By: Heather Grover In my previous entry, I covered how fraud prevention affected the operational side of new DDA account opening. To give a complete picture, we need to consider fraud best practices and their impact on the customer experience. As earlier mentioned, the branch continues to be a highly utilized channel and is the place for “customized service.” In addition, for retail banks that continue to be the consumer's first point of contact, fraud detection is paramount IF we should initiate a relationship with the consumer. Traditional thinking has been that DDA accounts are secured by deposits, so little risk management policy is applied. The reality is that the DDA account can be a fraud portal into the organization’s many products. Bank consolidations and lower application volumes are driving increased competition at the branch – increased demand exists to cross-sell consumers at the point of new account opening. As a result, banks are moving many fraud checks to the front end of the process: know your customer and Red Flag guideline checks are done sooner in the process in a consolidated and streamlined fashion. This is to minimize fraud losses and meet compliance in a single step, so that the process for new account holders are processed as quickly through the system as possible. Another recent trend is the streamlining of a two day batch fraud check process to provide account holders with an immediate and final decision. The casualty of a longer process could be a consumer who walks out of your branch with a checkbook in hand – only to be contacted the next day to tell that his/her account has been shut down. By addressing this process, not only will the customer experience be improved with increased retention, but operational costs will also be reduced. Finally, relying on documentary evidence for ID verification can be viewed by some consumers as being onerous and lengthy. Use of knowledge based authentication can provide more robust authentication while giving assurance of the consumer’s identity. The key is to use a solution that can authenticate “thin file” consumers opening DDA accounts. This means your out of wallet questions need to rely on multiple data sources – not just credit. Interactive questions can give your account holders peace of mind that you are doing everything possible to protect their identity – which builds the customer relationship…and your brand.
By: Heather Grover In past client and industry talks, I’ve discussed the increasing importance of retail branches to the growth strategy of the bank. Branches are the most utilized channel of the bank and they tend to be the primary tool for relationship expansion. Given the face-to-face nature, the branch historically has been viewed to be a relatively low-risk channel needing little (if any) identity verification – there are less uses of robust risk-based authentication or out of wallet questions. However, a now well-established fraud best practice is the process of doing proper identity verification and fraud prevention at the point of DDA account opening. In the current environment of declining credit application volumes and approval across the enterprise, there is an increased focus on organic growth through deposits. Doing proper vetting during DDA account openings helps bring your retail process closer in line with the rest of your organization’s identity theft prevention program. It also provides assurance and confidence that the customer can now be cross-sold and up-sold to other products. A key industry challenge is that many of the current tools used in DDA are less mature than in other areas of the organization. We see few clients in retail that are using advanced fraud analytics or fraud models to minimize fraud – and even fewer clients are using them to automate manual processes - even though more than 90 percent of DDA accounts are opened manually. A relatively simple way to improve your branch operations is to streamline your existing ID verification and fraud prevention tool set: 1. Are you using separate tools to verify identity and minimize fraud? Many providers offer solutions that can do both, which can help minimize the number of steps required to process a new account; 2. Is the solution realtime? To the extent that you can provide your new account holders with an immediate and final decision, the less time and effort you’ll spend after they leave the branch finalizing the decision; 3. Does the solution provide detail data for manual review? This can help save valuable analyst time and provider costs by limiting the need to do additional searches. In my next post, we’ll discuss how fraud prevention in DDA impacts the customer experience.
The definition of account management authentication is: Keep your customers happy, but don’t lose sight of fraud risks and effective tools to combat those risks. In my previous posting, I discussed some unique fraud risks facing institutions during the account management phase of their customer lifecycles. As a follow up, I want to review a couple of effective tools that allow you to efficiently minimize fraud losses during post-application: Knowledge Based Authentication (KBA) — this process involves the use of challenge/response questions beyond "secret" or "traditional" internally derived questions (such as mother's maiden name or last transaction amount). This tool allows for measurably effective use of questions based on more broad-reaching data (credit and noncredit) and consistent delivery of those questions without subjective question creation and grading by call center agents. KBA questions sourced from information not easily accessible by call center agents or fraudsters provide an additional layer of security that is more impenetrable by social engineering. From a process efficiency standpoint, the use of automated KBA also can reduce online sessions for consumers, and call times as agents spend less time self-selecting questions, self-grading responses and subjectively determining next steps. Delivery of KBA questions via consumer-facing online platforms or via interactive voice response (IVR) systems can further reduce operational costs since the entire KBA process can be accommodated without call center agent involvement. Negative file and fraud database – performing checks against known fraudulent and abuse records affords institutions an opportunity to, in batch or real time, check elements such as address, phone, and SSN for prior fraudulent use or victimization. These checks are a critical element in supplementing traditional consumer authentication processes, particularly in an account management procedure in which consumer and/or account information may have been compromised. Transaction requests such as address or phone changes to an account are particularly low-hanging fruit as far as running negative file checks are concerned.
--by Andrew Gulledge Intelligent use of features Question ordering: You want some degree of randomization in the questions that are included for each session. If a fraudster (posing as you) comes through Knowledge Based Authentication, for two or three sessions, wouldn’t you want them to answer new questions each time? At the same time, you want to try to use those questions that perform better more often. One way to achieve both is to group the questions into categories, and use a fixed category ordering (with the better-performing categories being higher up in the batting line up)—then, within each category, the question selection is randomized. This way, you can generally use the better questions more, but at the same time, make it difficult to come through Knowledge Based Authentication twice and get the same questions presented back to you. (You can also force all new questions in subsequent sessions, with a question exclusion strategy, but this can be restrictive and make the “failure to generate questions” rate spike.) Question weighting: Since we know some questions outperform others, both in terms of percentage correct and in terms of fraud separation, it is generally a good idea to weight the questions with points based on these performance metrics. Weighting can help to squeeze out some additional fraud detection from your Knowledge Based Authentication tool. It also provides considerable flexibility in your decisioning (since it is no longer just “how many questions were answered correctly” but it is “what percentage of points were obtained”). Usage Limits: You should only allow a consumer to come through the Knowledge Based Authentication process a certain number of times before getting an auto-fail decision. This can take the form of x number of uses allowable within y number of hours/days/etc. Time out Limit: You should not allow fraudsters to research the questions in the middle of a Knowledge Based Authentication session. The real consumer should know the answers off the top of their heads. In a web environment, five minutes should be plenty of time to answer three to five questions. A call center environment should allow for more time since some people can be a bit chatty on the phone.
Account management fraud risks: I “think” I know who I’m dealing with… Risk of fraudulent account activity does not cease once an application has been processed with even the most robust authentication products and tools available. These are a few market dynamics are contributing to increased fraud risk to existing accounts: - The credit crunch is impacting bad guys too! Think it’s hard to get approved for a credit account these days? The same tightened lending practices good consumers now face are also keeping fraudsters out of the “application approval” process too. While that may be a good thing in general, it has caused a migratory focus from application fraud to account takeover fraud. - Existing and viable accounts are now much more appealing to fraudsters given a shortage of application fraud opportunities, as financial institutions have reduced solicitation volume. A few other interesting challenges face organizations with regards to an institution’s ability to minimize fraud losses related to existing accounts: - Social engineering — the "human element" is inherent in a call center environment and critical from a customer experience perspective. This factor offers the opportunity for fraudsters to manipulate representatives to either gain unauthorized access to accounts or, at the very least, collect consumer and account information that may help them perpetrate fraud later. - Automatic Number Identification (ANI) spoofing — this technology allows a caller to alter the true displayable number from which he or she is calling to a falsely portrayed number. It's difficult, if not impossible, to find a legitimate use for this technology. However, fraudsters find this capability quite useful as they try to circumvent what was once a very effective method of positively authenticating a consumer based on a "good" or known incoming phone number. With ANI spoofing in play, many call centers are now unable to confidently rely on this once cost-effective and impactful method of authenticating consumers.
--by Andrew Gulledge General configuration issues Question selection- In addition to choosing questions that generally have a high percentage correct and fraud separation, consider any questions that would clearly not be a fit to your consumer population. Don’t get too trigger-happy, however, or you’ll have a spike in your “failure to generate questions” rate. Number of questions- Many people use three or four out-of-wallet questions in a Knowledge Based Authentication session, but some use more or less than that, based on their business needs. In general, more questions will provide a stricter authentication session, but might detract from the customer experience. They may also create longer handling times in a call center environment. Furthermore, it is harder to generate a lot of questions for some consumers, including thin-file types. Fewer Knowledge Based Authentication questions can be less invasive for the consumer, but limits the fraud detection value of the KBA process. Multiple choice- One advantage of this answer format is that it relies on recognition memory rather than recall memory, which is easier for the consumer. Another advantage is that it generally prevents complications associated with minor numerical errors, typos, date formatting errors and text scrubbing requirements. A disadvantage of multiple-choice, however, is that it can make educated guessing (and potentially gaming) easier for fraudsters. Fill in the blank- This is a good fit for some KBA questions, but less so with others. A simple numeric answer works well with fill in the blank (some small variance can be allowed where appropriate), but longer text strings can present complications. While undoubtedly difficult for a fraudster to guess, for example, most consumers would not know the full, official and (correct spelling) of the name to which they pay their monthly auto payment. Numeric fill in the blank questions are also good candidates for KBA in an IVR environment, where consumers can use their phone’s keypad to enter the answers.
--by Andrew Gulledge Where does Knowledge Based Authentication fit into my decisioning strategy? Knowledge Based Authentication can fit into various parts of your authentication process. Some folks choose to put every consumer through KBA, while others only send their riskier transactions through the out-of-wallet questions. Some people use Knowledge Based Authentication to feed a manual review process, while others use a KBA failure as a hard-decline. Uses for KBA are as sundry and varied as the questions themselves. Decision Matrix- As discussed by prior bloggers, a well-engineered fraud score can provide considerable lift to any fraud risk strategy. When possible, it is a good idea to combine both score and questions into the decisioning process. This can be done with a matrixed approach—where you are more lenient on the questions if the applicant has a good fraud score, and more lenient on the score if the applicant did well on the questions. In a decision matrix, a set decision code is placed within various cells, based on fraud risk. Decision Overrides- These provide a nice complement to your standard fraud decisioning strategy. Different fraud solution vendors provide different indicators or flags with which decisioning rules can be created. For example, you might decide to fail a consumer who provides a social security number that is recorded as deceased. These rules can help to provide additional lift to the standard decisioning strategy, whether it is in addition to Knowledge Based Authentication questions alone, questions and score, etc. The overrides can be along the lines of both auto-pass and auto-fail.
In my last post I discussed the problem with confusing what I would call “real” Knowledge Based Authentication (KBA) with secret questions. However, I don’t think that’s where the market focus should be. Instead of looking at Knowledge Based Authentication (KBA) today, we should be looking toward the future, and the future starts with risk-based authentication. If you’re like most people, right about now you are wondering exactly what I mean by risk-based authentication. How does it differ from Knowledge Based Authentication, and how we got from point A to point B? It is actually pretty simple. Knowledge Based Authentication is one factor of a risk-based authentication fraud prevention strategy. A risk- based authentication approach doesn’t rely on question/answers alone, but instead utilizes fraud models that include Knowledge Based Authentication performance as part of the fraud analytics to improve fraud detection performance. With a risk-based authentication approach, decisioning strategies are more robust and should include many factors, including the results from scoring models. That isn’t to say that Knowledge Based Authentication isn’t an important part of a risk-based approach. It is. Knowledge Based Authentication is a necessity because it has gained consumer acceptance. Without some form of Knowledge Based Authentication, consumers question an organization’s commitment to security and data protection. Most importantly, consumers now view Knowledge Based Authentication as a tool for their protection; it has become a bellwether to consumers. As the bellwether, Knowledge Based Authentication has been the perfect vehicle to introduce new and more complex authentication methods to consumers, without them even knowing it. KBA has allowed us to familiarize consumers with out-of-band authentication and IVR, and I have little doubt that it will be one of the tools to play a part in the introduction of voice biometrics to help prevent consumer fraud. Is it always appropriate to present questions to every consumer? No, but that’s where a true risk-based approach comes into play. Is Knowledge Based Authentication always a valuable component of a risk based authentication tool to minimize fraud losses as part of an overall approach to fraud best practices? Absolutely; always. DING!
--by Andrew Gulledge Definition and examples Knowledge Based Authentication (KBA) is when you ask a consumer questions to which only they should know the answer. It is designed to prevent identity theft and other kinds of third-party fraud. Examples of Knowledge Based Authentication (also known as out-of-wallet) questions include “What is your monthly car payment?:" or “What are the last four digits of your cell number?” KBA -- and associated fraud analytics -- are an important part of your fraud best practices strategies. What makes a good KBA question? High percentage correct A good Knowledge Based Authentication question will be easy to answer for the real consumer. Thus we tend to shy away from questions for which a high percentage of consumers give the wrong answer. Using too many of these questions will contribute to false positives in your authentication process (i.e., failing a good consumer). False positives can be costly to a business, either by losing a good customer outright or by overloading your manual review queue (putting pressure on call centers, mailers, etc.). High fraud separation It is appropriate to make an exception, however, if a question with a low percentage correct tends to show good fraud detection. (After all, most people use a handful of KBA questions during an authentication session, so you can leave a little room for error.) Look at the fraudsters who successfully get through your authentication process and see which questions they got right and which they got wrong. The Knowledge Based Authentication questions that are your best fraud detectors will have a lower percentage correct in your fraud population, compared to the overall population. This difference is called fraud separation, and is a measure of the question’s capacity to catch the bad guys. High question generability A good Knowledge Based Authentication question will also be generable for a high percentage of consumers. It’s admirable to beat your chest and say your KBA tool offers 150 different questions. But it’s a much better idea to generate a full (and diverse) question set for over 99 percent of your consumers. Some KBA vendors tout a high number of questions, but some of these can only be generated for one or two percent of the population (if that). And, while it’s nice to be able to ask for a consumer’s SCUBA certification number, this kind of question is not likely to have much effect on your overall production.
Round 1 – Pick your corner There seems to be two viewpoints in the market today about Knowledge Based Authentication (KBA): one positive, one negative. Depending on the corner you choose, you probably view it as either a tool to help reduce identity theft and minimize fraud losses, or a deficiency in the management of risk and the root of all evil. The opinions on both sides are pretty strong, and biases “for” and “against” run pretty deep. One of the biggest challenges in discussing Knowledge Based Authentication as part of an organization’s identity theft prevention program, is the perpetual confusion between dynamic out-of-wallet questions and static “secret” questions. At this point, most people in the industry agree that static secret questions offer little consumer protection. Answers are easily guessed, or easily researched, and if the questions are preference based (like “what is your favorite book?”) there is a good chance the consumer will fail the authentication session because they forgot the answers or the answers changed over time. Dynamic Knowledge Based Authentication, on the other hand, presents questions that were not selected by the consumer. Questions are generated from information known about the consumer – concerning things the true consumer would know and a fraudster most likely wouldn’t know. The questions posed during Knowledge Based Authentication sessions aren’t designed to “trick” anyone but a fraudster, though a best in class product should offer a number of features and options. These may allow for flexible configuration of the product and deployment at multiple points of the consumer life cycle without impacting the consumer experience. The two are as different as night and day. Do those who consider “secret questions” as Knowledge Based Authentication consider the password portion of the user name and password process as KBA, as well? If you want to hold to strict logic and definition, one could argue that a password meets the definition for Knowledge Based Authentication, but common sense and practical use cause us to differentiate it, which is exactly what we should do with secret questions – differentiate them from true KBA. KBA can provide strong authentication or be a part of a multifactor authentication environment without a negative impact on the consumer experience. So, for the record, when we say KBA we mean dynamic, out of wallet questions, the kind that are generated “on the fly” and delivered to a consumer via “pop quiz” in a real-time environment; and we think this kind of KBA does work. As part of a risk management strategy, KBA has a place within the authentication framework as a component of risk- based authentication… and risk-based authentication is what it is really all about.
Many compliance regulations such the Red Flags Rule, USA Patriot Act, and ESIGN require specific identity elements to be verified and specific high risk conditions to be detected. However, there is still much variance in how individual institutions reconcile referrals generated from the detection of high risk conditions and/or the absence of identity element verification. With this in mind, risk-based authentication, (defined in this context as the “holistic assessment of a consumer and transaction with the end goal of applying the right authentication and decisioning treatment at the right time") offers institutions a viable strategy for balancing the following competing forces and pressures: • Compliance – the need to ensure each transaction is approved only when compliance requirements are met; • Approval rates – the need to meet business goals in the booking of new accounts and the facilitation of existing account transactions; • Risk mitigation – the need to minimize fraud exposure at the account and transaction level. A flexibly-designed risk-based authentication strategy incorporates a robust breadth of data assets, detailed results, granular information, targeted analytics and automated decisioning. This allows an institution to strike a harmonious balance (or at least something close to that) between the needs to remain compliant, while approving the vast majority of applications or customer transactions and, oh yeah, minimizing fraud and credit risk exposure and credit risk modeling. Sole reliance on binary assessment of the presence or absence of high risk conditions and identity element verifications will, more often than not, create an operational process that is overburdened by manual referral queues. There is also an unnecessary proportion of viable consumers unable to be serviced by your business. Use of analytically sound risk assessments and objective and consistent decisioning strategies will provide opportunities to calibrate your process to meet today’s pressures and adjust to tomorrow’s as well.
By: Kennis Wong It's true that intent is difficult to prove. It's also true that financial situations change. That's why financial institutions have not, yet, successfully fought off first-party fraud. However, there are some tell-tale signs of intent when you look at the consumer's behavior as a whole, particularly across all his/her financial relationships. For example, in a classic bust out case, you would see that the consumer, with pristine credit history, applies for more and more credit cards while maintaining a relatively low balance and utilization across all issuers. If you graph the number of credit cards and number of credit applications over time, you would see two hockey-stick lines. When the accounts go bad, they do so at almost the same time. This pattern is not always apparent at the time of origination, that's why it's important to monitor frequently for account review and fraud database alerts. On the other hand, consumers with financial difficulties have different patterns. They might have more credit lines over time, but you would see that some credit lines may go delinquent while others don't. You might also see that consumers cure some lines after delinquencies…you can see their struggle of trying to pay. Of course the intent "pattern" is not always clear. When dealing with fraudsters in fraud account management, even with the help of the fraud database, fraud trends and fraud alert, change their behaviors and use new techniques.
On Friday, October 30th, the FTC again delayed enforcement of the “Red Flags” Rule – this time until June 1, 2010 – for financial institutions and creditors subject to the FTC’s enforcement. Here’s the official release: http://www.ftc.gov/opa/2009/10/redflags.shtm. But this doesn’t mean, until then, businesses get a free pass. The extension doesn’t apply to other federal agencies that have enforcement responsibilities for institutions under their jurisdiction. And the extension also doesn’t alleviate an institution’s need to detect and respond to address discrepancies on credit reports. Red Flag compliance Implementing best practices to address the identity theft under the Red Flags Rule is not just the law, it’s good business. The damage to reputations and consumer confidence from a problem gone unchecked or worse yet – unidentified – can be catastrophic. I encourage all businesses – if they haven’t already done so – to use this extension as an opportunity to proactively secure a Red Flags Rule to ensure Red Flag compliance. It’s an investment in protecting their most important asset – the customer.
As I wrote in my previous posting, a key Red Flags Rule challenge facing many institutions is one that manages the number of referrals generated from the detection of Red Flags conditions. The big ticket item in referral generation is the address mismatch condition. Identity Theft Prevention Program I’ve blogged previously on the subject of risk-based authentication and risk-based pricing, so I won’t rehash that information. What I will suggest, however, is that those institutions who now have an operational Identity Theft Prevention Program (if you don’t, I’d hurry up) should continue to explore the use of alternate data sources, analytics and additional authentication tools (such as knowledge-based authentication) as a way to detect Red Flags conditions and reconcile them all within the same real-time transaction. Referral rates Referral rates stemming from address mismatches (a key component of the Red Flags Rule high risk conditions) can approach or even surpass 30 percent. That is a lot. The good news is that there are tools which employ additional data sources beyond a credit profile to “find” that positive address match. The use of alternate data sources can often clear the majority of these initial mismatches, leaving the remaining transactions for treatment with analytics and knowledge-based authentication and Identity Theft Prevention Program. Whatever “referral management” process you have in place today, I’d suggest exploring risk-based authentication tools that allow you to keep the vast majority of those referrals out of the hands of live agents, and distanced from the need to put your customers through the authentication wringer. In the current marketplace, there are many services that allow you to avoid high referral costs and risks to customer experience. Of course, we think ours are pretty good.
In my last entry, I talked about the challenges clients face in trying to meet multiple and complex regulatory requirements, such as FACT Act’s Red Flags Rule and the USA Patriot Act. While these regulations serve both different and shared purposes, there are some common threads between the two: 1. You must consider the type of accounts and methods of account opening: The type of account offered - credit or deposit, consumer or business – as well as the method of opening – phone, online, or face-to-face – has a bearing on the steps you need to take and the process that will be established. 2. Use of consumer name, address, and identification number:The USA Patriot Act requires each of these – plus date of birth – to open a new account. Red Flags stops short of “requiring” these for new account openings, but it consistently illustrates the use of these Personally Identifiable Information (PII) elements as examples of reasonable procedures to detect red flags. 3. Establishing identity through non-documentary verification:Third party information providers, such as a credit reporting agency or data broker, can be used to confirm identity, particularly in the case where the verification is not done in person. Knowing what’s in common means you can take a look at where to leverage processes or tools to gain operational and cost efficiencies and reduce negative impact on the customer experience. For example, if you’re using any authentication products today to comply with the USA Patriot Act and/or minimize fraud losses, the information you collect from consumers and authentication steps you are already taking now may suffice for a large portion of your Red Flags Identity Theft Prevention Program. And if you’re considering fraud and compliance products for account opening or account management – it’s clear that you’ll want something flexible that, not only provides identity verification, but scales to the compliance programs you put in place, and those that may be on the horizon.