Electronic signatures and their emerging presence in our Internet-connected world I had the opportunity to represent Experian at the eSignRecords 2015 conference in New York City last week. The concept of electronic signature, while not new, certainly has an emerging presence in the Internet-connected world — as evidenced by the various attendee companies that were represented, everything from home mortgages to automobiles. Much of the discussion focused on the legal aspects of accepting an electronic signature in lieu of an in-person physical signature. The implications of accepting this virtual stamp of approval were discussed, as well as the various cases that already have been tried in court. Of course, the outcome of those cases shapes the future of how to properly integrate this new form of authorization into existing business processes. Attendees discussed the basic concept of simply accepting a signature on an electronic pad as opposed to one written on a piece of paper. That act alone has many legal challenges even though it provides the luxury of in-person authentication through a face-to-face meeting. The complexities and risk increase exponentially when these services are extended over the Internet. The ability to sign documents virtually opens up a whole new world of business opportunities, and the concept certainly caters to the consumer’s need for convenience. However, the anonymity of the Internet presents the everyday challenge of balancing consumer expectations of greater ease of use with necessary fraud prevention measures. Ultimately, it always comes back to understanding who is actually signing that document. All of this highlights the need for robust authentication and security measures. As more and more legal documents and contracts are passed around virtually, the opportunity to properly screen and verify who has access to the documents gets more critical. Many organizations still rely on the tried-and-true method of knowledge-based authentication (KBA), while many others have called for its end. KBA continues to soldier on as an effective way to ensure that people on the other end of the wire are who they say they are by asking questions that — presumably — only they know the answers to. In most cases, KBA is viewed as a “check the box” step in the process to satisfy the lawyers. In certain cases, that’s all you need to do to ensure compliance with legal policy or regulatory requirements. It starts to get tricky is when there’s more on the line than just “check the box” actions. When the liability of first- or third-party fraud, becomes greater than simple compliance, it’s time to implement tighter security, while at the same time limiting the amount of friction caused by the process. Many in attendance discussed the need for layers of authentication based on the type of documents that are being processed and handled. This speaks directly to the point that one size does not fit all. As the industry matures and acceptance of e-signatures increases, so too does the need for more robust, flexible options in authentication. Another topic — that was quite frankly foreign to everyone we talked to — was the need for security around the concept of account takeover. When discussing this type of fraud, most attendees did not even consider this to be a hole in their strategy. Consider this fictional scenario. I’m responsible for mergers and acquisitions for my publicly traded company. I often share confidential information via electronic means, leveraging one of the many electronic signature solutions on the market. I become a victim of a phishing attack and unknowingly provide my login credentials to the fraudster. The fraudster now has access to every electronic document that I have shared with various organizations — most of which have been targets for mergers and acquisitions. Fraudsters are creative. They exploit new technologies — not because they’re trendsetters, but because oftentimes these new technologies fail to consider how fraudsters can benefit from the system. If you are considering adopting e-signature as a formal process, please consider implementing: Flexible levels of authentication based on the risk and liability of the documents that are being presented and what they are protecting FraudNet for Account Takeover, which enhances security around access to these critical documents to protect against data breaches Not only the needs and experiences of your own business, but customer needs as well to enable to the best possible customer interactions If you haven’t considered implementing e-signature technology into your business process, you should — but be sure to have your fraud team present when considering the implementation.

Experian® recently released the 2015 State of Credit report, which analyzes key credit metrics across the nation.

We all know that first party fraud is a problem. No one can seem to agree on the definitions of first party fraud and who is on the hook to find it, absorb the losses and mitigate the risk going forward. More often than not, first-party fraud cases and associated losses are simply combined with the relatively big “bucket” of credit losses. More importantly, the means of quickly detecting potential first-party fraud, properly segmenting it (as either true credit risk or malicious behavior) and mitigating losses associated with it usually lies within more general credit policies instead of with unique, targeted strategies designed to combat this type of fraud. In order to create a frame of reference, it’s helpful to have some quick — and yes, arguable — definitions: Synthetic identity: the fabrication of an identity with the intention of perpetrating fraudulent applications for, and access to, credit or other financial services Bust-out: the substantive building of positive credit history, followed by the intentional, high-velocity opening of several new accounts with subsequent line utilization and “never payment” Default payment: intentionally allowing credit lines to default to avoid payments Straight-roller: an account opened with immediate utilization followed by default without any attempt to make a payment Never pay: a form of straight-roller that becomes delinquent within the first few months of opening the account So what’s a risk manager to do? In my opinion, the best methods to consider in the fight against first-party fraud include analytical solutions that take multiple data points into consideration and focus on a risk-based approach. For my money, the four most important are: Models and scores developed with the proper set of identity and credit risk attributes derived from current and historic identity and account usage patterns (in other words, ANALYTICS) — Used at both the account opening and account management phases of the Customer Life Cycle, such analytics can be customized for each addressable market and specific first-party fraud threat The monitoring of individual identity elements at a portfolio level and beyond — This type of monitoring and LINK ANALYSIS allows organizations to detect the creation of synthetic identities Reasonable (e.g., one-to-one) identity and device associations over time versus a cluster of devices or coordinated attacks stemming from a single device — Knowing a customer’s device profile and behavioral usage with DEVICE INTELLIGENCE provides assurance that applications and account access are conducted legitimately Leveraging industry experts who have worked with other institutions to design and implement effective first-party fraud detection and loss-mitigation strategies — This kind of OPERATIONAL CONSULTING can save time and money in the long run and afford an opportunity to avoid mistakes By active use of these methods, you are applying a risk-based approach that will allow you to realize substantial savings in the forms of loss reduction and operational efficiencies associated with non-acquisition of high-risk first-party fraud applications, more effective credit line management of potentially high-risk accounts, better segmentation of treatment strategies and associated spend against high-risk identities, and removal of first-party fraud accounts from traditional collections processes that will prove futile. Download our recent White Paper, Data confidence realized: Leveraging customer intelligence in the age of mass data compromise, to understand how data and technology are needed to strengthen fraud risk strategies through comprehensive customer intelligence.

This month, it’s all about parties and gift giving and holiday traditions. Fast forward a month, however, and consumers will be in a different place. Today, they are spending. In a few weeks, the focus will be on paying down bills, or perhaps seeking solutions to consolidate or transfer balances. The good news for the economy is consumers are expected to spend more this holiday season – $830 on average, a huge jump from last year’s $720. Total retail is expected to increase 5.6 percent, while ecommerce (thanks Amazon Prime) should rise 13.9 percent. Credit card originations are also trending up more than 1 percent year-over-year as of the end of the third quarter of 2015. So what does this mean for lenders? Card utilization is peaking, creating the perfect scenario for many consumers to seek balance transfers, consolidate debt and search for competitive rates, especially if they’ve been leveraging high-interest cards. A recent analysis by NerdWallet revealed consumers are more interested in shopping with store credit cards than with traditional cards this season, putting them at particular risk of sky-high rates. A deeper look at utilization revealed super-prime consumers use less than 6 percent of their available credit limits, while consumers in the deep-subprime tier use nearly every dollar allotted. “Consumers spend billions during the holidays on high-interest credit cards,” said Kyle Matthies, Experian product manager. “Many of them have excellent credit, but struggle juggling multiple payments, which can lead to delinquencies. Credit card consolidation can provide relief by lowering interest rates and simplifying repayment.” Card issuers that remain passive during this window may find their portfolios at-risk as customers take advantage of seasonal offers. Competitors who capitalize on this peak season of balance transfers will likely be mailing out offers to acquire and grow their card portfolio, as well as protect their current card base. “As banks and credit unions finish out the calendar year, they might seek one last marketing push, so a balance-transfer campaign might be the ideal play,” said Matthies. “Still, to avoid blowing the budget, it helps to leverage data to know exactly who to target – both within and outside the card portfolio.” Specific models and/or tools can identify who to try to retain, as well as provide insights on whom to conquest from the outside. An index can additionally offer guidance on when to lower APRs, sweeten rewards and increase credit limits for specific consumers. The post-holiday balance-transfer wave is coming. The question is which lenders will be best prepared to protect and grow their respective card portfolios.

Hello from the other side ... While Adele scores big on the Billboard Hot 100 by crooning of coming to terms with a lover from the past, a new Experian “State of Credit” reveals we are officially on the “other side” of the recession – at least if you’re looking at the nation’s credit scores. While the bottom of the Great Recession was reached in the second quarter of 2009, steady job growth was not seen until 2011, and even since, some economists claim it has been a "Tortoise Recovery.” But key findings from Experian’s 6th annual study, ranking top and bottom cities across the nation in regards to credit, suggests the U.S. is strong. “If I were to give a grade to the overall picture of credit in the United States, I would give it an A minus,” said Michele Raneri, Experian’s vice president of analytics and new business development. “I’m optimistic about the state of credit as we are seeing more loans being extended, late payments are decreasing and consumers are continuing to gain more confidence in originating loans. There definitely is growth and momentum — we’re back to prerecession levels in nearly every category, which means lenders are in a prime position to capitalize on this market and foster business growth.” Which states topped the credit charts? As in previous years, Minnesota continues to shine with three of its cities — Mankato, Rochester and Minneapolis — leading with credit scores of 706, 705 and 704, respectively. Greenwood, Miss. and Albany, Ga. ranked the lowest with scores of 612 and 622. While still at the bottom of the list with a score of 612, Greenwood, Miss., residents did improve their score by three points, more than any other city in the bottom 10. Overall, the report reveals the national credit score increased by three points over the last year (and by five points since 2013) and the 10 cities with the highest credit scores in the nation increased their scores by an average of 1.8 points. Additionally, bankcards, retail cards and mortgage lending showed significant growth, making this year’s study an indicator of the nation’s confidence in the credit market. Just in time for the election year, this year’s study includes insight into how residents of these top and bottom metropolitan statistical areas (MSAs) identify politically. The study found that half of the highest-scoring cities have residents whose views skew more middle of the road, while residents of lower-scoring cities are more likely to lean conservative. The full lists of the top 10 and bottom 10 cities are featured (scores are rounded to the nearest whole number). Detailed study highlights include the following changes over the last year: The national VantageScore® credit score is up by three points, from 666 to 669. Bankcard lending continues to increase, with new bankcards up 7.7 percent. The average number of bankcards per consumer is up 2.8 percent to 2.24 cards. Retail card lending also is on the rise, with a 10.8 percent increase in new originations. The average number of retail cards per consumer is up 0.3 percent to 1.55 cards from last year and up by 7 percent since 2013. Instances of late payments (includes bankcard and retail) decreased by 4.4 percent over the last year and by 17.3 percent since the height of the recession in 2010. Average debt2 is up 2.1 percent to $29,093 per consumer. Mortgage originations increased by 42.5 percent. For a more complete look at the above cities as well as the other MSAs studied, visit http://www.livecreditsmart.com to view a fully interactive map and infographic. Purchase The Experian Market Intelligence Brief, a quarterly report that includes more than 70 charts and data trends on loan originations, outstanding loans and delinquency performance metrics spanning three years.

With Black Friday quickly approaching, a recent Experian study shows online Black Friday searches are already tracking ahead of last year. This October, the weekly search share for Black Friday averaged 12% higher than October 2014 and is expected to increase dramatically between now and Thanksgiving week. Top product searches for the week ending October 31, 2015 include: Marketers can design more successful campaigns and maximize rewards for both consumers and brands by staying on top of the latest search trends. >> Holiday Hot Sheet

Profile of an online fraudster I recently read a study about the profile of a cybercriminal. While I appreciate the study itself, one thing it lacks perspective on is an understanding of how identity data is being used to perpetrate fraud in the online channel. One may jump to conclusions about what is a good indicator for catching fraudsters. These very broad-brush observations may result in an overwhelming number of false positives without digging in deeper. Purchase value A single approach for understanding the correlation between purchase value and fraud does not work to best protect all businesses. Back in 2005, we saw that orders under $5 were great indicators of subsequent large-ticket fraud. For merchants that sell large-ticket items, such as electronics, those same rules may not be effective. To simply believe that the low dollar amount is the extent of the crime and not just a precursor to the real, bigger crime indicates a lack of understanding of how fraudsters work to manipulate a system. For some merchants, where fraudsters know they can go to do card testing against their business, low-dollar-amount rules may apply. However, for other businesses a different set of rules must be put into place. Time of day We have been tracking fraud time of day as a rule since 2004, but the critical point is a clear definition of which time of day. For the merchant, 3 a.m. is very different than 3 a.m. for a fraudster who is in Asia or Eastern Europe, where 3 a.m. merchant time is actually the middle of the online fraudster’s day. FraudNet is designed to identify the time from the user’s device and runs its rules from the user’s time. We find that every individual business will have a very specific threat profile. Businesses need to build their individual fraud strategy around their overall attack rate taking into account the strength of the defense and the ability to be flexible to accommodate the nuances for individual consumers. A general approach to fraud mitigation inevitably results in a system that begins to chase broad averages, which leads to excessive false positives and mediocre detection. That’s what drives us to do the job better. The proof of every fraud solution should lie in its ability to catch the most fraud without negatively impacting good customers.  

Understanding the Impact of New Marketplace Lending Regulations The online marketplace lending sector has enjoyed unprecedented growth these past few years. According to a recent Morgan Stanley research report, the volume of loans extended by online marketplace lenders in the United States has doubled every year since 2010, hitting $12 billion last year. Some analysts speculate this growth will continue at a compound annual rate of 47 percent through 2020. The market’s growth, coupled with new, disruptive lending models, is now prompting regulators in Washington to raise questions about the potential opportunities and challenges for consumers, small businesses, and the safety and soundness of our financial system. Last July, the Treasury Department issued a request for information to better understand the benefits and risks associated with new online lending platforms and other “fin-tech” startups. The Treasury’s RFI sought information about how these entities’ business models differ from traditional lenders, their impact on financially underserved consumers, and ultimately whether the regulatory framework should evolve to ensure the safe growth of this emerging marketplace. They were also interested in how online lenders were assessing credit risk of borrowers. Most comments the Treasury Department received from online lenders focused on the positive impact that innovation in financial services could have on consumers and small businesses. For example, in an open letter to the Treasury, Lending Club Founder and CEO Renaud Laplanche stated his company’s role in “bringing more transparency, removing friction, reducing systemic risk by requiring a match between assets and liabilities, and offering traditional banks … the opportunity to participate on our platform and benefit from the same cost reductions from which our other borrowers and investors benefit.” Laplanche emphasized the benefits to consumers by noting that “over 70 percent of borrowers on our platform report using their loan to pay off an existing loan or credit card balance and report that the interest rate on their Lending Club loan was an average of seven percentage points lower than they were paying on their outstanding debt or credit cards.” For small businesses, Laplanche explained how commercial loans less than $250,000 tend to be underserved by traditional lenders. “Bank loans from $100k to $250k have fallen 22 percent since 2007, during a period when bank loans of $1 million or greater increased by 56 percent,” he wrote. “Our platform’s automated processes allow us to provide smaller commercial loans that are less available more economically than traditional banks can.” Meanwhile, some commenters called for regulators to increase oversight of the marketplace to provide more certainty. In a joint comment letter, the American Bankers Association and Consumer Bankers Association argued that all lenders — regardless of medium by which they deliver loans — should operate under the same rules and standards. They highlighted the numerous consumer protections in place to protect borrowers — from transparency in pricing, to fair debt collection methods,  and data protection — and advocate for these protections to apply in all bank-like activities involving lending or servicing. But what about the Consumer Financial Protection Bureau (CFPB)? The CFPB will take a leadership role to ensure marketplace lenders comply with the fair lending and consumer financial protection laws that the CFPB has authority to enforce. The CFPB has not made any direct notice to the online lending marketplace specifically, but it did issue a notice in October 2014 saying it had no intention of bringing enforcement actions against companies that offer innovative financial products — so long as they benefit consumers. Meanwhile, it is also likely the Federal Trade Commission and state attorneys general will increase their focus on the online lending segment, especially as it relates to how products and services are marketed. The FTC held a symposium on Oct. 30 to examine online lead generation and consumer protection in the lending and education industries.  The FTC workshop raised questions about the potential consumer protection challenges of this advertising medium used heavily by online lenders. In particular, there were calls for greater transparency in the use of lead generation, including more information on the ways consumer data is collected through lead-gen websites and how it is used and shared. Online marketplace lenders should expect to stay under the regulatory spotlight – because that’s what success often brings.  The sector can avoid undue burdens by ensuring compliance with existing laws and adopting and following industry best practices. For more information, visit www.experian.com/marketplacelending.

According to a recent survey commissioned by VantageScore® Solutions, millennials cite being unscoreable as the main obstacle to credit access. Among the findings: One-third of millennials cannot obtain the credit they need Of those unable to obtain credit, 34% attribute it to lack of a credit score 49% of millennials agree that competition in the credit-scoring marketplace is beneficial Lenders can help this segment and open the gateway of credit by using advanced risk models that can accurately score consumers considered unscoreable by conventional risk models. >> Infographic: The Giant Credit Gap VantageScore® is a registered trademark of VantageScore Solutions, LLC.

What the EMV Shift means for you I recently facilitated a Webinar looking at myths and truths in the market regarding the EMV liability shift and what it means for both merchants and issuers. I found it to be a very beneficial discussion and wanted to take some time to share some highlights from our panel with all of you. Of course, if you prefer to hear it firsthand, you can download the archive recording here. Myth #1: Oct. 1 will change everything Similar to the hype we heard prior to Y2K, Oct. 1, 2015, came and went without too much fanfare. The date was only the first step in our long and gradual path to EMV adoption. This complex, fragmented U.S. migration includes: More than 1 billion payment cards More than 12 million POS terminals Four credit card networks Eighteen debit networks More than 12,000 financial institutions Unlike the shift in the United Kingdom, the U.S. migration does not have government backing and support. This causes additional fragmentation and complexity that we, as the payments industry, are forced to navigate ourselves. Aite Group predicts that by the end of 2015, 70 percent of U.S. credit cards will have EMV capabilities and 40 percent of debit cards will be upgraded. So while Oct. 1 may not have changed everything, it was the start of a long and gradual migration. Myth #2: Subscription revenues will plummet due to reissuances According to Aite, EMV reissuance is less impactful to merchant revenues than database breaches, since many EMV cards are being reissued with the same pan. The impact of EMV on reoccurring transactions is exaggerated in the market, especially when you look at the Update Issuer provided by the transaction networks. There still will be an impact on merchants, coming right at the start of the holiday shopping season. The need for consumer education will fall primarily on merchants, given longer lines at checkout and unfamiliar processes for consumers. Merchants should be prepared for charge-back amounts on their statements, which they aren’t used to seeing. Lastly, with a disparate credit and debit user experience, training is needed not just for consumers, but also for frontline cashiers. We do expect to see some merchants decide to wait until after the first of the year to avoid impacting the customer experience during the critical holiday shopping season, preferring to absorb the fraud in the interest of maximizing consumer throughout. Myth #3: Card fraud will decline dramatically We can look to countries that already have migrated to see that card fraud will not, as a whole, decline dramatically. While EMV is very effective at bringing down counterfeit card fraud, organized crime rings will not sit idly by while their $3 billion business disappears. With the Canadian shift, we saw a decrease in counterfeit card loss but a substantial increase in Card Not Present (CNP) fraud. In Canada and Australia, we also saw a dramatic, threefold increase in fraudulent applications. When criminals can no longer get counterfeit cards, they use synthetic and stolen identities to gain access to new, legitimate cards. In the United States, we should plan for increased account-takeover attacks, i.e., criminals using compromised credentials for fraudulent CNP purchases. For merchants that don’t require CVV2, compromised data from recent breaches can be used easily in an online environment. According to Aite, issuers already are reporting an increase in CNP fraud. Fraudsters did not wait until the Oct. 1 shift to adjust their practices. Myth #4: All liability moves to the issuer EMV won’t help online merchants at all. Fraud will shift to the CNP channel, and merchants will be completely responsible for the fraud that occurs there. We put together a matrix to illustrate where actual liability shifts and where it does not. Payments liability matrix Note: Because of the cost and complexity of replacing POS machines, gas stations are not liable until October 2017. For more information, or if you’d like to hear the full discussion, click here to view the archive recording, which includes a great panel question-and-answer session.

The Responsible Business Lending Coalition, a group of nonbank small-business lenders, recently announced a regulatory program designed to bring greater clarity to the industry’s pricing and consumer protections, including: The right to transparent pricing and terms The right to non-abusive products The right to responsible underwriting The right to fair treatment from brokers The right to inclusive credit access The right to fair collection practices Industry self-regulation is a good way for market leaders to demonstrate self-discipline and is preferable to legislative or regulatory changes because of its flexibility and ability to accommodate evolving market trends. >> Webinar: Online Marketplace Lending

Using bankcard utilization to forecast holiday spend It’s officially November, and like me, you’ve probably noticed all the holiday promotions in your mailbox and inbox. With only a brief window of holiday shopping available, it’s a retailer’s race to get consumer discretionary dollars. As we near the end of 2015, the U.S. economy continues to improve steadily, and consumers are cautiously optimistic about their financial well-being. National unemployment[i] is down to 5.1 percent, and while the Consumer Confidence Index®[ii] slipped to 97.6 in October, it is still higher than it was at the end of 2014. So will the U.S. consumer spend more this holiday season? One way to measure this behavior is through bankcard utilization rates — i.e., how much of their available credit consumers use. Overall, average bankcard utilization didn’t show much movement in Q3 2015, averaging 20.6 percent, compared with 20.3 percent the year before (a 1.5 percent increase).[iii] However, when we look at utilization rates by VantageScore® credit score tier, we see not only varying year-over-year (YOY) changes among consumer risk segments, but, more importantly, significant disparity in the overall usage of available credit.   Q3 2014 Q3 2015 YOY increase Super Prime (781-850) 5.5% 5.6% 1.8% Prime (661-780) 27.4% 27.8% 1.4% Near Prime (601-660 63.8% 64.5% 1.2% Subprime (501-600) 76.1% 78.4% 3.1% Deep Subprime (300-500) 94.7% 97.6% 3.1% Super-prime consumers use less than 6 percent of their available credit limits, while consumers in the deep-subprime tier use nearly every dollar allotted. So while we can’t yet determine how “black” this holiday season will be, we can predict that the lower a consumer’s credit tier, the more that consumer will rely on bankcards to fund his or her holiday shopping. For more credit and market insights, join Robert Stone and I for a Webinar, Unique insights on consumer credit trends and outlook for the remainder of 2015. [i]Bureau of Labor Statistics [ii]The Conference Board [iii]Experian IntelliView℠ VantageScore® is a registered trademark of VantageScore Solutions, LLC.

While walking through a toy store in search of the perfect gift for a nephew, I noticed the board game Risk, which touts itself as “The Game of Global Domination.” For those who are unaware, the game usually is won by players who focus on four key themes: Strategy — Before you begin the game, you need a strategy to attack new territories while defending your own Attack — While you have the option to sit back and defend your territory, it’s better to attack a weakened opponent Fortify — When you are finished attacking, it’s often best to fortify your position Alliances — While not an official part of the game, creating partnerships is necessary in order to win These themes also are relevant to the world of real-life fraud risk prevention. The difference is that the stakes are real and much higher. Let’s look at how these themes play out in real-life fraud risk prevention:  Strategy — Like in the game, you need a strategy for fraud risk detection and prevention. That strategy must be flexible and adaptable since fraudsters (your enemies) also continuously adapt to changing environments, usually at a much quicker, less bureaucratic pace. For example, your competitors (other countries) may improve their defenses, so fraudsters will mount a more focused attack on you. Fraudsters also may build alliances to attack you from different vectors or channels, resulting in a more sophisticated, comprehensive strike.  Attack — As the game begins, all players have access to all competitors (countries). This means that fraudsters might have the upper hand in a certain area of the business. You can sit back and try to defend the territory you already “own,” where fraudsters have no traction, but it’s best to be aggressive and attack fraudsters by expanding your coverage across all channels. For example, you might have plenty of controls in place to manage your Web orders (occupied territory), but your call center operations (opponents’ territory) aren’t protected, i.e., the fraudsters “own” this space. You need to attack that channel to drive fraudsters out.  Fortify — In the game, you can fortify your position after a successful move — that is, move more troops to your newly conquered territories. In real life, you always have the option to fortify your position, and you should constantly look for ways to improve your controls. You can’t afford to maintain on your current position, because fraudsters constantly are looking for weaknesses.  Alliances — In business, we often are hesitant to share information with our competitors. Fraudsters use this to their advantage. Just as fraudsters act in a coordinated fashion, so must we. Use all available resources and partners to shore up your defenses Leverage the power of consortium data Learn new methods from traditional competitors Always team up with internal and external partners to defend your territory If you apply these themes, you will be positioned for global domination in the fight against fraud risk. You can read more about fraud-prevention strategies in our recent ebook, Protecting the Customer Experience. As a side note, I’m always ready for a game of Risk, so contact me if you’re interested. But be forewarned — I’m competitive.

Winning the loyalty of millennials continues to be a key area of opportunity for financial institutions.

While marketers typically begin deploying Halloween emails in September, last-minute mailings receive the highest response.