Financial Services

Optimization is a very broad and commonly used term today and the exact interpretation is typically driven by one's industry experience and exposure to modern analytical tools. Webster defines optimize as: "to make as perfect, effective or functional as possible". In the risk/collections world, when we want to optimize our strategies as perfect as technology will allow us, we need to turn to advanced mathematical engineering. More than just scoring and behavioral trending, the most powerful optimization tools leverage all available data and consider business constraints in addition to behavioral propensities for collections efficiency and collections management. A good example of how this can be leveraged in collections is with letter strategies. The cost of mailing letters is often a significant portion of the collections operational budget. After the initial letter required by the Fair Debt Collection Practice Act (FDCPA) has been sent, the question immediately becomes: “What is the best use of lettering dollars to maximize return?” With optimization technology we can leverage historical response data while also considering factors such as the cost of each letter, performance of each letter variation and departmental budget constraints, while weighing the alternatives to determine the best possible action to take for each individual customer. n short, cutting edge mathematical optimization technology answers the question: "Where is the point of diminishing return between collections treatment effectiveness and efficiency / cost?"  

Currently, financial institutions focus on the existing customer base and prioritize collections to recover more cash, and do it faster. There is also a need to invest in strategic projects with limited budgets in order to generate benefits in a very short term, to rationalize existing strategies and processes while ensuring that optimal decisions are made at each client contact point. To meet the present challenging conditions, financial institutions increasingly are performing business reviews with the goal of evaluating needs and opportunities to maximize the value created in their portfolios.  Business reviews assess an organization’s capacity to leverage on existing opportunities as well as identifying any additional capability that might be necessary to realize the increased benefits. An effective business review covers the following four phases: Problem definition: Establish and qualify what the key objectives of the organization are, the most relevant issues to address, the constraints of the solution, the criteria for success and to summarize how value management fits into the company’s corporate and business unit strategies. Benchmark against leading practice: Strategies, processes, tools, knowledge, and people have to be measured using a review toolset tailored to the organization’s strategic objectives. Define the opportunities and create the roadmap: The elements required to implement the opportunities and migrating to the best practice should be scheduled in a phased strategic roadmap that includes the implementation plan of the proposed actions. Achieve the benefits: An ROI-focused approach, founded on experience in peer organizations, will allow analysis of the cost-benefits of the recommended investments and quantify the potential savings and additional revenue generated. A continuous fine-tuning (i.e. impact of market changes, looking for the next competitive edge and proactively challenge solution boundaries) will ensure the benefits are fully achieved. Today’s blog is an extract of an article written by Burak Kilicoglu, an Experian Global Consultant To read the entire article in the April edition of Experian Decision Analytics’ global newsletter e-news, please follow the link below: http://www.experian-da.com/news/enews_0903/Story2.html  

The Federal Trade Commission announced on April 30, one day before the intended May 1 Red Flags Rule enforcement deadline, a third extension of that deadline to August 1, 2009.  It's like showing up to class without your homework and the teacher is out sick that day….kind of.  The first extension from November 1, 2008 to May 1, 2009 seems to center on the general confusion among many market sectors around their level of coverage under the Identity Theft Red Flags Rule.  This latest delay seems to be a result of pushback from businesses with a lower risk of identity theft occurrences and a more "known" consumer base.So, it looks like we have at least three more months of preparation time.  This can be a good thing for all institutions regardless of their current Red Flag guidelines readiness status.  Those who scrambled to get a program in place now have time to fine tune it.  Those that were hoping for another extension have it.  Those who still question what their program should look like or if they are even covered can look forward to some more clarifying information out soon.Some key takeaways from the announcement:The FTC announcement does not impact other federal agency enforcement deadlines dating back to November 1, 2008.Specific to institutions that may have a perceived lower risk of identity theft, or businesses that generally know their customers personally, the Commission will be publishing more clarifying language and sample process (in the form of a template) to help those types of businesses comply with the Rule.Finally, this quote from the announcement sums it up:  “Given the ongoing debate about whether Congress wrote this provision too broadly, delaying enforcement of the Red Flags Rule will allow industries and associations to share guidance with their members, provide low-risk entities an opportunity to use the template in developing their programs, and give Congress time to consider the issue further,” FTC Chairman Jon Leibowitz said. 

By: Tom Hannagan As I'm preparing for traveling to the Baker Hill Solution Summit next week, I thought I would revisit the ideas of risk-based loan pricing. Risk Adjusted Loan Pricing – The Major Parts I have referred to risk-adjusted commercial loan pricing (or the lack of it) in previous posts. At times, I’ve commented on aspects of risk-based pricing and risk-based bank performance measurement,  but I haven’t discussed what risk-based pricing is -- in a comprehensive manner. Perhaps, I can begin to do that now, and in my next posts. Risk-based pricing analysis is a product-level microcosm of risk-based bank performance. You begin by looking at the financial implications of a product sale from a cost accounting perspective. This means calculating the revenues associated with a loan, including the interest income and any fee-based income. These revenues need to be spread over the life of the loan, while taking into account the amortization characteristics of the balance (or average usage for a line of credit). To save effort (and in providing good client relationship management), we often download the balance and rate information for existing loans from a bank’s loan accounting system. To “risk-adjust” the interest income, you need to apply a cost of funds that has the same implied market risk characteristics as the loan balance. This is not like the bank’s actual cost of funds for several reasons. Most importantly, there is usually no automatic risk-based matching between the manner in which the bank makes loans and the term characteristics of its deposits and/or borrowing. Once we establish a cost of funds approach that removes interest rate risk from the loan, we subtract the risk-adjusted interest expense from the revenues to arrive at risk-adjusted net interest income, or our risk-adjusted gross margin. We then subtract two types of costs. One cost includes the administrative or overhead expenses associated with the product. Our best practice is to derive an approach to operating expense breakdowns that takes into account all of the bank’s non-interest expenses. This is a “full absorption” method of cost accounting. We want to know the marginal cost of doing business, but if we just apply the marginal cost to all loans, a large portion of real-life expenses won’t be covered by resulting pricing. As a result, the bank’s profits may suffer. We fully understand the argument for marginal cost coverage, but have seen the unfortunate end-result of too many sales -- that use this lower cost factor -- hurt a bank’s bottom line. Administrative cost does not normally require additional risk adjustment, as any risk-based operational expenses and costs of mitigating operation risk are already included in the bank’s general ledger for non-interest expenses. The second expense subtracted from net interest income is credit risk cost. This is not the same as the bank’s provision expense, and is certainly not the same as the loss provision in any one accounting period.  The credit risk cost for pricing purposes should be risk adjusted based on both product type (usually loan collateral category) and the bank’s risk rating for the loan in question. This metric will calculate the relative probability of default for the borrower combined with the loss given default for the loan type in question. We usually annualize the expected loss numbers by taking into account a multi-year history and a one- or two-year projection of net loan losses. These losses are broken down by loan type and risk rating based on the bank’s actual distribution of loan balances. The risk costs by risk rating are then created using an up-sloping curve that is similar in shape to an industry default experience curve. This assures a realistic differentiation of losses by risk rating. Many banks have loss curves that are too flat in nature, resulting in little or no price differentiation based on credit quality. This leads to poor risk-based performance metrics and, ultimately, to poor overall financial performance. The loss expense curves are fine-tuned so that over a period of years the total credit risk costs, when applied to the entire portfolio, should cover the average annual expected loss experience of the bank. By subtracting the operating expenses and credit risk loss from risk-adjusted net interest income, we arrive at risk-adjusted pre-tax income. In my next post we’ll expand this discussion further to risk-adjusted net income, capital allocation for unexpected loss and profit ratio considerations.

1.       Portfolio Management – You should really focus on this topic in 2009.  With many institutions already streamlining the origination process, portfolio management is the logical next step.  While the foundation is based in credit quality, portfolio management is not just for the credit side.  2.       Review of Data (aka “Getting Behind the Numbers”) – We are not talking about scorecard validation; that’s another subject.  This is more general.  Traditional commercial lending rarely maintains a sophisticated database on its clients.  Even when it does, traditional commercial lending rarely analyzes the data.  3.       Lowering Costs of Origination – Always a shoe-in for a goal in any year!  But how does an institution make meaningful and marked improvements in reducing its costs of origination?  4.       Scorecard Validation – Getting more specific with the review of data.  Discuss the basic components of the validation process and what your institution can do to best prepare itself for analyzing the results of a validation.  Whether it be an interim validation or a full-sized one, put together the right steps to ensure your institution derives the maximum benefit from its scorecard. 5.       Turnaround Times (Response to Client) –Rebuild it.  Make the origination process better, stronger and faster.  No; we aren’t talking about bionics here -- nor how you can manipulate the metrics to report a faster turnaround time.  We are talking about what you can do from a loan applicant perspective to improve turnaround time. 6.       Training – Where are all the training programs?  Send in all the training programs!  Worry, because they are not here.  (Replace training programs with clowns and we might have an oldies song.)  Can’t find the right people with the right talent in the marketplace?  7.       Application Volume/Marketing/Relationship Management – You can design and execute the most efficient origination and portfolio management processes.   But, without addressing client and application volume, what good are they? 8.       Pricing/Yield on Portfolio – “We compete on service, not price.” We’ve heard this over and over again.  In reality, the sales side always resorts to price as the final differentiator.  Utilizing standardization and consistency can streamline your process and drive improved yields on your portfolio. 9.       Management Metrics – How do I know that I am going in the right direction?  Strategize, implement, execute, measure and repeat.  Learn how to set your targets to provide meaningful bottom line results. 10.    Operational Risk Management – Different from credit risk, operational risk and its management, operational risk management deals with what an institution should do to make sure it is not open to operational risk in the portfolio. Items totally in the control of the institution, if not executed properly, can cause significant loss. What do you think? As the end of April approaches, are these still hot topics in your financial institution?

The debate continues in the banking industry -- Do we push the loan authority to the field or do we centralize it (particularly when we are talking about small business loans)? A common argument for sending the loan authority to the field is the improved turnaround time for the applicant. However reality is that centralized loan authority actually provides a decision time almost two times faster than those of a decentralized nature.  The statistics supporting this fact are from the Small Business Benchmark Study created and published by Baker Hill, a Part of Experian, for the past five years. Based upon the 2008 Small Business Benchmark Study, those institutions with assets of $20 billion to $100 billion used only centralized underwriting and provided decisions within 2.5 days on average. In contrast, the next closest category ($2 billion to $20 billion in assets) took 4.4 days. Now, if we only consider the time it takes to make a decision (meaning we have all the information needed), the same disparity exists.  The largest banks using solely centralized underwriting took 0.8 days to make a decision, while the next tier ($2 billion to $20 billion) took an average 1.5 days to make a decision.  This drop in centralized underwriting usage between these two tiers was simply a 15 percent change. This means that the $20 billion to $100 billion banks had 100% usage of centralized underwriting while the $2 billion to $20 billion dropped only to 85% usage. Eighty-five percent is still a strong usage percentage, but it has a significant impact on turnaround time. The most perplexing issue is that the smaller community banks are consistently telling me that they feel their competitive advantages are that they can respond faster and they know their clients better than bigger, impersonal banks.  Based upon the stats, I am not seeing this competitive advantage supported by reality.  What is particularly confusing is that the small community banks, that are supposed to be closest to the client, take twice as long overall from application receipt to decision and almost three times as long when you compare them to the $20 billion to $100 billion category (0.8 days) to the $500 million to $2 billion category (2.2 days). As you can see - centralized underwriting works.  It is consistent, provides improved customer service, improved throughput, increased efficiency and improved credit quality when compared to the decentralized approach.   In future blogs, I will address the credit quality component.

I was recently asked in a comment, "What do we have to do to become compliant?" Great question.  There is not a single path to compliance when it comes to Red Flags compliance.  Effectively, an institution that has covered accounts under the Rule must implement both a written and operational Identity Theft Prevention Program.    The Red Flags Rule requires financial institutions and creditors to establish and maintain a written Program designed to detect, prevent and mitigate identity theft in connection with their covered accounts. The Program is a self-prescribed system of checks and balances that each financial institution and creditor implements to reach compliance with the Red Flags Rule. The goal of the provisions is to drive organizations to put into place a system that identifies patterns, practices and forms of activities that indicate the possible existence of identity theft. The provisions are not designed to steer the market to a “one size fits all” compliance platform. In essence, how businesses choose to meet the requirements will depend on the business size, operational complexity, customer transaction processes and risks associated with each of these characteristics.   A compliant Program must contain reasonable policies and procedures to address four mandatory elements: Identifying Red Flags applicable to covered accounts and incorporating them into the Program Detecting and evaluating the Red Flags included in the Program Responding to the Red Flags detected in a manner that is appropriate to the degree of risk they pose and Updating the Program to address changes in the risks to customers, and to the financial institution’s or creditor’s safety and soundness, from identity theft  The Red Flags Rule includes 26 illustrative examples of possible Red Flags financial institutions and creditors should consider when implementing a written Program. While implementation of any predetermined number of the 26 Red Flag examples is not mandatory, financial institutions and creditors should consider those that are applicable to their business processes, consumer relationships and levels of risk.   The Red Flags Rule requires financial institutions and creditors to focus on identifying Red Flags applicable to their account opening activities, existing account maintenance, and new activity on an account that has been inactive for two years or more. Some mandatory requirements include: Keeping a current, written Identity Theft Prevention Program that contains reasonable policies and procedures to identify, detect and respond to Red Flags, and keeping the Program updated Confirming that the consumer reports requested from consumer reporting agencies are related to the consumer with whom the financial institution or creditor are doing business Reviewing address discrepancies

The way in which you communicate with your customers really does impact the effectiveness of your collections operation. At the heart of any collections management operation is the quality of the correspondence and, in particular, the tone of voice adopted with the debtor. In short, what you say is important, but how you say it has a critical impact on its effectiveness. To help guide best practice in this area and provide areas for consideration when designing and implementing customer letters within a collections strategy, Experian commissioned a study to explore how consumers react to the words used to communicate with them about their debt. Key findings:An appropriate tone, clear detail of the consequences and a conciliatory approach are effective in the early phases of collection  Fees and charges and negative impacts on credit ratings were key motivators to pay Charges applied to an account for issuing a letter is disliked and likely to encourage many to contact the organisation to express their frustration After 3 months a strong emphasis on serious action is appropriate, including reference to legal action or debt collection agency involvement  Support should be offered, wherever possible, to aid those in difficulty  Letters should avoid an informal and patronising tone Lengthy letters have a low impact and are often not fully read, resulting in important messages being missed Use of red to highlight and focus on a specific point is effectiveUse of red to highlight more than one point is counter-effective To download the entire paper* and view other best practice briefings, follow the link below to the global Experian Decision Analytics collections briefing papers page: http://www.experian-da.com/resources/briefingpapers.html * Secure download account required. You can sign up for one today - FREE.

Due to the recent economic events, increased collections workloads are straining client infrastructures and resources. Most clients in North America operate their delinquent accounts on legacy collections systems that are inflexible and expensive to manage and maintain. A recent and abrupt spending shift has drifted toward collections tools, data, operational, efficient workflow and decisioning systems.On the information technology front, the collections workflow software industry is on the brink of a technology shift from legacy systems to modern next generation offerings that are typically coded in Java. Very few collections software vendors have actually released and implemented their next generation products and are preparing to do so over the next six to 12 months. Clients are aware of this technology shift and the interest of many end users has been heightened and many are actively researching and shopping.Reducing operational costs is an urgent priority for most financial institutions and utilities. Legacy systems do not allow management to change strategies or flows quickly or in a cost effective manner, which leaves most collections departments unable to keep up with rapidly changing environments and business objectives. Clients also have critical business needs to reduce losses, improve cash flow and promote customer satisfaction. Many clients maintain multiple systems and it is common that these disparate systems do not communicate with each other. Consolidating collections operations and databases into one central system is strongly desired and presents an opportunity for significant financial gain. 

Our current collections management landscape is seeing unprecedented consumer debt burdens: Total consumer debt o/s is at $14 trillion as of Jan ’09 Revolving debt o/s has reached $1 trillion The unemployment rate is at 7.6% and is expected to continue to rise Credit card and Home Equity Line Of Credit issuers reduced available credit by approximately $2 Trillion last year and more reductions are expected in 2009 There is a continuing rise in delinquencies and chargeoffs.  Here are some examples from our recent research: 8.5% of Prime Adjustable Rate Mortgages are now delinquent which shows an increase of 491% over this time last year 25% of all sub prime mortgages are now 60+ days delinquent Delinquencies for prime bankcard customers have increased 286% over the last 2 years 34% of all scoreable consumers (those who have sufficient trade information to calculate a score) now have a collection account. Compound these by a decline in the relative collectability of these accounts and you see: 9 million households now have negative equity 20% of 401(k) accounts have been tapped for loans (usually at a cost of 45% in penalties and fees to the account holder) According to the Federal Reserve, in late 2006 – at the height of the sub prime mortgage boom - the U.S. experienced a negative savings rate for the first time since the Great Depression.  

  I encourage all of you to have a look at this newly launched Federal Trade Commission Web site dedicated to the Red Flags Rule guidelines.  It is a good resource to that organizes the requirements of the Rule in a user-friendly manner.  It also looks to be an ongoing resource for the posting of updates and related commentary.  I suggest you make this site one of your bookmarks today:     The Federal Trade Commission has launched a Web site to help entities covered by the Red Flags Rule design and implement identity theft prevention programs. The Rule requires “creditors” and “financial institutions” to develop written programs to identify the warning signs of ID theft, spot them when they occur, and take appropriate steps to respond to those warning “red flags.”   Of particular interest, is the "Read the Guide" tab, where you can view and download the new FTC guide to Red Flag Rules.  For those in the telecommunications and utilities spaces, check out the "Publish the Articles" tab where you will find two bulletins on Red Flags in these arenas.  Enjoy.

This post continues the feature from my colleague and guest blogger, Mark Sofietti, Associate Process Architect in Advisory Services at Baker Hill, a part of Experian. In today’s market, the banking industry seems to be changing at a very rapid pace.  The current crisis that we are in, as an industry and as a nation, is forcing institutions to revisit risk management policies and procedures to make the appropriate changes needed to remain healthy and profitable.  However, the current crisis is not the only reason why institutions should focus on change management.  Change management needs to be appropriately handled in bad and good times.  Understanding change management is always a necessity to a well-run organization.  Whether it is a reorganization, a new software system, a new policy or moving to a new building, change can cause a great deal of stress and uncertainty -- but it can also cause benefits. So, as managers, you may be asking, “What can I do to ensure that positive changes are happening within my organization?  What are some of the items that I should consider when I am bringing about organizational change?” There are four necessary steps that need to be taken in order to improve the success of an initiative that is causing change to an institution. I covered two in my last post. Here are the additional steps. 3. Consider methods of change One method of change is the education of individuals about new ways of operating.  This method should be used when there is more resistance to change and when individuals lack a clear understanding or knowledge of the change being made.  Education may cause the implementation to take longer, but those involved will better understand the effects of the change. A second method is gathering participation from different levels and skill sets within the organizations.  Building a team should be used when there is the highest risk of failure due to change resistance and when more information needs to be gathered before an effective implementation can be completed. Negotiation is a method that is used when a group or person is going to be negatively affected by the change.  This method could alleviate the discomfort by giving the person or group some other benefit.  Negotiations could allow an organization to avoid resistance, but it may be very costly and time consuming to implement the change. The coercion change method is when a change is implemented with little room for diversion from the plan.  Employees are told what the change is going to be and they have to accept it.  This method should be used when speed is of the utmost importance, or if the change is not going to be easily accepted.  Most employees do not like this approach and it may cause resentment or it might cause staff members to leave. The final method of change uses manipulation, the conscious decision to share limited information about the change that is taking place.  This method should only be used when no other tactic will work, or if time or cost is major issues.  This approach is dangerous because it can lead to more problems in the future. 4. Create plan of action A plan should be created for the implementation of change to clearly address reservations and define the change strategy.  It should include internal and external audiences who can be affected by the change.  It is common to forget those who are indirectly impacted by the change -- and these audiences (customers, for example) may be the most important.  Objectives of the change need to be clearly outlined in the plan in order to understand how the new future state of the organization will look and operate.  The plan needs to be communicated to all those involved so that the transition can be understood and everyone can be held accountable.  The plan should be periodically revisited after implementation in order to review progress.  Creating a plan of action is a very important step to ensure that those who resisted the change do not revert back to their old habits. Achieving change is not an easy process, especially when time is not on your side.  If you take a second look at the change that you are trying to implement and do the necessary planning, you have a greater chance for success than if you or your organization fails to fully evaluate the consequences. Effective change management should be part of any financial risk management process. Take charge of your institution’s future through a calculated approach to change management and your organization will be in a better position for the next change that is coming around the bend.

I've previously posted content around an overall risk-based approach to Red Flags compliance. I also want to keep current in mentioning the use of Knowledge Based Authentication (KBA) as an effective component in an Identity Theft Prevention Program.  I get this question often:  "Is KBA a fraud detection tool or a verification tool?"  Short answer:  "It's both."Beyond fraud detection and prevention, KBA implementation can provide your program real returns in a few key areas:Reconciliation of initially detected "Red Flag" conditionsKBA allows you to positively pass consumers who may have some level of initial authentication challenge or high-risk condition.  The reality of identity verification is that regardless of all the data assets potentially leveraged, there are still those cases in which a good consumer identity continues to pose challenges to basic verification checks.Cost reduction in referral / reconciliation processesKBA can replace more subjective decision making and process invocation, turning instead to objective question presentation and performance to drive overall decisioning.Customer experienceConsumers are more willing today than ever before to participate in a KBA session, and most would prefer this activity over provision of documentary evidence, for example.KBA, when used in combination with strong analytics and comprehensive authentication results, can be valued tool in your overall Red Flags Identity Theft Prevention program.

Behavioral scoring is one of the most important tools that allow collections management and account management groups to evaluate accounts in an efficient and cost-effective manner. Although behavioral models are developed in a similar manner as new applicant models, there are several key differences that make behavioral models a better choice for many account management applications and collections workflow systems:By using only internal master file data as opposed to external credit bureau data, for example, accounts can be regularly evaluated without incremental cost. The most common practices are to score accounts on a weekly or monthly basis, which allows for quick strategic responses to a customer’s change in behavior. Frequent evaluations can result in automated or manual actions such as the acceleration or deceleration of collections efforts, adjusting credit limits and changing terms and conditions.The performance definitions of behavioral scores are very specific to each strategy and task, and it is typically not advised to use models in applications for which they were not designed. For example, a new applicant model definition of “bad” may be a high probability of charge off during the initial term of a line of credit. For collections strategy, a more appropriate bad definition might be the likelihood of an account rolling to the next delinquency bucket, regardless of the age of the account. Behavioral models also have a much shorter outcome period of three to four months versus new applicant models that forecast over one to two years. Since behaviors with one creditor can typically be recognized more quickly than with all lending institutions associated with a particular debtor, behavioral models provide a unique and timely evaluation of the ongoing risk once the account is already on the books. 

Regardless of the specific checks and overall processes incorporated into your Red Flags Identity Theft Prevention Program, the use of an automated decisioning strategy or strategies will allow you to: Deliver consistent responses based on objective authentication results, while eliminating subjectivity often found in more manual review processes.  Save time and money associated with a manual review process currently attributed to Red Flag Rule referrals.  Provide examiners a detailed process flow including decision elements.  Create champion / challenger flows to test, compare and alter new strategies over time.  Revise, over time, the specific elements used in your decisioning to appropriately weight each from a fraud detection and/or compliance perspective. Experian's consumer authentication products provide hosted decisioning strategies that alleviate the burden on our clients associated with maintenance and development of those processes.  Whether you facilitate your own strategies or use a service provider's hosted strategies, it is important to ensure you are maximizing their ability to balance pass rates, fraud detection and compliance requirements.