Fintech

Using digital technology like a big bank How was your holiday? Are the chargebacks rolling in yet? It’s no secret - digital technology like mobile device usage has increased significantly over the years, making it a breeding ground for fraudsters. As credit unions continue to grow their membership, their fraud security treatments need to grow as well. Bigger banks are constantly updating their fraud tools and strategies to fight against cybercrime and, therefore, fraudsters are setting their eyes on credit unions. Even as I write this, fraudsters are searching and targeting credit unions that don’t have their mobile channel secured. They attempt to capitalize on any weakness or opportunity: Registering stolen cards to mobile wallets Taking over an account via mobile banking apps Using a retailers’ mobile app to make fraudulent payments Disabling the SIM card in the victim’s phone and diverting the one-time password sent through text message to their own phones These are clever ways to commit fraud. But credit unions are becoming wise to these new threats and are serious about protecting their members. They are incorporating device intelligence with a solid identity authentication service. This multi-layered approach is essential to securing mobile channels, and protecting your Credit Union from chargebacks. To learn more about our fraud solutions, click here.

Experian shares five trends and twists coming over the next 12 months, that could push new boundaries and in many cases improve the customer experience as it pertains to the world of credit and finance.

As 2016 comes to a close, many in the financial services industry are trying to assess the impact the Trump administration and Republican controlled Congress will have on regulatory issues. Answers to these questions may be clearer after President-elect Trump is inaugurated on Jan. 20. However, those in the federal regulatory environment are already exploring oversight and regulation of the FinTech and marketplace lending sector. Warning on alternative credit risk models Inquiries by federal and state policymakers over the past year have centered on how FinTech and marketplace lenders are assessing credit risk. In particular, regulators have asked about how credit models different from traditional credit scoring models and what, if any, new attributes or data are being incorporated into credit risk models for consumers and small businesses. On Dec. 2, Federal Reserve Governor Lael Brainard signaled that policymakers continue to be interested in this area during a wide-ranging speech on the potential opportunities and risks associated with FinTech. In particular, Brainard warned that “While nontraditional data may have the potential to help evaluate consumers who lack credit histories, some data may raise consumer protection concerns” and that nontraditional data “… may not necessarily have a broadly agreed upon or empirically established nexus with creditworthiness and may be correlated with characteristics protected by fair lending laws.” Brainard also suggested that there are transparency concerns with alternative scoring models, saying that “alternative credit scoring methods present new challenges that could raise questions of fairness and transparency” given that consumers may not always understand what data is used utilized and how it impacts a consumer’s ability to access credit at an affordable price. Look for regulators and Congress to continue to focus on the fairness and accuracy of new credit risk models and the data underpinning those models in debates surrounding FinTech and Marketplace lending in 2017. A national charter for FinTech? Earlier this month, the Office of the Comptroller of the Currency (OCC) announced that it was considering the creation of a national charter for FinTech lenders. There has long been speculation that the OCC would offer a national charter for FinTech. Analysts have suggested that the creation of a charter could help increase regulatory oversight of the growing market and also provide additional regulatory certainty for the emerging FinTech industry. The OCC’s proposal would create a special purpose national bank charter for FinTech businesses that are engaged in at least one of three core banking activities: receiving deposits; paying checks; or lending money. The OCC will be developing a formal agency policy for evaluating special purpose bank charters for Fintech companies that will designate the specific criteria that companies applying for a charter will have to meet for approval. OCC has suggested that this will likely focus on safety and soundness; financial inclusion; consumer protection; and community reinvestment. The OCC is collecting comments on the proposed policy through Jan. 15, 2017.  

You know what I love getting in the mail? Holiday cards, magazines, the occasional picturesque catalog. What I don’t open? Credit card offers, invitations to apply for loans and other financial advertisements. Sorry lenders, but these generally go straight into my shredder. Your well-intentioned efforts were a waste in postage, printing and fulfillment costs, and I’m guessing my mail consumption habits are likely shared by millions of other Americans. I’m a cusper, straddling the X and Millennial generations, and it’s no secret people like me have grown accustomed to living on our mobile devices, shopping online and managing our financial lives digitally. While many retailers have wised up to the trends and shifted marketing dollars heavily into the digital space, the financial services industry has been slow to follow. I’m hoping 2017 will be the year they adapt, because solutions are emerging to help lenders deliver firm offers of credit via email, display, retargeting and even social media platforms. There are multiple reasons to make the shift to digital credit marketing. It’s trackable. The beauty of digital marketing is that it can be tracked much more efficiently over direct mail efforts. You can see if offer emails are opened, if banners are clicked, if forms are completed and how quickly all of this takes place. In short, there are more touchpoints to measure and track, and more insights made available to help with marketing and offer optimization. It’s efficient. A solid digital campaign means you now have more flexibility. And once those assets start to deploy and you begin tracking the results, you can additionally optimize on the fly. Subject line not getting the open rate you want? Test a new one. Banners not getting clicked? Change the creative. A portion of your target audience not responding? Capture that feedback sooner rather than later, and strategize again. With direct mail, the lag time is long. With digital, the intelligence gathering begins immediately. It’s what many consumers want. They are spending 25% of their time on mobile devices. Research has found they check their phones and average 46 times per day. They are bouncing from screen to screen, engaging on desktops, tablets, smartphones, wearables and smart TVs. If you want to capture the eyeballs and mindshare of consumers, financial marketers must embrace the delivery of digital offers. Consumer behaviors have evolved, so must lenders. Sure, there is still a place for direct mail efforts, but it would be wasteful to not embrace the world of digital credit marketing and find the right balance between offline and online. It’s a digital world. It’s time financial institutions join the masses and communicate accordingly.

Technology sharing can unlock a more effective strategy in fighting fraud. Experian’s multi-layered and risk-based approach to fraud management is discussed as many businesses are learning that combining data and technology to strengthen their fraud risk strategies can help reduce losses. Evolving fraud schemes, changes in regulatory requirements and the advent of new digital initiatives make it difficult for businesses to manage all of the tools needed to keep up with the relentless pace of change.

Let’s play word association. When I say holiday season, what’s the first thing that comes to mind? Childhood memories. Connecting with family. A special dish mom used to make. Or perhaps it’s budgeting, debt and credit card spend. The holidays can be a stressful time of year for consumers, and also an important time for lenders to anticipate the aftermath of big credit card spend. According to a recent study by Experian and Edelman Intelligence: 48 percent of respondents felt thoughtful when thinking about the season 30 percent felt stressed 24 percent felt overwhelmed. Positive emotions are up across the board this year, which may be a good sign for retailers and bankcard lenders. And if emotion is an indicator of spending, 2016 is looking good. But while the holly-jolly sentiment is high, 56 percent of consumers say holiday shopping puts a strain on their finances. And, 43 percent of respondents said the stress of holiday shopping makes it difficult to enjoy the season. Regardless of stress, consumers are seeking ways to spend. Nearly half of respondents plan to use a major credit card to finance at least a portion of their holiday spending, second only to cash. With 44 percent of consumers saying they feel obligated to spend more than they can afford, it’s easy to see why credit cards are so important this time of year. Bankcard originations have fully rebounded from the recession, exceeding $104 billion in the third quarter of 2016, the highest level since the fourth quarter of 2007. While originations have rebounded, delinquency rates have remained at historic lows. The availability of credit is giving consumers more purchasing power to fund their holiday spending. But what happens next? As it turns out, many consumers resolve to consolidate all that holiday debt in the new year. Experian research shows that balance transfer activity reaches annual highs during the first quarter as consumers seek to simplify repayment and take advantage of lower interest rates. Proactive lenders can take advantage of this activity by making timely offers to consumers in need. At the same time, reactive lenders may feel the pain as balances transfer out of their portfolio. By identifying consumers who are most likely to engage in a card-to-card balance transfers, lenders can anticipate these consumer bankcard trends. The insights can then be used to acquire new customers and balances through prescreen campaigns, while protecting existing balances before they transfer out of an existing lender portfolio. With Black Friday and Cyber Monday behind us, the card balances are likely already rising. Now is the time for lenders to prepare for the January and February consolidations. Those hefty credit card statements are coming soon.

Which part of the country has bragging rights when it comes to sporting the best consumer credit scores? Drum roll please … Honors go to the Midwest. In fact, eight of the 10 cities with the highest consumer credit scores heralded from Minnesota and Wisconsin. Mankato, Minn., earned the highest ranking with an average credit score of 708 and Greenwood, Miss., placed last with an average credit score of 622. Even better news is that the nation’s average credit score is up four points; 669 to 673 from last year and is only six points away from the 2007 average of 679, which is a promising sign as the economy continues to rebound. Experian’s annual study ranks American cities by credit score and reveals which cities are the best and worst at managing their credit, along with a glimpse at how the nation and each generation is faring. “All credit indicators suggest consumers are not as ‘credit stressed’ — credit card balances and average debt are up while utilization rates remained consistent at 30 percent,” said Michele Raneri, vice president of analytics and new business development at Experian. As for the generational victors, the Silents have an average 730, Boomers come in with 700, Gen X with 655 and Gen Y with 634. We’re also starting to see Gen Z emerge for the first time in the credit ranks with an average score of 631. Couple this news with other favorable economic indicators and it appears the country is humming along in a positive direction. The stock market reached record highs post-election. Bankcard originations and balances continue to grow, dominated by the prime borrower. And the housing market is healthy with boomerang borrowers re-emerging. An estimated 2.5 million Americans will see a foreclosure fall of their credit report between June 2016 and June 2017, creating a new pool of potential buyers with improved credit profiles. More than 12 percent who foreclosed back in the Great Recession have already boomeranged to become homeowners again, while 29 percent who experienced a short sale during that same time have also recently taken on a mortgage. “We are seeing the positive effects of economic recovery with the rise in income and low unemployment reflected in how Americans are managing their credit,” said Raneri. Which means all is good in the world of credit. Of course there is always room for improvement, but this year’s 7th annual state of credit reveals there is much to be thankful for in 2016.

2017 data breach landscape Experian Data Breach Resolution releases its fourth annual Data Breach Industry Forecast report with five key predictions What will the 2017 data breach landscape look like? While many companies have data breach preparedness on their radar, it takes constant vigilance to stay ahead of emerging threats and increasingly sophisticated cybercriminals. To learn more about what risks may lie ahead, Experian Data Breach Resolution released its fourth annual Data Breach Industry Forecast white paper. The industry predictions in the report are rooted in Experian's history helping companies navigate more than 17,000 breaches over the last decade and almost 4,000 breaches in 2016 alone. The anticipated issues include nation-state cyberattacks possibly moving from espionage to full-scale cyber conflicts and new attacks targeting the healthcare industry. "Preparing for a data breach has become much more complex over the last few years," said Michael Bruemmer, vice president at Experian Data Breach Resolution. "Organizations must keep an eye on the many new and constantly evolving threats and address these threats in their incident response plans. Our report sheds a light on a few areas that could be troublesome in 2017 and beyond." "Experian's annual Data Breach Forecast has proven to be great insight for cyber and risk management professionals, particularly in the healthcare sector as the industry adopts emerging technology at a record pace, creating an ever wider cyber-attack surface, adds Ann Patterson, senior vice president, Medical Identity Fraud Alliance (MIFA). "The consequences of a medical data breach are wide-ranging, with devastating effects across the board - from the breached entity to consumers who may experience medical ID fraud to the healthcare industry as a whole. There is no silver bullet for cybersecurity, however, making good use of trends and analysis to keep evolving our cyber protections along with forecasted threats is vital." "The 72 hour notice requirement to EU authorities under the GDPR is going to put U.S.-based organizations in a difficult situation, said Dominic Paluzzi, co-chair of the Data Privacy & Cybersecurity Practice at McDonald Hopkins. "The upcoming EU law may just have the effect of expediting breach notification globally, although 72 hour notice from discovery will be extremely difficult to comply with in many breaches. Organizations' incident response plans should certainly be updated to account for these new laws set to go in effect in 2017." Omer Tene, Vice President of Research and Education for International Association of Privacy Professionals, added "Clearly, the biggest challenge for businesses in 2017 will be preparing for the entry into force of the GDPR, a massive regulatory framework with implications for budget and staff, carrying stiff fines and penalties in an unprecedented amount. Against a backdrop of escalating cyber events, such as the recent attack on Internet backbone orchestrated through IoT devices, companies will need to train, educate and certify their staff to mitigate personal data risks." Download Whitepaper: Fourth Annual 2017 Data Breach Industry Forecast Learn more about the five industry predictions, and issues such as ransomware and international breach notice laws in our the complimentary white paper. Click here to learn more about our fraud products, find additional data breach resources, including webinars, white papers and videos.

Experian is recognized as a leading security solution provider for fraud and identity solutions in order to protect customers and financial institutions

It’s been a wild ride for the financial services industry over the past eight years. After the mortgage meltdown, the Great Recession and a stagnant economy … well, one could say the country had seen better days. Did you watch The Big Short last winter? It all came crumbling down. And then President Barack Obama entered the scene. Change was needed. More oversight introduced. Suddenly, we had the Affordable Care Act, the Dodd-Frank Wall Street Reform Act and the creation of the Consumer Financial Protection Bureau (CFPB). Taxes were raised on the country’s highest earners for the first time since the late-1990s. In essence, the pendulum swung hard and fast to a new era of tightened and rigorous regulation. Fast forward to present day and we find ourselves on the cusp of transitioning to new leadership for the country. A new president, new cabinet, new leaders in Congress. What will it all mean for financial services regulations? It’s helpful to initially take a look back at the key regulations that have been introduced over the past eight years. Mortgage Reform: Long gone are the days of obtaining a quick mortgage.  New rules have required loan originators to verify and document the consumer’s income and assets, including employment status (if relied upon), existing debt obligations, mortgage-related obligations, alimony and child support. The CFPB has also expanded foreclosure protections for struggling borrowers and homeowners. Maintaining the health of the mortgage industry is important for the entire country, and updated rules have enhanced the safety and transparency of the mortgage market. Home values have largely recovered from the darkest days, but some question whether the underwriting criteria have become too strict. Combatting Fraud: The latest cyber-attack trends and threats come fast and furious. Thus, regulators are largely addressing the challenge by expecting banks to adhere to world-class standards from organizations such as the National Institute of Standards and Technology (NIST). The Federal Trade Commission (FTC) and the National Credit Union Administration (NCUA) implemented the Red Flags Rule in November 2008. It requires institutions to establish policies and procedures to identify and recognize red flags — i.e., patterns, practices or specific activities that indicate the possible existence of identity theft — that occur during account-opening activities, existing account maintenance and new activity on an account that has been inactive for two or more years. Loss Forecasting: The Dodd-Frank Act Requires the Federal Reserve to conduct an annual stress test of bank holding companies (BHCs), savings and loan holding companies, state member banks, and nonbank financial institutions. In October 2012, the Fed Board adopted the Comprehensive Capital Analysis and Review (CCAR) rules. This requires banks with assets of $50 billion or more to submit to an annual review centered on a supervisory stress test to gauge capital adequacy. In January 2016, Dodd-Frank Act Stress Testing (DFAST) was introduced, requiring bank holding companies with assets of $10 billion or more to conduct separate annual stress tests known as “company-run tests” using economic scenarios. Every year regulators expect to see continued improvement in stress-testing models and capital-planning approaches as they raise the bar on what constitutes an acceptable practice. CFPB: No longer the new kids on the block, the CFPB has transitioned to an entity that has its tentacles into every aspect of consumer financial products. Mortgage lending was one of their first pursuits, but they have since dug into “ability-to-pay underwriting” and servicing standards for auto loans, credit cards and add-on products sold through third-party vendors. Now they are looking into will likely be the next “bubble,” – student lending – and educating themselves about online marketplace lending. Data Quality: Expectations related to data quality, risk analytics, and regulatory reporting have risen dramatically since the financial downturn. Inaccuracy in data is costly and harmful, slows down the industry, and creates frustration. In short, it’s bad for consumers and the industry. It’s no secret that financial institutions rely on the accuracy of credit data to make the most informed decisions about the creditworthiness of their customers. With intense scrutiny in this area, many financial institutions have created robust teams to handle and manage requirements and implement sound policies surrounding data accuracy. --- This is merely a sliver of the multiple regulations introduced and strengthened over the past eight years. Is there a belief that the regulatory pendulum might take a swing to other side with new leadership? Unlikely. The agenda for 2017 largely centers on the need to improve debt collections practices, enhance access to credit for struggling Americans, and the need for ongoing monitoring of the fintech space. Only time will tell, but one thing is certain. Anyone involved in financial services needs to keep a watchful eye on the ever-evolving world of regulation and Washington.

In this new Telephone Consumer Protection Act (TCPA) era, calling your customers isn’t a thing of the past. It’s still okay to reach out to your clients by phone, whether to offer a new product or collect on an overdue bill. But strict compliance with TCPA rules is critical for any business that contacts customers by phone. Some of the very best ways you can protect yourself from TCPA exposure is to follow four steps when creating your dialing strategy: Customer consent: It’s important to maintain and update your customers’ contact preferences and consent to call them. Simply having a phone number on an application isn’t sufficient. Companies are required to have written permission, such as “I consent to calling my cell phone when there’s a problem …” Remember, permission may only be granted by the party who subscribes to the cellular service or who regularly uses that cell phone number. Landline or wireless?: Your database should also include the phone type for the telephone numbers you have for your customers. The dialing rules differ depending on the phone type, so it’s critical to know the type of phone you are calling or texting. Verify ownership: Ownership of cell phones should especially be validated to ensure the number hasn’t been reassigned and that the person who gave consent still owns the phone. One call can be made to a reassigned number with no liability, assuming you have no knowledge the number has changed. Repeating the action could lead to fines from $500 to $1,500 per infraction. Scrub Your Database: Have practices in place to remove any confirmed reassigned phone numbers from your database. This will help to improve your right-party contact rate and save you from potential TCPA headaches. No one disagrees that calling cell numbers is a risky business, but it can be done if you set the proper workflow in motion. Click here to learn more about Experian solutions that will help to reduce your TCPA compliance risk.

In this age of content and increasing financial education available to all, most entities are familiar with credit bureaus, including Experian. They are known for housing enormous amounts of data, delivering credit scores and helping businesses decision on credit. On the consumer side, there are certainly myths about credit scores and the credit report. But myths exist among businesses as well, especially as it pertains to the topic of reporting credit data. How does it work? Who’s responsible? Does reporting matter if you’re a small lender? Let’s tackle three of the most common myths surrounding credit reporting and shine a light on how it really is essential in creating a healthy credit ecosystem. Myth No. 1: Reporting to one bureau is good enough. Well, reporting to one bureau is definitely better than reporting to none, but without reporting to all three bureaus, there could be gaps in a consumer’s profile. Why? When a lender pulls a consumer’s profile to evaluate it for extending additional credit, they ideally would like to see a borrower’s complete credit history. So, if one of their existing trades is not being reported to one bureau, and the lender makes a credit pull from a different bureau to use for evaluation purposes, no knowledge of that trade exists. In cases like these, credit grantors may offer credit to your customer, not knowing the customer already has an obligation to you. This may result in your customer getting over-extended and negatively impacting their ability to pay you. On the other side, in the cases of a thin-file consumer, not having that comprehensive snapshot of all trades could mean they continue to look “thin” to other lenders. The best thing you can do for a consumer is report to all three bureaus, making their profile as robust as it can be, so lenders have the insights they need to make informed credit offers and decisions. Some believe the bureaus are regional, meaning each covers a certain part of the country, but this is false. Each of the bureaus are national and lenders can report to any and all. Myth No. 2: Reporting credit data is hard. Yes, accurate and timely data reporting requires a few steps, but after you get familiar with Metro 2, the industry standard format for consumer data reporting, choose a strategy, and register for e-Oscar, the process is set. The key is to do some testing, and also ensure the data you pass is accurate. Myth No. 3: Reporting credit data is a responsibility for the big institutions –not smaller lenders and companies. For all lenders, credit bureau data is vitally important in making informed risk determinations for consumer and small business loans. Large financial institutions have been contributing to the ecosystem forever. Many smaller regional banks and credit unions have reported consistently as well. But just think how much stronger the consumer credit profile would be if all lenders, utility companies and telecom businesses reported? Then you would get a true, complete view into the credit universe, and consumers benefit by having the most comprehensive profile --- Bottom line is that when comprehensive data on consumer credit histories is readily available, it’s a good thing for consumers and lenders. And the truth is all businesses - big and small - can make this a reality.

Prescriptive solutions: Get the Rx for your right course of action By now, everyone is familiar with the phrase “big data” and what it means. As more and more data is generated, businesses need solutions to help analyze data, determine what it means and then assist in decisioning. In the past, solutions were limited to simply describing data by creating attributes for use in decisioning. Building on that, predictive analytics experts developed models to predict behavior, whether that was a risk model for repayment, a propensity model for opening a new account or a model for other purposes. The next evolution is prescriptive solutions, which go beyond describing or predicting behaviors. Prescriptive solutions can synthesize big data, analytics, business rules and strategies into an environment that provides businesses with an optimized workflow of suggested options to reach a final decision. Be prepared — developing prescriptive solutions is not simple. In order to fully harness the value of a prescriptive solution, you must include a series of minimum capabilities: Flexibility — The solution must provide users the ability to make quick changes to strategies to adjust to market forces, allowing an organization to pivot at will to grow the business. A system that lacks agility (for instance, one that relies heavily on IT resources) will not be able to realize the full value, as its recommendations will fall behind current market needs. Expertise — Deep knowledge and a detailed understanding of complex business objectives are necessary to link overall business goals to tactical strategies and decisions made about customers. Analytics — Both descriptive and predictive analytics will play a role here. For instance, the use of a layered score approach in decisioning — what we call dimensional decisioning — can provide significant insight into a target market or customer segment. Data — It is assumed that most businesses have more data than they know what to do with. While largely true, many organizations do not have the ability to access and manage that data for use in decision-making. Data quality is only important if you can actually make full use of it. Let’s elaborate on this last point. Although not intuitive, the data you use in the decision-making process should be the limiting factor for your decisions. By that, I mean that if you get the systems, analytics and strategy components of the equation right, your limitation in making decisions should be data-driven, and not a result of another part of the decision process. If your prescriptive environment is limited by gaps in flexibility, expertise or analytic capabilities, you are not going to be able to extract maximum value from your data. With greater ability to leverage your data — what I call “prescriptive capacity” — you will have the ability to take full advantage of the data you do have. Taking big data from its source through to the execution of a decision is where prescriptive solutions are most valuable. Ultimately, for a business to lead the market and gain a competitive advantage over its competitors — those that have not been able to translate data into meaningful decisions for their business — it takes a combination of the right capabilities and a deep understanding of how to optimize the ecosystem of big data, analytics, business rules and strategies to achieve success.

Consumers want to pay less. This is true in retail and in lending. No big surprise, right? So in order for lenders to capitalize and identify the right consumers for their respective portfolios, they need insights. Lenders want to better understand what rates consumers have. They want to know how much interest their customers pay. They want to know if consumers within their portfolio are at risk of leaving, and they want visibility into new prospects they can market to in an effort to grow. Luckily, lenders can look to trade level fields to be in the know. These inferred data fields, powered by Trended Data,  allow lenders to offer products and terms that serve two purposes: First, their use in response models and offer alignment strategies drive better performance, ROI and life-time value. As noted earlier, consumers want to pay less, so if they are offered a better rate or money-saving offer, they’re more likely to respond. Second, they ultimately save consumers money in a way that benefits each consumer’s unique financial situation- overall savings on interest paid over the life of the loan, or consolidation of other debt often combined for a lower monthly payment. These trade level fields allow lenders to dig into various trends and insights surrounding consumers. For example, Experian data can identify big spenders and transactors (those who pay off their purchases every month). Research reveals these individuals love to be rewarded for how they use credit, demanding rewards, airline miles or other goodies for the spending they do. They also really like to be rewarded with higher credit lines, whether they use the increased line or not. Fail to serve these transactors in the right way and lenders could be faced with lackluster performance in the form poor response rates, booking rates, activation rates and early attrition. Thus, a little trade level insight can go a long way in helping lenders personalize products, offers and anticipate future financial needs. Knowing the profitability of a customer across all of their accounts is important, and accessing this intelligence in a seamless way is ideal. The data exists. For lenders, it’s just a matter of unlocking it, making those small, but meaningful changes and keeping a pulse on the portfolio. Together, these strategies can help lenders keep their best customers and acquire new ones that stick around longer.

The pendulum has swung again. The great recession brought a glacial freeze to access to capital. The thaw brought rapid, frictionless underwriting with an almost obsessive focus on growth and customer experience. Enter Marketplace Lenders and their more “flexible” approach to credit risk assessment. While much good has come from this evolution in financing, new challenges have surfaced – especially as it pertains to fraud prevention and credit risk management. Stacking has emerged as a particularly knotty problem in the small business lending space. Applicants have the opportunity to apply for and be approved for multiple loans in a matter of days or even hours.   Technology allows for underwriting that is at least somewhat automated and depositing often occurs within hours of approval. The speed of fulfillment is a boon for small businesses. However, it also makes it possible to be approved and draw down funds on multiple loans in quick succession. Core underwriting metrics, such as debt-to-income ratios and cashflow, are unreliable in the face of ratcheting debt from concurrent online business loans. This situation occurs because the window between the approval of the loan and delivery of the funds is much shorter than the timeframe to report the loan to credit reporting agencies and other third-party data suppliers. Not all lenders report small business loans, further compounding the problem.  Lenders’ risk and pricing strategies are hamstrung in the face of stacking, whether intentional on the part of the small business or not. If a struggling small business applies for credit and receives multiple loan offers, should we rely on their ability to resist the temptation to accept them all and use the funds wisely? No. The burden rests squarely on the credit provider to proactively address the problem. Technology-enabled frictionless underwriting underpins the online consumer loan space and facilitates a similar, yet subtly different stacking problem.  There are a large number of loan providers, with a spectrum of risk appetites and pricing strategies. This all but ensures that a consumer has access to additional loans at an ever-increasing interest rate. The underlying assumption, among the more mainstream, lower-rate providers, is that the consumer is disclosing all of their obligations – including any recent loans.  Although reporting in the consumer space is more robust and timely, it is still possible for an applicant to quickly access and draw funds on several loans within a very short timeframe, making it difficult for loan providers to get a full and complete picture of their capacity to repay the loan. The situation is further complicated by lenders at the higher risk, higher rate end of the market whose business models are structured to allow for, and perhaps even encourage, stacking by the consumer. Fortunately, there are a number of steps lenders can take to improve the situation: Contribute credit data to the credit reporting agencies. Know your customer, their industry, their market and underwrite appropriately. Develop a tailored underwriting approach that achieves a balance between frictionless customer experience and prudent credit and risk assessment. All applicants are not equal, and some require additional scrutiny and more time to underwrite. Understand the drivers and indicators of stacking. The latter point is worth emphasizing. The time to address stacking is prior to funding. This requires the lender to anticipate, identify and pre-empt stackers. There is no 100 percent foolproof remedy.  However, lenders can stack (pun-intended) the odds in their favor. For example, if an existing loan has a high balance and is delinquent, might that be an indicator of a propensity to stack? What if the business owner has applied for multiple loans, resulting in multiple inquiries, over a 45-day period? A proactive, data-driven anti-stacking strategy can yield positive results, reducing delinquency and losses. In combination with consistent comprehensive reporting to the bureaus, it can go a long way toward reducing the risk posed by this largely invisible threat.