Tag: Loss Forecasting

Despite the constant narrative around “unprecedented times” and the “new normal,” if the current market volatility tells us anything, it’s to go back to basics. As financial institutions navigate COVID-19’s economic impact, and challenges that are likely to be different or more extreme than in the past, the best credit portfolio management practices are fundamental. The global pandemic impacts today’s data as existing data and analytics may not accurately reflect what is happening now, resulting in inaccurate portfolio assessment. In order to successfully navigate loss forecasting, predicting borrower behavior and controlling loss ratios, lenders must engage new data, analytics and economic scenarios suited for today’s changing times. In Experian’s latest white paper, “Credit Portfolio Management After the COVID-19 Recession,” we’ll explore best practices to combat the following challenges: Forecasting credit losses despite increased economic volatility Businesses have long used a variety of data, analytics and models to anticipate and project the future direction of their organization based on a number of data points; however, with the onset of the global pandemic, long-standing scenarios became suddenly irrelevant.   Predicting borrower behavior given increased financial disparities The post-pandemic and pre-pandemic worlds are very different places for some borrowers. Pandemic-related job losses and other economic effects will not be spread evenly and this variability may be reflected in lenders’ portfolios.   Controlling loss ratios In the post-COVID world, it will be mission critical for lenders to use high-quality and up-to-date data to balance priorities and identify which areas of their portfolio need attention now.   Whether your portfolio is doing better than expected, as expected, or worse than expected, now is the time to refresh portfolio management strategy. Lenders should be watching for early indicators in loan portfolios to better navigate a fluctuating economy and that requires new resources and better tools. Take control of your business’ trajectory. Download now

Today, Experian and Oliver Wyman launched the Ascend Portfolio Loss ForecasterTM, a solution built to help lenders make better decisions – during COVID-19 and beyond – with customized forecasts and macroeconomic data. Phrases like “the new normal,” “unprecedented times,” and “extreme economic volatility” have flooded not only media for the last few months, but also financial institutions’ strategic discussions regarding plans to move forward. What has largely been crisis response is quickly shifting to an urgent need to answer the many questions around “Will we survive this crisis?,” let alone “What’s next?” And arguably, we’ve entered a new era of loss forecasting. After the longest period of economic growth in post-war U.S. history, previously built models are not sufficient for the unprecedented and sudden changes in economic conditions due to COVID-19. Lenders need instant insights to assess impact and losses to their portfolios. The Ascend Portfolio Loss Forecaster combines advanced modeling from Oliver Wyman,  pandemic-specific insights and macroeconomic scenarios from Oxford Economics, and Experian’s quality data to analyze and produce accurate loan loss forecasts. Additionally, all of the data, including the forecasts and models, are regularly updated as macroeconomic conditions change. “Experian’s agility and innovative technologies allow us to help lenders make informed decisions in real time to mitigate future risk,” said Greg Wright, chief product officer of Experian’s Consumer Information Services, in a recent press release. “We’re proud to work with our partners, Oxford Economics and Oliver Wyman, to bring lenders a product powered by machine learning, comprehensive data and macroeconomic forecast scenarios.” Built using advanced modeling and expert scenarios, the web-based application maximizes the more than 15 years of Experian’s loan-level data, including VantageScore® credit score, bankruptcy scores and customer-level attributes.  Financial institutions can gauge loan portfolio performance under various scenarios. “It is important that the banks take into account the evolving credit behaviors due to the COVID-19 pandemic, in addition to the robust modeling technique for their loss forecasting and strategic decisioning,” said Anshul Verma, senior director of products at Oliver Wyman, also in the release. “With the Ascend Portfolio Loss Forecaster, lenders get robust models that work in the current conditions and take into account evolving consumer behaviors,” Verma said. To watch Experian’s webinar on portfolio loss forecasting, please click here and to learn more about the Ascend Portfolio Loss Forecaster, click the button below. Learn More

While an overdue economic downturn has been long discussed, arguably no one could have foreseen the economic disruption from COVID-19 to the extent that’s been witnessed thus far. But now that we’re here, is there a line of sight to financial institutions’ next move? With the current situation marked by a history-making rise in unemployment, massive amounts of uncertainty within the market as well as for consumers and small businesses and consumer spending changes, loss forecasting is more important now than ever before. After the longest period of economic growth in history, financial institutions are caught off guard. While large banks are more prepared as they have stress testing capabilities in place and are estimating the potential large impact on their loss allowances, the since-delayed CECL requirements emphasized forecasting for the masses, and yet many are still under-equipped. Loss forecasting has evolved from a need for a small few to now a necessary strategy for all. While some financial institutions will look to loss forecasting to potentially reduce the severity of impact for the path ahead during these times (or even how they might come out stronger than their competition), for many, loss forecasting is the key to survival. Bare necessities. Understanding the possible outcomes of the pandemic’s impact is necessary to make critical business decisions. Lenders are likely receiving numerous questions about their portfolios and possible outcomes. These questions include, but are not limited to: What could the range of outcomes to my portfolio based on expert forecasts of macroeconomic conditions? How will I make lending decisions in the short term? Do my models need to change? How bad could charge offs be for my portfolio? If I have reduced marketing and application flows, at what point do I need to begin opening new accounts or consider portfolio acquisitions? How can lenders get answers? Loss forecasting. As Mohammed Chaudhri, Experian Chief Economist, said, “Loss forecasting is more pivotal than ever…existing models are not going to be up to the task of accurately predicting losses.” Whatever questions you’re receiving, you need certain necessary pieces of information to navigate this new era of loss forecasting. Those pieces are frequently updated client and industry data; ongoing access to expert macroeconomic forecasts; and sophisticated and evolved forecasting models. Client and Industry Data Loan-level data, bankruptcy scores and customer-level attributes are key insights to fueling loss forecasting models. By combining several data sets and scores (and a comprehensive history of both) your organization can see greater benefits. Macroeconomic Forecasts As has been mentioned numerous times, the economic impact resulting from COVID-19 is not at all like the Great Recession. As such, leveraging macroeconomic forecasts, and specifically COVID-19 forecasts, is critical to analyzing the potential impacts to your organization. Sophisticated Models Whether building models on your own or leveraging an expert, the key ingredients include the innerworkings of the model, leveraging historical data and making sure that both the models and the data are updated regularly to ensure you have the most accurate, thorough forecasts available. Also, leveraging machine learning tools is imperative for model specification and evaluation. Fortunately, while model building and loss forecasting used to be synonymous with countless resources and dollar signs, innovation and digital transformation have made these strategies within reach for financial institutions of all sizes. Incorporating the right data (and ensuring that data is regularly updated), with the right tools and macroeconomic scenarios (including COVID-19, upside, baseline, adverse and severely adverse scenarios) enables you to get a line of sight into the actions you need to take now. Empowered with insights to compare and benchmark results, discover the cause of changes in results, explore result scenarios in advance, and access recommended optimizations, loss forecasting enables you to focus on the critical decisions your business depends on. Experian helps you with loss forecasting for now and the future. For more information, including an on-demand webinar Experian presented with Oliver Wyman as well as the opportunity to engage Experian experts into your loss forecasting strategy, please click the button below. Learn More

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.

Today, Experian and Oliver Wyman announced the launch of Ascend CECL ForecasterTM, a solution built to help financial institutions of all sizes more quickly and accurately forecast lifetime credit losses. The Financial Accounting Standards Board’s current expected credit loss (CECL) model has been a hot discussion topic throughout the financial services industry - first when it was announced (and considered one of the most significant accounting changes in decades), and most recently with the FASB’s delay for implementation for smaller lenders. As the compliance deadlines approach, Experian and Oliver Wyman have joined forces to help financial institutions adhere their loan portfolios to the new guidelines. Delivered through Experian’s Ascend Technology PlatformTM, Ascend CECL Forecaster is a new user-friendly, web-based application that combines Experian’s vast loan-level data and Premier AttributesSM, third-party macroeconomic data, valuation data and Oliver Wyman’s industry-leading CECL modeling methodology to accurately calculate potential losses over the life of a loan. “Ascend CECL Forecaster is a critical capability needed urgently by all lending and financial institutions,” said Ash Gupta, a Senior Advisor to Oliver Wyman and former Chief Risk Officer for American Express, in a press release. “The collaboration between Experian and Oliver Wyman allows a frictionless synthesis of industry data, capabilities and experience to serve customers in both first and second line of defense.” The premise behind the model, which will need access to more data than that used to calculate reserves under the incurred loss model, Allowance for Loan and Lease Losses (ALLL), is for financial institutions to estimate the expected loss over the life of a loan by using historical information, current conditions and reasonable forecasts. Built using advanced machine learning and statistical techniques, the web-based application maximizes the more than 15 years of historical credit data spanning previous economic cycles to help financial institutions gauge loan portfolio performance under various scenarios. Ascend CECL Forecaster does not require additional data nor does it require a secondary integration from the financial institution and enables organizations to more quickly test their portfolios under different economic factors. Moreover, financial institutions receive guidance from industry experts to assist with implementation and strategy. Additionally, Experian and Oliver Wyman will host a webinar to help financial institutions better understand and prepare for the upcoming CECL standards. Register today! Read the Press Release Register for Webinar

Financial institutions preparing for the launch of the Financial Accounting Standard Board’s (FASB) new current expected credit loss model, or CECL, may have concerns when it comes to preparedness, implications and overall impact. Gavin Harding, Experian’s Senior Business Consultant and Jose Tagunicar, Director of Product Management, tackled some of the tough questions posed by the new accounting standard. Check out what they had to say: Q: How can financial institutions begin the CECL transition process? JT: To prepare for the CECL transition process, companies should conduct an operational readiness review, which includes: Analyzing your data for existing gaps. Determining important milestones and preparing for implementation with a detailed roadmap. Running different loss methods to compare results. Once losses are calculated, you’ll want to select the best methodology based on your portfolio. Q: What is required to comply with CECL? GH: Complying with CECL may require financial institutions to gather, store and calculate more data than before. To satisfy CECL requirements, financial institutions will need to focus on end-to-end management, determine estimation approaches that will produce reasonable and supportable forecasts and automate their technology and platforms. Additionally, well-documented CECL estimations will require integrated workflows and incremental governance. Q: What should organizations look for in a partner that assists in measuring expected credit losses under CECL? GH: It’s expected that many financial institutions will use third-party vendors to help them implement CECL. Third-party solutions can help institutions prepare for the organization and operation implications by developing an effective data strategy plan and quantifying the impact of various forecasted conditions. The right third-party partner will deliver an integrated framework that empowers clients to optimize their data, enhance their modeling expertise and ensure policies and procedures supporting model governance are regulatory compliant. Q: What is CECL’s impact on financial institutions? How does the impact for credit unions/smaller lenders differ (if at all)? GH: CECL will have a significant effect on financial institutions’ accounting, modeling and forecasting. It also heavily impacts their allowance for credit losses and financial statements. Financial institutions must educate their investors and shareholders about how CECL-driven disclosure and reporting changes could potentially alter their bottom line. CECL’s requirements entail data that most credit unions and smaller lenders haven’t been actively storing and saving, leaving them with historical data that may not have been recorded or will be inaccessible when it’s needed for a CECL calculation. Q: How can Experian help with CECL compliance? JT: At Experian, we have one simple goal in mind when it comes to CECL compliance: how can we make it easier for our clients? Our Ascend CECL ForecasterTM, in partnership with Oliver Wyman, allows our clients to create CECL forecasts in a fraction of the time it normally takes, using a simple, configurable application that accurately predicts expected losses. The Ascend CECL Forecaster enables you to: Fulfill data requirements: We don’t ask you to gather, prepare or submit any data. The application is comprised of Experian’s extensive historical data, delivered via the Ascend Technology PlatformTM, economic data from Oxford Economics, as well as the auto and home valuation data needed to generate CECL forecasts for each unsecured and secured lending product in your portfolio. Leverage innovative technology: The application uses advanced machine learning models built on 15 years of industry-leading credit data using high-quality Oliver Wyman loan level models. Simplify processes: One of the biggest challenges our clients face is the amount of time and analytical effort it takes to create one CECL forecast, much less several that can be compared for optimal results. With the Ascend CECL Forecaster, creating a forecast is a simple process that can be delivered quickly and accurately. Q: What are immediate next steps? JT: As mentioned, complying with CECL may require you to gather, store and calculate more data than before. Therefore, it’s important that companies act now to better prepare. Immediate next steps include: Establishing your loss forecast methodology: CECL will require a new methodology, making it essential to take advantage of advanced statistical techniques and third-party solutions. Making additional reserves available: It’s imperative to understand how CECL impacts both revenue and profit. According to some estimates, banks will need to increase their reserves by up to 50% to comply with CECL requirements. Preparing your board and investors: Make sure key stakeholders are aware of the potential costs and profit impacts that these changes will have on your bottom line. Speak with an expert

What is CECL? CECL (Current Expected Credit Loss) is a new credit loss model, to be leveraged by financial institutions, that estimates the expected loss over the life of a loan by using historical information, current conditions and reasonable forecasts. According to AccountingToday, CECL is considered one of the most significant accounting changes in decades to affect entities that borrow and lend money. To comply with CECL by the assigned deadline, financial institutions will need to access much more data than they’re currently using to calculate their reserves under the incurred loss model, Allowance for Loan and Lease Losses (ALLL). How does it impact your business? CECL introduces uncertainty into accounting and growth calculations, as it represents a significant change in the way credit losses are currently estimated. The new standard allows financial institutions to calculate allowances in a variety of ways, including discounted cash flow, loss rates, roll-rates and probability of default analyses. “Large banks with historically good loss performance are projecting increased reserve requirements in the billions of dollars,” says Experian Advisory Services Senior Business Consultant, Gavin Harding. Here are a few changes that you should expect: Larger allowances will be required for most products As allowances will increase, pricing of the products will change to reflect higher capital cost Losses modeling will change, impacting both data collection and modeling methodology There will be a lower return on equity, especially in products with a longer life expectancy How can you prepare? “CECL compliance is a journey, rather than a destination,” says Gavin. “The key is to develop a thoughtful, data-driven approach that is tested and refined over time.” Financial institutions who start preparing for CECL now will ultimately set their organizations up for success. Here are a few ways to begin to assess your readiness: Create a roadmap and initiative prioritization plan Calculate the impact of CECL on your bottom line Run altered scenarios based on new lending policy and credit decision rules Understand the impact CECL will have on your profitability Evaluate current portfolios based on CECL methodology Run different loss methods and compare results Additionally, there is required data to capture, including quarterly or monthly loan-level account performance metrics, multiple year data based on loan product type and historical data for the life of the loan. How much time do you have? Like most accounting standards, CECL has different effective dates based on the type of reporting entity. Public business entities that file financial statements with the Security and Exchange Commission will have to comply by 2020, non-public entity banks must comply by 2022 and non-SEC registered companies have until 2023 to adopt the new standard. How can we help: Complying with CECL may require you to gather, store and calculate more data than before. Experian can help you comply with CECL guidelines including data needs, consulting and loan loss calculation. Experian industry experts will help update your current strategies and establish an appropriate timeline to meet compliance dates. Leveraging our best-in-class industry data, we will help you gain CECL compliance quickly and effectively, understand the impacts to your business and use these findings to improve overall profitability. Learn more

Day 2 at this year’s Vision conference was fueled with new technology and inspiration. The morning session opened with Robert Boxberger, Experian President, Decision Analytics, and also featured two live demos, one on Experian’s solution for the upcoming CECL compliance deadline and the second for mobile credit, including two use cases on instant issuance and lead generation, which has resulted in a 28% conversion rate of hot leads for one of Experian’s marquee clients. Keynote Speaker: Aimée Mullins "Get comfortable with the uncomfortable" was just one of the mantras shared on Tuesday morning by Aimée Mullins, an actor, Olympian, TEDTalk speaker, and one of the youngest honorees to be inducted into the National Women’s Hall of Fame, among many other accomplishments. “It is our uniqueness that’s our greatest asset that we can leverage for our greatest strength,” said Mullins during her keynote centered on achieving the “impossible.” As a bi-lateral amputee (or “double BK” also known as double below-the-knee amputee, as she referenced), Mullins had doctors and experts tell her and her parents what she would not be able to do. Instead, she encouraged Tuesday’s audience to never stop thinking like a child, to use their curiosity to find new ways where you want to go, and to practice curiosity like a sport to keep from getting comfortable, and therefore static. “It made my not knowing what I can do so much more powerful than an expert's presumption of what he thought I could do,” she said. Session Highlights – Day 2 Consumer Trust What engenders trust as consumers? And what does it take to build online trust? With 51% of new account fraud victims personally knowing the perpetrator and 3.4 billion total losses from fraudulent account openings (Javelin Feb 2019), there are five key components to building trust: digital adoption, transparency, fraud management, recognition and authentication. Today’s consumers want to use the digital channel, have both security and ease of access, be recognized, know how their personal information is being used, and engage and trust with biometrics. Artificial Intelligence – Chat Bots and Beyond According to Gartner, “'Conversational AI-first' will supersede ‘cloud-first,’ ‘mobile first’ as the most important high-level imperative for the next 10 years.” As evidenced by Google Duplex’s realistic conversations with humans, including the use of “uh” and “um,” conversational AI is positioned to redefine the next generation of human interface, aimed at achieving better customer satisfaction and elevate the customer relationship. Marketing Analytics The marketing analytics landscape is changing. Today’s marketing problems – including the always limited budget and need to produce greater ROI – require tactical strategies to target the right consumers. Enter Experian’s AscendTM marketing platform. Leveraging this tool, including its neural networks that were demonstrated Monday morning, helps gain new insights into consumer behavior. Fraud in the Digital Wild West A panel discussion featuring representatives from Merchant Risk Council, USAA and Alliance Data compared fighting fraud to herding cats. Challenges discussed included the ongoing struggle to find balance between limiting friction during the authentication process, while also protecting customers, as well as fraudsters’ tendencies to tap into victims’ emotions and curiosity (think phishing schemes). As one of the panelists offered as a piece of advice, “Fraudsters share best practices, so should we.” Visibility for the Invisibles People are more than the sum of their parts. The traditional credit score may show a consumer’s reputation, but layering trended and alternative data sets adds their character. Not only can trended data and alternative credit data – including leveraging education attributes – make invisible consumers visible, they can also reveal that a consumer with a presumably superlative credit score is actually a “credit zombie.” These data sets enable the opportunity to create first chances, drive second chances and re-evaluate risk, while also driving a strong growth strategy. CECL After reviewing the basics of CECL and the upcoming deadlines (ranging from Q1 2020 to Q1 2022), a review of CECL compliance challenges and potential product changes preceded a modeling techniques case study and a list of key impacts to businesses. Those impacts include: product profitability, loss forecasting methodology, data management and processes and capital ratios. Experian’s CECL forecasting solution leverages Experian’s extensive historical data and Ascend Analytical Sandbox. Using a best practice modeling pipeline to improve efficiency and reduce operational risks, the solution combines advanced machine learning, traditional model techniques and modeling experience to improve performance and reduce risk of overfitting. Keynote Speaker: Kobe Bryant Kobe Bryant closed out the day with stories from his highly-decorated 20-year career with the Los Angeles Lakers, some tips on trash talk and lessons in leadership. “I had to figure out how to be undeniable,” Bryant said, on competing for minutes at the start of his career. In addition to his basketball legacy, including wining five NBA championships, being named an NBA MVP, a two-time NBA Finals MVP and winning two Olympic gold medals, Bryant also launched the Kobe and Vanessa Bryant Family Foundation, hosts the Kobe Academy and has formed Kobe Inc. He’s a storyteller, an Oscar winner, and his name has become synonymous with standing for uncompromising excellence. How to be successful? “Make sure you have the right people on the team,” Bryant said. “Passionate. Borderline obsessive.” One of his key takeaways from his basketball career that translates to his leadership on and off the court happened when his pre-game and game time thinking shifted from internal to external. “You have to put yourself 2nd, 3rd, 4th…you have to put the team first,” Bryant said.   For more coverage, follow #ExperianVision on Twitter or check the Experian Insights LinkedIn page.  

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

In recent months, the topics of stress-testing and loss forecasting have been at the forefront of the international media and, more importantly, at the forefront of the minds of American banking executives. The increased involvement of the federal government in managing the balance sheets of the country’s largest banks has mixed implications for financial institutions in this country. On one hand, some banks have been in the practice of building macroeconomic scenarios for years and have tried and tested methods for risk management and loss forecasting. On the other hand, in financial institutions where these practices were conducted in a less methodical manner, if at all, the scrutiny placed on capital adequacy forecasting has left many looking to quickly implement standards that will address regulatory concerns when their number is called. For those clients to whom this process is new, or for those who do not possess a methodology that would withstand the examination of federal inspectors, the question seems to be – where do we begin? I think that before you can understand where you’re going, you must first understand where you are and where you have been. In this case, it means having a detailed understanding of key industry and peer benchmarks and your relative position to those benchmarks. Even simple benchmarking exercises provide answers to some very important questions. • What is my risk profile versus that of the industry? • How does the composition of my portfolio differ from that of my peers? • How do my delinquencies compare to those of my peers? How has this position been changing? By having a thorough understanding of one’s position in these challenging circumstances, it allows for a more educated foundation upon which to build assessments of the future.