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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.  

As we approach the FTC's May 1, 2009 Red Flags Rule enforcement deadline, we are still working with many of our existing and prospective clients to support their Red Flags Identity Theft Prevention Program.  In my opinion, the May 1, 2009 extension did much good on two fronts:  1.  It brought to light the need for all institutions, particularly in markets outside of traditional financial services arenas, to re-evaluate the expectation of their being 'covered' under the Red Flag guidelines.  2.  It allowed 'covered' institutions the opportunity to take additional steps to not only create and operationalize their programs, but to spend time making those programs efficient and in line with business and regulatory objectives. In the spirit of information gathering and sharing, we at Experian are conducting a quick survey to gauge how 'helpful' the May 1, 2009 extension was to your organization.  We're also trying to informally keep our finger on the pulse of market readiness, as the enforcement deadline is upon us. Via the link below, please take about 60 seconds to answer a few questions that will help us better understand the current state of the market's Red Flags Rule readiness. Experian Red Flags Survey We certainly appreciate your time.  

Understanding the Champion/Challenger testing strategy As the economic world continues to change, collection strategy testing becomes increasingly important. Champion/Challenger strategy testing is performed using a sample segment and the results provide a learning tool for determining which collections strategies are most effective. This allows strategies to be tested before rolling them out across the entire portfolio. The purpose of this experimental element to collections strategy management is to observe the effectiveness of new strategies, support continuous improvement of collection approaches and facilitate adaptability to changes in consumer behavior. The methodology behind testing is simple. First, the current environment should be assessed to identify specific areas for potential improvement. Then, a test plan is designed. The test plan should, at a minimum, include well-defined objectives and goals, proposed strategy design, determination of sample size, operational considerations, execution approach, success criteria, and evaluation timetable. After the framework for the test plan has been outlined, running “what if” scenarios will improve refinement of the collections strategy. In the next phase, implementation occurs following the directives of the test plan. Evaluating strategies commences after implementation and continues throughout the duration of the test. This includes analyzing metrics established during the test plan phase to identify trends and changes as a result of the new challenger strategy. The challenger strategy is declared the new champion if the test achieves or exceeds expectations. However, before proceeding with the new champion strategy over the entire portfolio, carefully consider any operational constraints that might hinder the success of the strategy on a grand scale. Once these operational constraints have been identified and their impact assessed, the new champion strategy should be executed.

  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.

In addition to behavioral models, collections management and account management groups need the ability to implement strategies in order to effectively handle and process accounts, particularly when the optimization of resources is a priority. While the behavioral models will effectively evaluate and measure the likelihood that an account will become delinquent or result in a loss, strategies are the specific actions taken, based on the score prediction, as well as other key information that is available when those actions are appropriate. Identifying high-risk accounts, for example, may result in collections strategies designed to accelerate collections activity and execute more aggressive actions and increase collections efficiency. On the other hand, identifying low-risk accounts can help determine when to take advantage of cost-saving actions and focus on customer retention programs. Effective strategies also address how to handle accounts that fall between the high- and low-risk extremes, as well as accounts that fall into special categories such as first-payment defaults, recently delinquent accounts and unique customer or product segments. To accommodate lenders with systems that cannot support either behavioral scorecards or automated strategy assignments a hosted collections software decisioning system can close the gap. To use these services master file data needs to be transmitted (securely) on a regular basis. The remote decision engine then calculates behavioral scores, identifies special handling accounts and electronically delivers the recommended strategy code or string of actions to drive treatments.  

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.

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.

Have you ever wondered how your current collections workflow process evolved to its current state?  To start at the beginning, let’s rewind to medieval England … The Tallyman The earliest known collections system was essentially a door-to-door program, as there were no modern day devices to make the process more efficient. The system of record at that time was typically a hardwood stick with carved notches representing loans and payments between a lender and borrower. This door-to-door collector was known as the Tallyman, which referred to the collection of tally sticks he carried to document financial transactions. The beginning of modern times As technology evolved, telephones and letters became the collections management tools of choice, with a personal visit being a last resort action. The process where a collector managed the repayment strategy and relationships for his assigned customers was still in practice. Collections operations were typically in decentralized branches and small teams of skilled collectors were able to effectively manage this “cradle-to-grave” approach. Yesterday When expense management became a priority, the migration to larger, centralized operations became an industry trend.  Many companies found it difficult to hire large teams of highly-skilled collectors in their geographic regions and the bucket system was born. The concept was simple and effective -- let the less experienced staff work the accounts that are the easiest to collect and focus the experienced collectors on the more difficult cases.  Advanced collections tools such as automatic dialers arrived on the market to increase efficiency and were shortly followed by decision engines used to support behavioral scoring and segmentation strategies. Today Current trends in collections include the migration towards a risk-based segmentation and strategy approach. Cutting edge tools and collection management software, designed to address today’s collections business objectives, are hitting the market and challenging the traditional bucket approach most of us are used to. As the economic conditions of the past few years deteriorated, many organizations began shifting their spending focus towards the collections department and this, in turn, has inspired investment and innovation from software, analytics and data vendors. New collections scores were recently unveiled that yield predictiveness that has never been seen and collections data products have become significantly more sophisticated. Modern technology is also empowering collections managers to control the destiny of their business units by freeing them from the constraints of over-burdened IT departments and inflexible systems. There is also an emerging trend to consider the collective power of multiple products working in tandem. Collections experts are finding that the benefit of the complete solution equals much more than just the sum of the parts. Tomorrow Once we all migrate to the next level and employ today’s modern marvels to make our businesses more productive and efficient, what’s next?  It’s highly probable that tomorrow’s collections workflow will consider the entire relationship and profit potential of a customer before a collections action is executed. Additionally, the value in considering the entire credit and risk picture associated with a customer will be better understood and we will learn when each of the holistic view options is most appropriate. There are a number of roadblocks in the way today, including disparate systems and databases and siloed business units with goals and objectives that are not aligned. Will we eventually get there? The business leaders with long-range vision certainly will … just as some unknown visionary had the initiative to embrace emerging technology and abandon his tally sticks. For more information and to read the Decision Analytics newsletter that features one of my previous blogs, "Next generation collections systems", click here.   

We have talked about: the creation of the vision for our loan portfolios (current state versus future state) – e.g. the strategy for moving our current portfolio to the future vision. Now comes the time for execution of that strategy. In changing portfolio composition and improving credit quality, the discipline of credit must be strong (this includes in the arenas of commercial loan origination, loan portfolio monitoring, and credit risk modeling of course). Consistency, especially, in the application of policy is key. Early on in the change/execution process there will be strong pressure to revert back to the old ways and stay in a familiar comfort zone.  Credit criteria/underwriting guidelines will have indeed changed in the strategy execution. In the coming blogs we will be discussing: assessment of the current state in your loan portfolio; development of the specific strategy to effect change in the portfolio from a credit quality perspective and composition; business development efforts to affect change in the portfolio composition; and policy changes to support the strategy/vision.  

If the business is a creditor or a “financial institution” (defined as a depository institution) that offers covered accounts, you must develop a Program to detect possible identity theft in the accounts and respond appropriately. The federal banking agencies, the NCUA and the FTC have issued Guidelines to help covered entities identify, detect and respond to indicators of possible identity theft, as well as to administer the Program. A copy of the Red Flag Guidelines can be found: Federal Reserve Board – 12 C.F.R. pt 222, App. J Federal Deposit Insurance Corporation – 12 C.F.R. pt 334, App. J FTC – 16 C.F.R. pt 681, App. A NCUA – 12 C.F.R. pt 717, App. J Office of the Comptroller of the Currency - 12 C.F.R. pt 41, App. J Office of Thrift Supervision - 12 C.F.R. pt 571, App. J  

They have started to shift away from time-based collections management activities (the 30-, 60-, 90-day bucket approach).  Instead, the focus is migrating towards the development of collections strategy that is based on the underlying risk of the individual – to look at how he is performing on all of the obligations in the total relationship to determine the likelihood of repayment and the associated activities that can facilitate that repayment.  They’ve found they can’t rely purely on traditional models anymore because consumer behavior has dramatically changed and an account only approach doesn’t reflect the true risk and value of the individual’s relationship.

The credit reporting agencies will not identify Red Flags, as such, on a credit report. However, there may be certain information on a credit report that you have determined to be an indicator of possible identity theft and have incorporated into your Program, such as a consumer fraud alert or a notice of address discrepancy. In addition, the Red Flag Guidelines specify that a credit report indicating a pattern of inconsistent or unusual recent activity might be a Red Flag.

By: Tom Hannagan   Part 6 Peer Group 2 fee income Non-interest income again, as a percent of average total assets, declined to .86 percent from .95 percent in 2007. For Peer Group 2 (PG2), fees have also been steadily declining relative to asset size, down from 1.04 percent of assets in 2005. A smaller, non-interest bearing deposit base with no other new and offsetting sources of fee income will lead to increased pressure on this metric. Operating expenses Operating expenses also put more pressure on earnings on these smaller banks. They increased from 2.79 percent to 2.83 percent of average assets. That’s four basis points on the negative. Historically, this metric has been flattering for this size bank and usually moves up or down from year-to-year. It was almost equal at 2.82 percent of assets in 2004. As a result of the sizeable decline in margins, the continued decline in fee income and the slight increase in operating expenses PG2’s efficiency ratio lost ground from 59.52 percent in 2007 to only 64.72 percent in 2008. That means that every dollar in gross revenue cost them almost 65 cents in administrative expenses this year. This metric averaged 56 cents in 2005/2006. It’s amazing how close these numbers are for banks of very different size where you would expect clear economies of scale. The total impact of margin performance, fee income and operating expenses, plus the huge increase in provision expense of 59 basis points leads us to a total decline in pre-tax operating income of .96 percent on total assets. That is a total decline from 1.58 percent pre-tax ROA in 2007 to .64 percent pre-tax ROA, a loss of 61 percent from the pre-tax performance in 2007. My same conclusion as above would hold regarding the pricing of risk into bank lending (although the smaller banks didn’t perform a badly as the larger in this regard). Although all 490 banks are declining in all profit metrics, the smaller banks seem to have an edge in pricing loans, but not deposits. Although up dramatically in 2007, and even more in 2008 for both groups, the PG2 banks seem to be suffering fewer credit losses relative to their asset size than their larger brethren. Both groups have resulting huge profit declines, but the largest banks are under the most pressure through this period. An interesting point, with higher loan yields and fewer apparent losses, is whether PG2 banks are somewhat better at risk-based pricing (for whatever reason) than the largest bank group. Results are results. The 2009 numbers aren’t expected to show a lot of improvement as the general economy continues to slow and credit and financial risk management issues continue. We’ll probably comment on 2009 as the quarterlies become available this year.  

For all you folks who, like me, waited until the last minute to knock out a term paper or class project in school, here is a friendly reminder…Yes, the Federal Trade Commission (FTC) pushed out the enforcement deadline of the Red Flags Rule to May 1, 2009.  Yes, a sigh of relief was heard across compliance officers and operations managers nationwide.  However, you should still keep a few things in mind as we approach May 1.  First, per the FTC, "many entities also noted that because they generally are not required to comply with FTC rules in other contexts, they had not followed or even been aware of the rulemaking, and therefore learned of the requirements of the rule too late to be able to come into compliance by November 1, 2008."  Those of you, who have not been subject to FTC enforcement in the past are quite possibly still subject to the Red Flags Rule based on your institution maintaining 'covered accounts' per the definition in the Red Flags Rule itself.  Double check if you think otherwise. Second, the FTC was clear in stating that "this delay in enforcement is limited to the Identity Theft Red Flags Rule (16 CFR 681.2), and does not extend to the rule regarding address discrepancies applicable to users of consumer reports (16 CFR 681.1), or to the rule regarding changes of address applicable to card issuers (16 CFR 681.3)."  So, while May 1 is still a few weeks away, if you are accessing consumer credit reports, for example, you should already have a formal written and operational process to detect and respond to address discrepancies on those credit reports.

Red Flags Rule I've heard more than one institution claim that they may limit and even reduce the identity elements (perhaps down to just name and address) that are captured during consumer applications or other transactions.  Their rationale is that the fewer identity elements they request or require during these processes, the less information they will need to authenticate as part of their Red Flags Identity Theft Prevention Program.  While this argument seems logical on the surface, I would suggest that if securely gathered/stored and appropriate to the nature of your business, additional data elements such as Social Security Number (SSN), date of birth and phone number can actually allow you to accomplish a few things to your benefit.  1.  Analysis of our consumer authentication products shows that contributing SSN, date of birth, and phone (in addition to name and address) to an authentication process, will actually improve your ability to positively authenticate a consumer via an overall risk-based strategy.  2.  The use of additional data elements, such as the phone number, can unlock additional data sources for use in verifying not only that phone number, but the inquiry name and address as well.  3.  Just because you don't capture certain identity elements, doesn't mean the risk goes away.  In providing additional identity elements for authentication, you can gain a more holistic view of a consumer - be that good, bad or ugly.  It’s better to figure this out up front versus down the road when bills go unpaid and the bad guys scatter.