Tag: compliance

As E-Government customer demand and opportunity increases, so too will regulatory requirements and associated guidance become more standardized and uniformly adopted.  Regardless of credentialing techniques and ongoing access management, all enrollment processes must continue to be founded in accurate and, most importantly, predictive risk-based authentication. Such authentication tools must be able to evolve as new technologies and data assets become available, as compliance requirements and guidance become more defined, and as specific fraud threats align with various access channels and unique customer segments. A risk-based fraud detection system allows institutions to make customer relationship and transactional decisions based not on a handful of rules or conditions in isolation, but on a holistic view of a customer’s identity and predicted likelihood of associated identity theft.  To implement efficient and appropriate risk-based authentication procedures, the incorporation of comprehensive and broadly categorized data assets must be combined with targeted analytics and consistent decisioning policies to achieve a measurably effective balance between fraud detection and positive identity proofing results. The inherent value of a risk-based approach to authentication lies in the ability to strike such a balance not only in a current environment, but as that environment shifts as do its underlying forces. The National Institute of Standards and Technology, in special publication 800-63, defines electronic authentication (E-authentication) as “the process of establishing confidence in user identities electronically presented to an information system”. Since, as stated in publication 800-63, “individuals are enrolled and undergo an identity proofing process in which their identity is bound to an authentication secret, called a token”, it is imperative that identity proofing is founded in an approach that generates confidence in the authentication process. Experian believes that a risk-based approach that can separate valid from invalid identities using a combination of data and proven quantitative techniques is best. As “individuals are remotely authenticated to systems and applications over an open network, using a token in an authentication protocol”, enrollment processes that drive ultimate provision of tokens must be implemented with an eye towards identity risk, and not simply a series of checks against one or more third party data assets. If the “keys to the kingdom” are housed in the ongoing use of tokens provided by Credentials Service Providers (CRA) and binding credentials to that token, trusted Registration Authorities (RA) must employ highly predictive identity proofing techniques designed to segment true, low-risk identities from identities that may have been manipulated, fabricated, or in true-form are subject to fraudulent use, abuse or victimization. Many compliance-oriented authentication requirements (ex. USA PATRIOT Act, FACTA Red Flags Rule) and resultant processes hinge upon identity element (ex. name, address, Social Security number, phone number) validation and verification checks. Without minimizing the importance of performing such checks, the purpose of a more risk-based approach to authentication is to leverage other data sources and quantitative techniques to further assess the probability of fraudulent behavior.

Working with clients in the financial sector means keeping an eye toward compliance and regulations like the Gramm-Leach-Bliley Act (GLB), the Fair Credit Reporting Act (FCRA) or Fair and Accurate Credit Transactions Act (FACTA). It doesn’t really matter what kind of product it is, if a client is a financial institution (FI) of some kind, one of these three pieces of legislation is probably going to apply. The good part is, these clients know it and typically have staff dedicated to these functions. In my experience, where most clients need help is in understanding which regulations apply or what might be allowed under each. The truth is, a product designed to minimize fraud, like knowledge based authentication, will function the same whether using FCRA regulated or non-FCRA regulated data. The differences will be in the fraud models used with the product, the decisioning strategies set-up, the questions asked and the data sources of those questions. Under GLB it is acceptable to use fraud analytics for detection purposes, as fraud detection is an approved GLB exception. However, under FCRA rules, fraud detection is not a recognized permissible purpose (for accessing a consumer’s data). Instead, written instructions (of the consumer) may be used as the permissible purpose, or another permissible purpose permitted under FCRA; such as legitimate business need due to risk of financial loss. Fraud best practices dictate engaging with clients, and their compliance teams, to ensure the correct product has been selected based on client fraud trends and client needs. A risk based authentication approach, using all available data and appropriately decisioning on that data, whether or not it includes out of wallet questions, provides the most efficient management of risk for clients and best experience for consumers.