Financial Services
April is Financial Literacy Month, a special window of time dedicated to educating Americans about money management. But as stats and studies reveal, financial education is always needed.
Whether it is an online marketplace lender offering to refinance the student loan debt of a recent college graduate or an online small-business lender providing an entrepreneur with a loan when no one else will, there is no doubt innovation in the online lending sector is changing how Americans gain access to credit. This expanding market segment takes great pride in using “next-generation” underwriting and credit scoring risk models. In particular, many online lenders are incorporating noncredit information such as income, education history (i.e., type of degree and college), professional licenses and consumer-supplied information in an effort to strike the right balance between properly assessing credit risk and serving consumers typically shunned by traditional lenders because of a thin credit history. Regulatory concerns The exponential growth of the online lending sector has caught the attention of regulators — such as the U.S. Treasury Department, the Federal Deposit Insurance Corporation, Congress and the California Business Development Office — who are interested in learning more about how online marketplace lenders are assessing the credit risk of consumers and small businesses. At least one official, Antonio Weiss, a counselor to the Treasury secretary, has publicly raised concerns about the use of so-called nontraditional data in the underwriting process, particularly data gleaned from social media accounts. Weiss said that “just because a credit decision is made by an algorithm, doesn’t mean it is fair,” citing the need for lenders to be aware of compliance with fair lending obligations when integrating nontraditional credit data. Innovative and “tried and true” are not mutually exclusive Some have suggested the only way to assuage regulatory concerns and control risk is by using tried-and-true legacy credit risk models. The fact is, however, online marketplace lenders can — and should — continue to push the envelope on innovative underwriting and business models, so long as these models properly gauge credit risk and ensure compliance with fair lending rules. It’s not a simple either-or scenario. Lenders always must ensure their scoring analytics are based upon predictive and accurate data. That’s why lenders historically have relied on credit history, which is based upon data consumers can dispute using their rights under the Fair Credit Reporting Act. Statistically sound and validated scores protect consumers from discrimination and lenders from disparate impact claims under the Equal Credit Opportunity Act. The Office of the Comptroller of the Currency guidance on model risk management is an example of regulators’ focus on holding responsible the entities they oversee for the validation, testing and accuracy of their models. Marketplace lenders who want to push the limit can look to credit scoring models now being used in the marketplace without negatively impacting credit quality or raising fair lending risk. For example, VantageScore® allows for the scoring of 30 million to 35 million more people who currently are unscoreable under legacy credit score models. The VantageScore® credit score does this by using a broader, deeper set of credit file data and more advanced modeling techniques. This allows the VantageScore® credit score model to capture unique consumer behaviors more accurately. In conclusion, online marketplace lenders should continue innovating with their own “secret sauce” and custom decisioning systems that may include a mix of noncredit factors. But they also can stay ahead of the curve by relying on innovative “tried-and-true” credit score models like the VantageScore® credit score model. These models incorporate the best of both worlds by leaning on innovative scoring analytics that are more inclusive, while providing marketplace lenders with assurances the decisioning is both statistically sound and compliant with fair lending laws. VantageScore® is a registered trademark of VantageScore Solutions, LLC.
A step towards making checking accounts available to all, recent actions leave unresolved regulatory actions regarding “affordable” checking access.
Identity management traditionally has been made up of creating rigid verification processes that are applied to any access scenario. But the market is evolving and requiring an enhanced Identity Relationship Management strategy and framework. Simply knowing who a person is at one point in time is not enough. The need exists to identify risks associated with the entire identity profile, including devices, and the context in which consumers interact with businesses, as well as to manage those risks throughout the consumer journey. The reasoning for this evolution in identity management is threefold: size and scope, flexible credentialing and adaptable verification. First, deploying a heavy identity and credentialing process across all access scenarios is unnecessarily costly for an organization. While stringent verification is necessary to protect highly sensitive information, it may not be cost-effective to protect less-valuable data with the same means. A user shouldn’t have to go through an extensive and, in some cases, invasive form of identity verification just to access basic information. Second, high-friction verification processes can impede users from accessing services. Consumers do not want to consistently answer multiple, intrusive questions in order to access basic information. Similarly, asking for personal information that already may have been compromised elsewhere limits the effectiveness of the process and the perceived strength in the protection. Finally, an inflexible verification process for all users will detract from a successful customer relationship. It is imperative to evolve your security interactions as confidence and routines are built. Otherwise, you risk severing trust and making your organization appear detached from consumer needs and preferences. This can be used across all types of organizations — from government agencies and online retailers to financial institutions. Identity Relationship Management has three unique functions delivered across the Customer Life Cycle: Identity proofing Authentication Identity management Join me at Vision 2016 for a deeper analysis of Identity Relationship Management and how clients can benefit from these new capabilities to manage risk throughout the Customer Life Cycle. I look forward to seeing you there!
Who sports higher scores, less debt and more on-time payments? According to Experian’s latest analysis, women take the credit title.
Tax return fraud occurs when an attacker uses a consumer’s stolen SSN and other information to file a tax return, often claiming a significant refund.
It’s hard to remember a world without online lenders. Today, fintech players continue to pop up, making it easier to cross-shop loans and land instant approvals. Gone are the days of lengthy applications and waiting to hear if you’ve scored the latest credit line or personal loan. Consumers, especially with top-tier credit, can easily seek lower monthly payments or consolidate another loan with a cash-out option. Whatever the need, there’s a lender ready to serve. Strike that. There’s actually two or three lenders waiting to serve you. In fact, a recent Experian data pull revealed an increasing share of personal loan balances is actually going to lenders outside of the traditional banks and credit union space (they still own the lion’s share of the business). In 2013 (Q4), these more non-traditional lenders had 15.36 percent of personal loan balances. In Q4 of 2015, that number increased to 27.26 percent. The personal loan business today is just over $222.9 billion in outstanding balances. As the competition heats up, lenders will need to diversify, stand out and provide more value to consumers. Those that engage with new, value-added services, and deliver timely, personalized needs-based messages will capture the greatest share of the market. Here is a sampling of ways to draw consumers in and deliver the value they seek in a financial institution: Be Transparent Lending Club, one of the original peer-to-peer lenders and currently the biggest in terms of dollars funded, continues to grow by providing consumers and investors with transparency, good loan terms and speed. Prosper, on the other hand, recently acquired an app that allows their customers to track spending, budget and monitor their credit. They plan to leverage this technology in the near future and offer it to customers and investors for free. Research reveals Millennials especially are looking to tech and free services to manage their personal finances. A recent Experian survey focused on Millennials and credit revealed 48 percent have used free financial services, like Mint, to manage their finances. Additionally, 57 percent use on average three financial apps. Know Your Customers Payoff uses survey data to segment their customers into roughly 10 financial personalities based on how they use and think about their debt. These personality types are used to tailor marketing messages and customer service conversations about how to improve their financial situation. Their site features a quiz, Discover the Secrets of Your Financial Personality, helping consumers and Payoff understand more about trends attached to spending, saving and managing money. Offer Solutions for Debt Consolidation Even after consumers consolidate debt and pay it off successfully, unforeseen expenses, unexpected life events, evolving spending habits and the increasing cost-of-living expenses mean there will always be a market for debt consolidation solutions. Understanding consolidation credit account behavior is mandatory for lenders looking to stand out and stay ahead of the consolidation needs of consumers. Having visibility to consumers’ interest rates, revolving loan balances and the remaining months on existing loans provides unique ways to segment and engage clients with need-based offers. Consumer-tailored messages during the prospecting, acquisition and account management stages of the relationship sets the stage for repeat business. The research is clear. Individuals are willing to switch brands if they feel a different provider will better meet their needs. Lenders – in both the traditional and fintech spaces – should not expect many chances when it comes to getting it right with consumers. Fail to keep them engaged and you’ll fail to keep them. Period. Learn more about identifying profitable consolidation candidates, check out Experian’s annual Vision Conference in May.
Time to dust off those compliance plans and ensure you are prepared for the new regulations, specifically surrounding the Military Lending Act (MLA). Last July, the Department of Defense (DOD) published a Final Rule to amend its regulation implementing the Military Lending Act, significantly expanding the scope of the existing protections. The new, beefed-up version encompasses new types of creditors and credit products, including credit cards. While the DOD was responsible for implementing the rule, enforcement will be led by the Consumer Financial Protection Bureau (CFPB). The new rule became effective on October 1, 2015, and compliance is required by October 3, 2016. Compliance, however, with the rules for credit cards is delayed until October 3, 2017. While there is no formal guidance yet on what federal regulators will look for in reviewing MLA compliance, there are some insights on the law and what’s coming. Why was MLA enacted? It was created to provide service members and their dependents with specific protections. As initially implemented in 2007, the law: Limited the APR (including fees) for covered products to 36 percent; Required military-specific disclosures, and; Prohibited creditors from requiring a service member to submit to arbitration in the event of a dispute. It initially applied to three narrowly-defined “consumer credit” products: Closed-end payday loans; Closed-end auto title loans; and Closed-end tax refund anticipation loans. What are the latest regulations being applied to the original MLA implemented in 2007? The new rule expands the definition of “consumer credit” covered by the regulation to more closely align with the definition of credit in the Truth in Lending Act and Regulation Z. This means MLA now covers a wide range of credit transactions, but it does not apply to residential mortgages and credit secured by personal property, such as vehicle purchase loans. One of the most significant changes is the addition of fees paid “for a credit-related ancillary product sold in connection with the credit transaction.” Although the MAPR limit is 36 percent, ancillary product fees can add up and — especially for accounts that carry a low balance — can quickly exceed the MAPR limit. The final rule also includes a “safe harbor” from liability for lenders who verify the MLA status of a consumer. Under the new DOD rule, lenders will have to check each credit applicant to confirm that they are not a service member, spouse, or the dependent of a service member, through a nationwide CRA or the DOD’s own database, known as the DMDC. The rule also permits the consumer report to be obtained from a reseller that obtains such a report from a nationwide consumer reporting agency. MLA status for dependents under the age of 18 must be verified directly with the DMDC. Experian will be permitted to gain access to the DMDC data to provide lenders a seamless transaction. In essence, lenders will be able to pull an Experian profile, and MLA status will be flagged. What is happening between now and October 2016, when lenders must be compliant? Experian, along with the other national credit bureaus, have been meeting with the DOD and the DMDC to discuss providing the three national bureaus access to its MLA database. Key parties, such as the Financial Services Roundtable and the American Bankers Association, are also working to ease implementation of the safe harbor check for banks and lenders. The end goal is to enable lenders the ability to instantly verify whether an applicant is covered by MLA by the Oct. 1, 2016 compliance date. --- If you have inquiries about the new Military Lending Act regulations, feel free to email MLA.Support@experian.com or contact your Experian Account Executive directly. Next Article: A check-in on the latest Military Lending Act news
Every portfolio has a set of delinquent customers who do not make their payments on time. Truth. Every lender wants to collect on those payments. Truth. But will you really ever be able to recover all of those delinquent funds? Sadly, no. Still, financial institutions often treat all delinquent customers equally, working the account the same and assuming eventually they’ll get their funds. The sentiment to recover is good, but a lot of collection resources are wasted on customers who are difficult or impossible to recover. The good news? There is a better way. Predictive analytics can help optimize the allocation of collection resources by identifying the most effective accounts to prioritize to your best collectors, do not contact and proceed to legal actions to significantly increase the recovery of dollars, and at the same time reduce collection costs. I had the opportunity to recently present at the annual Debt Buyer Association’s International Conference and chat with my peers about this very topic. We asked the room, “How many of you are using scoring to determine how to work your collection accounts?” The response was 50/50, revealing many of these well-intentioned collectors are working themselves too hard, and likely not getting the desired returns. Before you dive into your collections work, you need to respond to two questions: Which accounts am I going to work first? How am I going to work those accounts? This is where scoring enters the scene. A scoring model is a statistical algorithm that assigns a numerical expression based on known information to predict an unknown future outcome. You can then use segmentation to group individuals with others that show the same behavior characteristics and rank order groups for collection strategies. In short, you allow the score to dictate the collection efforts and slope your expenses based on the propensity and expected amount of the consumer to pay. This will inform you on: What type, if any, skip trace tactic you should use? If you should purchase additional data? What intensity you should work the account? With scoring, you will see different performances on different debts. If you have 100 accounts you are collecting on, you’ll then want to find the accounts where you will have the greatest likelihood to collect, and collect the most dollars. I like to say, “You can’t get blood from a stone.” Well the same holds true for certain accounts in your collections pile. Try all you like, but you’ll never recoup those dollars, or the dollars you do recoup will be minimal. With a scoring strategy, you can establish your “hit list” and find the most attractive accounts to collect on, and also match your most profitable accounts with your best collectors. My message to anyone managing a collections portfolio can be summed up in three key messages. You need to use scoring in your business to optimize resources and increase profits. The better data that goes into your model will net you better performance results. Get a compliance infrastructure in place so you can ensure you are collecting the right way and stay out of trouble. The beauty of scores is they tell you what to do. It will help you best match resources to the most profitable accounts, and work smarter, not harder. That’s the power of scoring.
Compliance definitions for LOA, CIP, FACTA, KYC
Large number of HELOC loans will soon be entering their HELOC end of draw period, giving lenders an opportunity for new finance options
Accuracy matters. It matters in dart throwing, math calculations, and now more than ever, in data reporting. The Consumer Financial Protection Bureau (CFPB) issued a bulletin on Feb. 3 warning banks and credit unions that if they fail to meet accuracy obligations when reporting negative account histories to credit reporting companies, the result could be bureau action. As noted in the Fair Credit Reporting Act (FCRA) section 623, data furnishers have an obligation to ensure the accuracy of the information furnished to a Credit Reporting Agency (CRA). Violation of these rules presents a variety of risks, and the regulatory agencies have enforced harsh consequences. Avoiding penalties is certainly a strong incentive for data furnishers to implement a formal compliance management system and data quality program. But there are additional benefits to ensuring accuracy – most notably keeping customers happy and loyal, and maintaining a reputable brand in the marketplace. Today’s consumers increasingly understand the impact of credit scoring and data reporting, and recognize a poor credit score can impact their lives in major ways. Credit is tied to so many milestone financial moments. Securing mortgage loans, auto loans, obtaining low-interest rate interest credit cards and securing private student loans can all be derailed with an unfavorable and inaccurate credit report. Not to mention credit reports can influence one’s eligibility for rental housing, setting premiums for auto and homeowners insurance in some states, or determining whether to hire an applicant for a job. To properly serve customers who simply expect a fair and accurate representation of their financial history, data furnishers must be able to guarantee the credibility of their reported data. Those organizations that cannot ensure accuracy put their reputation at risk and may lose a customer’s trust and business. “Consumers should not be sidelined out of the basic banking services they need because of the flaws and limitations in a murky system,” Cordray said in the bulletin. “People deserve to have more options for access to lower-risk deposit accounts that can better fit their needs.” The CFPB has handled more than 105,000 credit-reporting complaints in its short history, making credit reporting the third most-complained-about consumer issue. By far the most common types of credit-reporting issues identified by consumers is incorrect information on credit report (77 percent).* Certainly these mistakes are not made intentionally. But speak to a consumer battling an inaccuracy, especially someone in the midst of applying for credit for a specific need, and frustrations can soar quickly. All lenders are advised to maintain a full 360-degree view of data reporting, from raw data submissions to the consumer credit profile. Better data input equals fewer inaccuracies. Additionally, there are comprehensive reporting solutions available to assess the accuracy of consumer credit data. The regulatory environment will without a doubt continue to be a hot topic in the media, fueled by announcements such as these by the CFPB, so lenders should take note and identify processes to ensure complete and utter accuracy. It matters in so many ways, so it’s best to make data reporting a priority now, if it’s not already. Source: CFPB August 2015 Monthly Complaint Report
Providing the essentials to credit risk managers
Basically, a blockchain is a permissionless, distributed database that maintains a growing list of records in a linear, chronological ledger.
Data Privacy Day reminds consumers to protect their privacy online — and for organizations to ensure they are vigilant in their fight against fraud.