Tag: CARES Act

Student loan forbearance, part of the Coronavirus Aid, Relief, and Economic Security (CARES Act) economic stimulus bill that paused student loan repayment, interest accrual, and collections, is set to expire on May 1, 2022.  Borrowers who carry  federal student loans in the United States need to anticipate the resumption of repayment and interest accrual. In this article, we’ll answer questions your borrowers will be asking about the end of the student loan pause and how they can better prepare.   Lenders and servicers should anticipate an influx of requests for modification and for private student loan lenders, a potential significant push for refinancing.   When do student loans resume and when does student loan interest start again?  Student loan repayments and resumption of interest accruals are set to resume on May 1, 2022. This means that student loans will start accruing interest again, and payments will need to resume on the existing payment date. In other words, if the due date prior to the pause was the fifth of every month, the first repayment date will be May 5, 2022.  In the weeks preceding this, borrowers can expect a billing statement from their student loan servicer outlining their debt and terms or they can reach out to their servicers directly to get more information.  Will student loan forbearance be extended again? Will the CARES Act be extended?  There is no indication that the federal government will extend student loan forbearance beyond May 1, 2022, which was already extended beyond the original deadline in February 2022. Your borrower’s best strategy is to prepare now for the resumption of repayments, interest accrual and collections. Will Biden forgive student loans?  Free community college tuition and federal student loan forgiveness up to $10,000 were a centerpiece of the Biden platform during his candidacy for president and were included in early iterations of the government's Build Back Better agenda. In February 2022, during bargaining, the administration removed the free tuition provision from the bill. The Build Back Better bill has yet to pass.  Although there remains a student loan relief provision in the draft Build Back Better agenda, there is no guarantee that it will make it into the final iteration.  What should borrowers do if they paid student loans using auto-debit?  Most borrowers will need to restart auto-debit after the student loan pause. If auto-debit or ACH was used prior to the student loan pause went into effect on March 13, 2020, borrowers can expect to receive a communication from their servicer confirming they wish to continue with auto-debit. If the borrower doesn’t respond to this notice, the servicer may cancel auto-debit. If the borrower signed up for auto-debit after the beginning of forbearance, payments should automatically begin.  How much interest will borrowers have to pay?  Unless terms have changed, such as consolidating loans, the interest rate will be the same as it was before the student loan pause went into effect.  Will balances be the same as they were before the student loan pause? Will it take the same amount of time to pay off the student loan?  For those on a traditional repayment plan, a student loan servicer might recalculate the amount based on the principal and interest and the amount of time left in the repayment period. Borrowers will still make payments for the same number of months in total, but the end date for repayment will be pushed forward to accommodate the payment pause.   In other words, if the loan terms originally stated that it would be repaid in full on January 1, 2030, the new terms will accommodate the pause and show full repayment on January 1, 2032.  For those on an Income-Driven Repayment Plan (IDRP) – such as Revised Pay as You Earn Repayment (REPAYE), Pay As You Earn Repayment (PAYE), Income-Based Repayment (IBR), or Income-Contingent Repayment (ICR) – the payment amount will resume at the same rate as before the payment pause. Student loan forbearance will not delay progress towards repayment.  What are borrower options if the student loan payment is too high?  Enroll in an IDRP program: Available plans include REPAYE, PAYE, IBR or ICR.  Student loan refinancing: When a borrower refinances, he or she can group federal and private loans and possibly negotiate a lower repayment amount. However, they will not be eligible to access federal loans protections or programs.  Loan consolidation: This process allows borrowers to combine multiple federal loans into a single loan with a single payment, which can reduce monthly payments by extending the repayment period. Note this will result in more interest being charged, as the time to repay will be extended. Will this change affect those with private student loans?  Private lenders are not covered by the CARES Act, so student loan forbearance did not apply to them. Most private lenders have continued collecting repayments throughout the COVID-19 pandemic.   Borrowers having trouble making payments to a private lender, can discuss options such as deferment, forbearance, consolidation and modified repayment terms.  What happens if a student loan payment is missed or the borrower can’t pay at all?   If a payment is missed, the account will be considered delinquent. The account becomes delinquent the first day after a missed payment and remains that way until the past-due amount is paid or other arrangements are made.   If the account remains delinquent, the loan may go into default. The amount of time between delinquency and default depends on the student loan servicer. If the loan goes into default, borrowers could face consequences including:  Immediate collections on the entire loan and interest owed Ineligibility for benefits such as deferment and forbearance,   Inability to choose a different payment plan or obtain additional federal student aid  Damage to credit score  Inability to buy or sell assets  Withholding of tax refunds or other federal benefits Wage garnishment A lawsuit Do student loans affect credit scores?  Yes, for delinquent student loans, the servicer will report the delinquency to the three major credit bureaus and the borrower’s credit score will drop.2 A poor credit score can affect a consumer’s ability to obtain credit cards or loans and may make it difficult to sign up with utilities providers, cell phone providers and insurance agencies. It can also be challenging to rent an apartment.  What are the options for those who can’t pay? Can student loans be deferred?  For those with federal student loans, now is the time to prepare for the end of student loan forbearance. Revisit budgets, make sure records are up to date and communicate with student loan servicers to make sure payments can be made in full and on time.  For those unable to pay back loans, they can consider requesting a deferment. A deferment is a temporary pause on student loan payments. Depending on the type of loan, interest may or may not continue to accrue during the deferment.  If they wish to apply for a deferment, they must meet eligibility requirements. Some common grounds for deferment are:  Economic hardship  Schooling  Military service  Cancer treatment  Loan servicers and private lenders should arm themselves for the large volume of questions  from borrowers who are not prepared to begin resuming payment. Now may the time to increase customer service or consider adding student loan consolidation products to serve the increase in demand.  For information on mitigating risk and effectively managing your portfolio, click here.  

It is no news that businesses are increasing their focus on advanced analytics and models. Whether looking to increase resources or focus on artificial intelligence (AI) and machine learning (ML), growth is the name of the game. But how do you maximize impact while minimizing risk? And how can you secure expertise and ROI when budgets are strapped?  Does your organization have the knowledge and talent in-house to remain competitive? No matter where you are on the analytics maturity curve, (outlined in detail below), your organization can benefit from making sure your machine learning models solution consists of: Regulatory documentation: Documentation for model and strategy governance is critical, especially as there is more conversation surrounding fair lending and how it relates to machine learning models. How does your organization ensure your models are explainable, well documented and making fair decisions? These are all questions you must be asking of your partners and solutions. Integrated services: For some service providers, “integrated,” is merely a marketing ploy, but it is essential that your solution truly integrates attributes, scores, models and decisions into one another. Not only does this serve as a “checks and balances” system of sorts, but it also is a primary driver for the speed of decisioning, which is crucial in today’s digital-first world. Deep expertise: Models are a major component for your decisioning, but ensuring those models are built and backed by experts is the one-two punch your strategies depend on. Make sure your services are managed by data scientists with extensive experience to take the best approach to solving your business problems. Usability: Does your solution close the loop? To future proof your processes, your solution must analyze the performance of attributes, scores and strategies. On top of that, your solution should make sure the items being built are useable and can be modified when needed. A one-and-done model does not suit the unique needs of your organization, so ensure your solution provides actionable analysis for continual refinement. Does your machine learning model solution check these boxes? Do you want to transform your existing system into a state-of-the-art AI platform? Learn more about how you can take your business challenges head-on by rapidly developing, deploying and monitoring sophisticated models and strategies to more accurately predict risk and achieve better outcomes. Learn more Access infographic   More information: What’s the analytics maturity curve? “Analytics” is the discovery, interpretation and communication of meaningful patterns in data; the connective tissue between data and effective decision-making within an organization. You can be along this journey for different decision points you’re making or product types, said Mark Soffietti, Director of Analytics Consulting at Experian, at our recent AI-driven analytics and strategy optimization webinar. Where you are on this curve often depends on your organization’s use of generic versus custom scores, the systems currently engaged to make those decisions and the sophistication of an organization’s models and/or strategies. Here’s a breakdown of each of the four stages: Descriptive Analytics – Descriptive analytics is the first step of the analytics maturity curve. These analytics answer the question “What is happening?” and typically revolve around some form of reporting. An example would be the information that your organization received 100 applications. Diagnostic Analytics – These analytics move from what happened to, “Why did it happen?” By digging into the 100 applications received, diagnostic analytics answer questions like “Who were we targeting?” and “How did those people come into our online portal/branch?” This information helps organizations be more strategic in their practices. Predictive Analytics – Models come into play at this stage as organizations try to predict what will happen. Based on the data set and an understanding of what the organization is doing, effort is put towards automating information to better solve business problems. Prescriptive Analytics – Optimization is key for prescriptive analytics. At this point in the maturity curve, there are multiple models and/or information that may be competing against one another. Prescriptive analytics will attempt to prescribe what an organization is doing and how it can drive more desired behaviors. For more information and to get personalized recommendations throughout your analytics journey, visit our website.

In the wake of unprecedented unemployment fraud since the start of COVID-19, Experian announced it was selected as the exclusive partner for identity and fraud verification for the Unemployment Insurance (UI) Integrity Center’s centralized Identity Verification (IDV) capability. IDV is available to state agencies at no cost through UI Integrity Center, which is operated by the National Association of Workforce Agencies (NASWA) in partnership with the U.S. Department of Labor.   With the Federal Bureau of Investigations (FBI) reporting a spike in fraudulent unemployment insurance claims complaints related to COVID-19, it’s more important than ever for state agencies to use innovative solutions to verify identities that are applying for unemployment insurance to protect consumers. If improper unemployment insurance payments are made to fraudsters, the efforts of the CARES Act could be largely wasted.   The IDV capability leverages Experian’s Precise IDTM to provide a centralized identity verification and proofing solution. Precise ID combines identity analytics with advanced fraud risk models to distinguish various types of fraud, which can help state agencies maximize time and resources. When state agencies submit claims, the IDV solution will return ID theft scoring and associated cause codes, enabling them to assess whether a claim may be fraudulent.   “Due to the COVID-19 health crisis, unemployment is high, with over roughly 60 million Americans filing for unemployment since March,” said Robert Boxberger, president of Experian’s Decision Analytics in North America. “At Experian, we’re proud to have a strong culture dedicated to continuous innovation that helps protect consumers’ financial health. We’re taking that same consumer focus and helping make the unemployment insurance application process more efficient and safer for constituents.”   The Integrity Data Hub (IDH) is a robust, multi-state data system that contains a continuously expanding set of sources to provide advanced cross-matching and analytic capabilities to states. It is designed to be easily implemented by any state Unemployment Insurance agency, regardless of claim volume, technology, or access to internal resources. The IDH was designed and built using the latest National Institute of Standards and Technology IT security standards, including the use of asymmetric encryption and other techniques to ensure the security of sensitive data.   “We’re excited to partner with Experian and utilize its Precise ID solution to assist states in mitigating fraud during these unprecedented times,” said Scott Sanders, NASWA Executive Director. “States are finding this to be a very valuable tool and we are pleased that we can offer this solution to states through our partnership with the U.S. Department of Labor.” Read Press Release Learn More About Precise ID

Achieving collection results within the subprime population was challenging enough before the current COVID-19 pandemic and will likely become more difficult now that the protections of the Coronavirus Aid, Relief, and Economic Security (CARES) Act have expired. To improve results within the subprime space, lenders need to have a well-established pre-delinquent contact optimization approach. While debt collection often elicits mixed feelings in consumers, it’s important to remember that lenders share the same goal of settling owed debts as quickly as possible, or better yet, avoiding collections altogether. The subprime lending population requires a distinct and nuanced approach. Often, this group includes consumers that are either new to credit as well as consumers that have fallen delinquent in the past suggesting more credit education, communication and support would be beneficial. Communication with subprime consumers should take place before their account is in arrears and be viewed as a “friendly reminder” rather than collection communication. This approach has several benefits, including: The communication is perceived as non-threatening, as it’s a simple notice of an upcoming payment. Subprime consumers often appreciate the reminder, as they have likely had difficulty qualifying for financing in the past and want to improve their credit score. It allows for confirmation of a consumer’s contact information (mainly their mobile number), so lenders can collect faster while reducing expenses and mitigating risk. When executed correctly, it would facilitate the resolution of any issues associated with the delivery of product or billing by offering a communication touchpoint. Additionally, touchpoints offer an opportunity to educate consumers on the importance of maintaining their credit. Customer segmentation is critical, as the way lenders approach the subprime population may not be perceived as positively with other borrowers. To enhance targeting efforts, lenders should leverage both internal and external attributes. Internal payment patterns can provide a more comprehensive view of how a customer manages their account. External bureau scores, like the VantageScore® credit score, and attribute sets that provide valuable insights into credit usage patterns, can significantly improve targeting. Additionally, the execution of the strategy in a test vs. control design, with progression to successive champion vs. challenger designs is critical to success and improved performance. Execution of the strategy should also be tested using various communication channels, including digital. From an efficiency standpoint, text and phone calls leveraging pre-recorded messages work well. If a consumer wishes to participate in settling their debt, they should be presented with self-service options. Another alternative is to leverage live operators, who can help with an uptick in collection activity. Testing different tranches of accounts based on segmentation criteria with the type of channel leveraged can significantly improve results, lower costs and increase customer retention. Learn About Trended Attributes Learn About Premier Attributes

The current pandemic will affect the way financial institutions lend and provide credit. Shawn Rife, Experian’s Director of Product Scoring, discusses the ways that financial institutions can navigate the COVID-19 crisis. Check out what he had to say: What implications does the global pandemic have on financial institutions’ analytical needs?  SR: In the customer lifecycle, there are 4 different stages: prospecting, acquisitions, portfolio management, and collections. During times of economic uncertainty, lenders typically take additional actions to ensure that there’s a first line of defense against delinquencies and payment stress. Expanding their focus to incorporate account review/portfolio management becomes particularly important. During this time, clients will be looking for leadership, early warning signs, and ways to recession-proof their portfolios (account management), while growing and maintaining their approvals in a healthy way (originations). Lenders may be well advised to delay any focus on collections, since many consumers may be facing major payment stress through no mismanagement of their own doing. Another critical component is with the rollout of government stimulus packages, which lenders can use to identify people in stress who could benefit for second chance opportunities they may not have otherwise been able to receive. As more consumers seek credit, from an analytics perspective, what considerations should financial institutions be making during this time?  SR: Financial institutions should be assessing and pre-identifying situations that might place consumers in positions of elevated financial stress. That way, organizations can implement solutions to identify and help at-risk consumers before they fall delinquent. The recent Coronavirus Aid, Relief, and Economic Security Act (CARES Act) – coupled with Experian’s score treatment, are designed to protect consumers against score declines during times of crisis. Furthermore, lenders can provide forbearance and loan deferment programs to help consumers.  For lenders, credit risk scores, models, and attributes are the best ways to identify – and even predict - delinquency risk. The FICO® Resilience Index can also identify consumers who are particularly susceptible to delinquency risk directly due to macroeconomic uncertainty. This gives lenders the opportunity to evaluate their portfolios for loss and connect with consumers who may be in need of further support. What is the smartest next play for financial institutions?  SR: For financial institutions, the smart play is to add alternative data into their data-driven decisioning strategies as much as possible. Alternative data works to enhance your ability to see a consumer’s entire credit portfolio, which gives lenders the confidence to continue to lend – as well as the ability to track and monitor a consumer’s historical performance (which is a good indicator of whether or not a consumer has both the intention and ability to repay a loan). How will the new attribute subset list benefit financial institutions during this time?   SR: Experian’s series of crisis attributes is an example of attributes that can be predictive in times of a crisis. These lists were designed to follow the 3 E’s – Expand, Enhance, and provide Ease of use. Enhance – With these attributes, lenders aren’t limited to traditional data. These attributes allow lenders to look at the entirety of a consumer’s credit or repayment behavior and use more data to make better lending decisions. This becomes crucial in a challenging environment. Expand – This data can also help lenders identify consumers who are in the market for products and services, even if there the lending criteria becomes more stringent. This can open doors and new opportunities for 40-50 million new customers, particularly ones that may not fit initial lending criteria. Ease of Use – Experian has put together the most predictive elements that can identify consumer resilience and potential financial stress in this challenging economy. Experian is committed to helping your organization during times of uncertainty. For more resources, visit our Look Ahead 2020 Hub. Learn more Shawn M. Rife, Director of Risk Scoring, Experian Consumer Information Services, North America Shawn Rife manages Experian’s credit risk scoring models, focused on empowering clients to maximize the scope and influence of their lending universe - while minimizing risk - and complying with ever-changing regulatory standards. Shawn also leads the implementation of Alternative Data within the lending environment, as well as key product implementation initiatives. Prior to Experian, Shawn held key consumer insights and predictive analytics roles for Consumer Packaged Goods and internet companies. Over his career, Shawn has focused on market segmentation, competitive research, new product development and consumer advocacy. He also holds a Master’s degree from Harvard University and a Bachelor’s degree in Political Science and Economics.

When running a credit report on a new applicant, you must ensure Fair Credit Reporting Act (FCRA) compliance before accessing, using and sharing the collected data. The Coronavirus Aid, Relief, and Economic Security (CARES) Act has impacted credit reporting under the FCRA, as has new guidance from the Consumer Financial Protection Bureau (CFPB). Recent updates include: The CARES Act amended the FCRA to require furnishers who agree to an “accommodation,”1 to report the account as current, although it is permitted to continue to report the account as delinquent if the account was delinquent before the accommodation was made. Although not legally obligated, data furnishers should continue furnishing information to the credit reporting agencies (CRAs) during the COVID-19 crisis, and make sure that information reported is complete and accurate. Below is a brief FCRA-related compliance overview2 covering various FCRA requirements3 when requesting and using consumer credit reports for an extension of credit permissible purpose. For more information regarding your responsibilities under the FCRA as a user of consumer reports, please consult your Legal Counsel and the Notice to Users of Consumer Reports: Obligations of Users Under the FCRA handbook located on our website. Before obtaining a consumer report you have…  Reviewed your federal and state regulations and laws related to consumer reports, scores, decisions, etc.  Made sure you have a valid permissible purpose for pulling the consumer report.  Certified compliance to the CRA from which you are getting the consumer report. You have certified that you complied with all the federal and state requirements. After you take an adverse action based on a consumer report you… Provide the consumer with an oral, written or electronic notice of the adverse action. Provide written or electronic disclosure of the numerical credit score used to take the adverse action, or when providing a “risk-based pricing” notice. Provide the consumer with an oral, written or electronic notice, which includes the below information:  Name, address and telephone number of CRA that supplied the report, if nationwide. A statement that the CRA did not make the adverse decision and therefore can’t explain why the decision was made.  Notice of the consumer’s right to a free copy of their report from the CRA, if requested within 60 days.  Notice of the consumer’s right to dispute with the CRA the accuracy or completeness of any information in a consumer report provided by the CRA. Provide the consumer with a “risk-based pricing” notice if credit was granted but on less favorable terms based on information in their consumer report. We understand how challenging it is to understand and meet all your obligations as a data furnisher – we’re here to make it a little easier. Click below to speak with a representative and gain more insight on how the CARES Act impacts FCRA reporting. Download overview Speak with a representative 1An “accommodation” is defined as “an agreement to defer one or more payments, make a partial payment, forbear any delinquent amounts, modify a loan or contract, or any other assistance or relief” granted to a consumer affected by COVID-19 during the covered period. 2This FCRA overview is not legal guidance and does not enumerate all your requirements under the FCRA as a user of consumer reports. Additionally, this FCRA Overview is not intended to provide legal advice or counsel you regarding your obligations under the FCRA or any other federal or state law or regulation. Should you have any questions about your institution’s specific obligations under the FCRA or any other federal or state law or regulation, you should consult with your Legal Counsel. 3This FCRA overview is intended to be used solely by financial service providers when extending credit to consumers and does not include all FCRA regulatory obligations. You are responsible for regulatory compliance when requesting and using consumer reports, which includes adhering to all applicable federal and state statutes and regulations and ensuring that you have the correct policies and procedures in place.

Last week, the unemployment rate soared past 20%, with over 30 million job losses attributed to the COVID-19 pandemic. As a result, many consumers are facing financial stress, which has raised many questions and discussions around how credit history and reporting should be treated at this time. Since the initial start of the pandemic, credit reporting companies and data furnishers have been put under the spotlight to ensure that consumers are able to get the assistance that they need. Numerous questions and concerns have also been raised around the extent of which consumers have access to fair and affordable credit. On March 27th, 2020, Congress signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act into law, which was a bill created to provide support and relief for American workers, families, and small businesses. This newly proposed Act also provides guidelines on how creditors and data furnishers should report information to credit bureaus, to ensure that lenders remain flexible as consumers navigate the current pandemic. The Act requires that creditors must provide “accommodations” to consumers affected by COVID-19 during “covered periods.” According to the National Credit Union Administration, “The CARES Act requires credit reporting agency data providers, including credit unions, to report loan modifications resulting from the COVID-19 pandemic as ‘current’ or as the status reported before the accommodation unless the consumer becomes current,” as stated in Section 4021. Section 4021 of the CARES Act also provides other guidelines for accurate data reporting. During this time, lenders can use attributes to determine risk during COVID-19. Attributes within custom scores can also capture consumer behavior and help lenders determine the best treatments. Payment attributes, debt burden attributes, inquiry attributes, credit extensions and originations are all key indicators to keep an eye on at this time as lenders monitor risk in their portfolios. Listen in as our panel of experts explore the areas related to data reporting that impact you the most. In addition to a regulatory update and discussions around programs to help support consumers and businesses, we’ll also review what other lenders are doing and early indicators of credit trends. You’ll also be able to walk away with key strategies around what your organization can do right now. Discover the latest information on: Data reporting and CDIA regulations Regulatory updates, including the CARES Act, a breakdown of Section 4021, and guidelines to remember Credit attribute trends and highlights, treatment of scores and attributes, as well as recommended attributes Watch the webinar

The coronavirus (COVID-19) outbreak is causing widespread concern and economic hardship for consumers and businesses across the globe – including financial institutions, who have had to refine their lending and downturn response strategies while keeping up with compliance regulations and market changes. As part of our recently launched Q&A perspective series, Shannon Lois, Experian’s Head of DA Analytics and Consulting and Bryan Collins, Senior Product Manager, tackled some of the tough questions for lenders. Here’s what they had to say: Q: What trends and triggers should lenders be prepared to react to? BC: Lenders are still trying to figure out how to assess risk between the broader, longer-term impacts of the pandemic and the near-term Coronavirus Aid, Relief, and Economic Security (CARES) Act that extends relief funds and deferment to consumers and small businesses. Traditional lending processes are not possible, lenders will have to adjust underwriting strategies and workflows as they deploy hardship programs while complying with the Act. From a utilization perspective, lenders need to look for near-term trends on payments, balances and skipped payments. From an extension standpoint, they should review limits extended or reduced by other lenders. Critical trends to look for would be missed or late auto payments, non-traditional credit shopping and rental payment delinquencies. Q: What should lenders be doing to plan for an uptick in delinquencies? SL: First, lenders should make sure they have a complete picture of how credit risk and losses are evolving, as well as any changes to their consumers’ affordability status. This will allow a pointed refinement of their customer management strategies (I.e. payment holidays, changing customer to cheaper product, offering additional services, re-pricing, term amendment and forbearance management.) Second, given the increased stress on collection processes and regulations guidelines, they should ensure proper and prepared staffing to handle increased call volumes and that agency outsourcing and automation is enabled. Additionally, lenders should migrate to self-service and interactive communication channels whenever possible while adopting new segmentation schemas/scores/attributes based on fresh data triggers to queue lower risk accounts entering collections. Q: How can lenders best help their customers? SL: Lenders should understand customers’ profiles with vulnerability and affordability metrics allowing changes in both treatment and payment. Payment Holidays are common in credit card management, consider offering payment freezes on different types of credit like mortgage and secured loans, as well as short term workout programs with lower interest rates and fee suppression. Additionally, lenders should offer self-service and FAQ portals with information about programs that can help customers in times of need. BC: Lenders can help by complying with aspects of the CARES Act guidance; they must understand how to deploy payment relief and hardship programs effectively and efficiently. Data integrity and accuracy of loan reporting will be critical. Financial institutions should adjust their collection and risk strategies and processes. Additionally, lenders must determine a way to address the unbanked population with relief checks. We understand how challenging it is to navigate the changing economic tides and will continue to offer support to both businesses and consumers alike. Our advanced data and analytics can help you refine your lending processes and better understand regulatory changes. Learn more About Our Experts: Shannon Lois, Head of DA Analytics and Consulting, Experian Data Analytics, North America Shannon and her team of analysts, scientists, credit, fraud and marketing risk management experts provide results-driven consulting services and state-of-the-art advanced analytics, science and data products to clients in a wide range of businesses, including banking, auto, credit, utility, marketing and finance. Shannon has been a presenter at many credit scoring and risk management conferences and is currently leading the Experian Decision Analytics advisory board. Bryan Collins, Senior Product Manager, Experian Consumer Information Services, North America Bryan is a member of Experian's CIS product management team, focusing on the Acquisitions suite and our evolving Ascend Identity Services Platform. With more than 20 years of experience in the financial services and credit industries, Bryan has established strong partnerships and a thorough understanding of client needs. He was instrumental in the launch of CIS's segmentation suite and led product management for lender and credit-related initiatives in Auto. Prior to joining Experian, Bryan held marketing and consumer experience roles in consumer finance, business lending and card services.

With new legislation, including the Coronavirus Aid, Relief, and Economic Security (CARES) Act impacting how data furnishers will report accounts, and government relief programs offering payment flexibility, data reporting under the coronavirus (COVID-19) outbreak can be complicated. Especially when it comes to small businesses, many of which are facing sharp declines in consumer demand and an increased need for capital. As part of our recently launched Q&A perspective series, Greg Carmean, Experian’s Director of Product Management and Matt Shubert, Director of Data Science and Modelling, provided insight on how data furnishers can help support small businesses amidst the pandemic while complying with recent regulations. Check out what they had to say: Q: How can data reporters best respond to the COVID-19 global pandemic? GC: Data reporters should make every effort to continue reporting their trade experiences, as losing visibility into account performance could lead to unintended consequences. For small businesses that have been negatively affected by the pandemic, we advise that when providing forbearance, deferrals be reported as “current”, meaning they should not adversely impact the credit scores of those small business accounts. We also recommend that our data reporters stay in close contact with their legal counsel to ensure they follow CARES Act guidelines. Q: How can financial institutions help small businesses during this time? GC: The most critical thing financial institutions can do is ensure that small businesses continue to have access to the capital they need. Financial institutions can help small businesses through deferral of payments on existing loans for businesses that have been most heavily impacted by the COVID-19 crisis. Small Business Administration (SBA) lenders can also help small businesses take advantage of government relief programs, like the Payment Protection Program (PPP), available through the CARES Act that provides forgiveness on up to 75% of payroll expenses and 25% of other qualifying expenses. Q: How do financial institutions maintain data accuracy while also protecting consumers and small businesses who may be undergoing financial stress at this time? GC: Following bureau recommendations regarding data reporting will be critical to ensure that businesses are being treated fairly and that the tools lenders depend on continue to provide value. The COVID-19 crisis also provides a great opportunity for lenders to educate their small business customers on their business credit. Experian has made free business credit reports available to every business across the country to help small business owners ensure the information lenders are using in their credit decisioning is up-to-date and accurate. Q: What is the smartest next play for financial institutions? GC: Experian has several resources that lenders can leverage, including Experian’s COVID-19 Business Risk Index which identifies the industries and geographies that have been most impacted by the COVID crisis. We also have scores and alerts that can help financial institutions gain greater insights into how the pandemic may impact their portfolios, especially for accounts with the greatest immediate exposure and need. MS: To help small businesses weather the storm, financial institutions should make it simple and efficient for them to access the loans and credit they need to survive. With cash flow to help bridge the gap or resume normal operations, small businesses can be more effective in their recovery processes and more easily comply with new legislation. Finances offer the support needed to augment currently reduced cash flows and provide the stability needed to be successful when a return to a more normal business environment occurs. At Experian, we’re closely monitoring the updates around the coronavirus outbreak and its widespread impact on both consumers and businesses. We will continue to share industry-leading insights to help data furnishers navigate and successfully respond to the current environment. Learn more About Our Experts Greg Carmean, Director of Product Management, Experian Business Information Services, North America Greg has over 20 years of experience in the information industry specializing in commercial risk management services. In his current role, he is responsible for managing multiple product initiatives including Experian’s Small Business Financial Exchange (SBFE), domestic and international commercial reports and Corporate Linkage. Recently, he managed the development and launch of Experian’s Global Data Network product line, a commercial data environment that provides a single source of up to date international credit and firmographic information from Experian commercial bureaus and Tier 1 partners across the globe. Matt Shubert, Director of Data Science and Modelling, Experian Data Analytics, North America Matt leads Experian’s Commercial Data Sciences Team which consists of a combination of data scientists, data engineers and statistical model developers. The Commercial Data Science Team is responsible for the development of attributes and models in support of Experian’s BIS business unit. Matt’s 15+ years of experience leading data science and model development efforts within some of the largest global financial institutions gives our clients access to a wealth of knowledge to discover the hidden ROI within their own data.  

Article written by Alex Lintner, Experian's Group President of Consumer Information Services and Sandy Anderson, Experian's Senior Vice President of Client and Sales Operations Many consumers are facing financial stress due to unemployment and other hardships related to the COVID-19 pandemic. Not surprisingly, data scientists at Experian are looking into how consumers’ credit scores may be impacted during the COVID-19 national emergency period as financial institutions and credit bureaus follow guidance from financial regulators and law established in Section 4021 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In a nutshell, Experian finds that if consumers contact their lenders and are granted an accommodation, such as a payment holiday or forbearance, and lenders report the accommodation accordingly, consumer scores will not be materially affected negatively. It’s not just Experian’s findings, but also those of the major credit scoring companies, FICO® and VantageScore®. FICO has reported that if a lender provides an accommodation and payments are reported on time consistent with the CARES Act, consumers will not be negatively impacted by late payments related to COVID-19. VantageScore® has also addressed this issue and stated that its models are designed to mitigate the impact of missed payments from COVID-19. At the same time, if as predicted, lenders tighten underwriting standards following 11 consecutive years of economic growth, access to credit for some consumers may be curtailed notwithstanding their score because their ability to repay the loan may be diminished. Regulatory guidance and law provide a robust response Recently, the Federal Reserve, along with the federal and state banking regulators, issued a statement encouraging mortgage servicers to work with struggling homeowners affected by the COVID-19 national emergency by allowing borrowers to defer mortgage payments up to 180-days or longer. The Federal Deposit Insurance Corporation stated that financial institutions should “take prudent steps to assist customers and communities affected by COVID-19.” The Office of the Comptroller of the Currency, which regulates nationally chartered banks, encouraged banks to offer consumers payment accommodations to avoid delinquencies and negative credit bureau reporting. This regulatory guidance was backed by Congress in passing the CARES Act, which requires any payment accommodations to be reported to a credit bureau as “current.” The Consumer Financial Protection Bureau, which has oversight of all financial service providers, reinforced the regulatory obligation in the CARES Act. In a statement, the Bureau said “the continuation of reporting such accurate payment information produces substantial benefits for consumers, users of consumer reports and the economy as a whole.” Moreover, the consumer reporting industry has a history of successful coordination during emergency circumstances, like COVID-19, and we’ve provided the support necessary for lenders to report accurately and consistent with regulatory guidance. For example, when a consumer faces hardship, a lender can add a code that indicates a customer or borrower has been “affected by natural or declared disaster.” If a lender uses this or a similar code, a notification about the disaster or other event will appear in the credit report with the trade line for the customer’s account and will remain on the trade line until the lender removes it. As a result, the presence of the code will not negatively impact the consumer credit score. However, other factors may impact a consumer’s score, such as an increase in a consumer’s utilization of their credit lines, which is a likely scenario during a period of financial stress. Suppression or Deletion of late payments will hurt, not help, credit scores In response to the nationwide impact of COVID-19, some lawmakers have suggested that lenders should not report missed payments or that credit bureaus should delete them. The presumption is that these actions would hold consumers harmless during the crisis caused by this pandemic. However, these good intentions end up having a detrimental impact on the whole credit ecosystem as consumer credit information is no longer accurately reflecting consumers’ specific situation. This makes it difficult for lenders to assess risk and for consumers to obtain appropriately priced credit. Ultimately, the best way to help is a consumer-specific solution, meaning one in which a lender reaches an accommodation with each affected individual, and accurately reflects that person’s unique situation when reporting to credit bureaus. When a consumer misses a payment, the information doesn’t end up on a credit report immediately. Most payments are monthly, so a consumer’s payment history with a financial institution is updated on a similar timeline. If, for example, a lender was required to suppress reporting for three months during the COVID-19 national emergency, the result would be no data flowing onto a credit report for three months. A credit report would therefore show monthly payments and then three months of no updates. The same would be true if a credit reporting agency were required to suppress or delete payment information. The lack of data, due to suppression or deletion, means that lenders would be blinded when making credit decisions, for example to increase a credit limit to an existing customer or to grant a new line of credit to a prospective customer. When faced with a blind spot, and unable to assess the real risk of a consumer’s credit history, the prudential tendency would be to raise the cost of credit, or to decrease the availability of credit, to cover the risk that cannot be measured. This could effectively end granting of credit to new customers, further stifling economic recovery and consumer financial health at a time when it’s needed most. Beyond the direct impact on consumers, suppression or deletion of credit information could directly affect the safety and soundness of the nation’s consumer and small business lending system. With missing data, lenders and their regulators would be flying blind as to the accurate information about a consumer’s risk and could result in unknowingly holding loan portfolios with heightened risk for loss. Too many unexpected losses threaten the balance of the financial system and could further seize credit markets. Experian is committed to helping consumers manage their credit and working with lenders on how best to report consumer-specific solutions. To learn more about what consumers can do to manage credit during the COVID-19 national emergency, we’ve provided resources on our website. For individuals looking to explore options their lenders may offer, we’ve included links to many of the companies and update them continuously. With good public policy and consumer-specific solutions, consumers can continue to build credit and help our economy grow.