learn more about Experian's view of the Consumer Financial Protection Bureau. ___________________ Original content provided by: Tony Hadley, Senior Vice President of Government Affairs and Public Policy About Tony: Tony Hadley is Senior Vice President of Government Affairs and Public Policy for Experian. He leads the corporation’s legislative, regulatory and policy programs relating to consumer reporting, consumer finance, direct and digital marketing, e-commerce, financial education and data protection. Hadley leads Experian’s legislative and regulatory efforts with a number of trade groups and alliances, including the American Financial Services Association, the Direct Marketing Association, the Consumer Data Industry Association, the U.S. Chamber of Commerce and the Interactive Advertising Bureau. Hadley is Chairman of the National Business Coalition on E-commerce and Privacy.

With the constant (and improving!) changes in the consumer credit landscape, understanding the latest trends is vital for institutions to validate current business strategies or make adjustments to shifts in the marketplace.  For example, a recent article in American Banker described how a couple of housing advocates who foretold the housing crisis in 2005 are now promoting a return to subprime lending. Good story lead-in, but does it make sense for “my” business?  How do you profile this segment of the market and its recent performance?  Are there differences by geography?  What other products are attracting this risk segment that could raise concerns for meeting a new mortgage obligation?   There is a proliferation of consumer loan and credit information online from various associations and organizations, but in a static format that still makes it challenging to address these types of questions. Fortunately, new web-based solutions are being made available that allow users to access and interrogate consumer trade information 24x7 and keep abreast of constantly changing market conditions.  The ability to manipulate and tailor data by geography, VantageScore risk segments and institution type are just a mouse click away.  More importantly, these tools allow users to customize the data to meet specific business objectives, so the next subprime lending headline is not just a story, but a real business opportunity based on objective, real-time analysis.

The pressures for both credit unions and banks, to generate returns to drive greater earnings are ever present. According to recent data released by the National Credit Union Administration, the nation's 7,019 federally-insured credit unions added 667,000 new members in the first quarter of 2012 to a record of 92.5 million. To offset these pressures, portfolio managers are aggressively expanding their policies and practices to drill more deeply and frequently into their portfolios. Increasingly, this requires the ability to trend consumer credit data, identify specific member metrics, and track those changes over time. Redefining the information your portfolios provide can by key to developing increased ROI. Learn how trended data can help you maximize your strategies and process to produce results in today's complex business environments. Source: How to drill deeper into your portfolio

As a scoring manager, this question has always stumped me because there was never a clear answer. It simply meant less than prime – but how much less? What does the term actually mean? How do you quantify something so subjective? Do you assign it a credit score? Which one? There were definitely more questions than answers. But a new proposed ruling from the FDIC could change all that – at least when it comes to large bank pricing assessments. The proposed ruling does a couple of things to bring clarity to the murky waters of the subprime definition. First, it replaces the term “subprime” with “high-risk consumer loans”. Then they go one better: they quantify high-risk as having a 20% probability of default or higher. Finally, something we can calculate! The arbitrary 3-digit credit score that has been used in the past to define the line between prime and subprime has several flaws. First of all, if a subprime loan is defined as having any particular credit score, it has to be for a specific version of a specific model at a specific time. That’s because the default rates associated to any given score is relative to the model used to calculate it. There are hundreds of custom-build and generic scoring models in use by lenders today – does that single score represent the same level of risk to all of them? Absolutely not. And even if all risk models were calibrated exactly the same, just assigning credit risk a number has no real meaning over time. We all know what scores shift, that consumer credit behavior is not the same today as it was just 6 years ago. In 2006, if a score of X represented a 15% likelihood of default, that same score today could represent 20% or more. It is far better to align a definition of risk with its probability of default to begin with! While it only currently applies to the large bank pricing assessments with the FDIC, this proposed ruling is a great step in the right direction. As this new approach catches on, we may see it start to move into other polices and adopted by various organizations as they assess risk throughout the lending cycle.

The cumulative effect of Basel III is expected to have a substantial impact on capital requirements. The total minimum regulatory capital will increase from 8 percent to 10.5 percent. For institutions that are considered "systematically important," an additional holding requirement may be imposed of up to 3.5 percent. Download our white paper to learn more about how your peers are reacting to Basel III and how Experian can help banks to optimize risk-weighted assets. Source: Creating value in challenging times: An innovative approach to Basel III compliance by Experian's Global Consulting Practice