Tag: model risk governance

Credit cards are the most widely available credit products offered to millions of consumers today. For many consumers, owning a credit card is a relatively simple step toward establishing credit history and obtaining access to other lending products later in life. For credit unions, offering a credit card to members expands and enriches the credit relationship. In today’s environment, some credit unions don’t view credit cards as an integral part of their member service. I propose that the benefits of credit cards in a credit union portfolio are impactful, meaningful and fully align to member outreach and community service. A high-level review of risk-adjusted yields across three of the most common retail products offered by credit unions show that credit cards can be very profitable. The average APR of credit cards as of Q3 2020 is just slightly below personal loans. While charge-offs as a percentage of balances are more than double of personal loans, the estimated risk-adjusted yield is still elevated and is 1.8 times higher than auto loan and leases. See Table 1. Table 1. Estimated average risk-adjusted yield for auto loan and lease, personal loan, and credit card for credit unions Auto loan and lease Personal loan Credit card Average APR 5.21% 12.05% 11.26% Charge-offs as % of balances (annualized) 0.28% 0.89% 1.98% Risk-adjusted yield 4.93% 11.16% 9.28% Notes: Average APR of auto loans and leases, personal loans, and charge-off information as of Q3 2020 was extracted from Experian-Oliver Wyman IntelliViewSM Market Intelligence Reports. IntelliView Market Intelligence Reports, Dec. 22, 2020, experian.com/decision-analytics/market-intelligence/intelliview. Average APR of credit card as of Q3 2020 was extracted from National Credit Union Administration website. Credit Union and Bank Rates 2020 Q3, Dec. 22, 2020, https://www.ncua.gov/analysis/cuso-economic-data/credit-union-bank-rates/credit-union-and-bank-rates-2020-q3. Estimated risk-adjusted yield is calculated as the difference between average APR and charge-offs. A profitable retail product allows a credit union to share those profits back with members consistent with its mission of promoting and supporting the financial health and well-being of its members. Credit cards provide diversification of income streams. Income diversification provides a level of stability across cyclical economic conditions when some types of credit exposures may perform poorly, while others may be more stable. When combined with sound and effective risk governance, credit diversification allows lenders to mitigate levels of concentration risks in their aggregate portfolio. Offering credit cards to members is one avenue to grow loan volume and achieve scale that’s sufficiently manageable for credit unions. Scale is particularly important today as it’s needed to fund technology investments. The pandemic accelerated the massive movement toward digital engagement, and scale makes technology investments more cost-effective.  When lenders become more productive and efficient, they further lower the cost of credit products to members. (Stovall, Nathan. Dec. 14, 2020. Desire to compete with megabanks driving more U.S. regional bank M&A — KBW CE blog. https://platform.mi.spglobal.com/web/client?auth=inherit#news/.) The barriers to offering credit cards have moderately declined. Technology partners, payment processors and specialized industry companies are available in the marketplace. The biggest challenge for credit unions and lenders is credit risk management. To be profitable and to stay relevant, credit cards require a relatively sophisticated risk management framework of underwriting criteria, pricing, credit line management, operations and marketing. Industry and specialized support for launching and managing credit cards is widely available and accessible. Analytics play an essential role in managing credit cards. With an average active life of approximately five years, credit card portfolios need regular and periodic performance reviews to manage inherent risk and to identify opportunities for growth and profitability. Account management for credit cards is equally as important as underwriting. Credit line management, authorization, activation and retention have significant impact to the performance of existing accounts. Continuous engagement with members is critical and has taken on a new meaning lately. Credit cards provide an opportunity to engage members, to grow lending relationships and to support financial well-being. Marketing and meaningful card offers drive card usage and relevance. They’re critical components in customer communication and service. The benefits of credit cards contribute positively to a credit union portfolio. With sound and effective risk management practices, credit cards are profitable, help diversify income streams, grow loan volume and support member credit needs.

Our clients are facing three primary issues when it comes to regulatory compliance: time resources knowledge Many are facing Matters Requiring Attention (MRA) and Matters Requiring Immediate Attention (MRIA) and don’t have the staff or the capacity to complete all of the work themselves within tight deadlines. They also want their limited resources to work on internal, proprietary initiatives to grow the business and maximize profit and return. These activities cannot be outsourced as easily as regulatory and compliance work, which is relatively easy to parse out and give to an external third party. Quite often, a level of independent oversight and effective challenge is also a requirement that can easily be solved through the use of an objective, external third party. A lot of the regulations are still relatively new, and there are still many issues and knowledge gaps our clients are facing. They have insight into their own organization only and quite often aren’t aware of or able to leverage industry best practice without the view of an external third party with broader industry knowledge and experience. In terms of best practice, it all really starts with the data, leading to the attributes used in models to create sound risk management strategies, manage capital adequacy, and ensure the safety and soundness of the overall U.S. and global financial system. The integrity of data reporting, dispute management and compliance with all applicable regulatory requirements need to be an enterprise-wide effort. In the area of attribute governance, there are three primary areas of focus: Attribution creation — definitions; logic, code and accuracy; and how to reduce implementation timelines. Monitoring and maintenance — looking for shifts in attributes and their potential impact and facilitating updates to attributes based upon changes in reporting and upgrades to newer versions of attributes as the credit environment changes, such as during the most recent mortgage crisis, where loan modification and associated attributes were created and took on increased importance. And last but definitely not least, documentation — We cannot say enough about the importance of documentation, especially to regulators. Documentation ensures accuracy and consistent application and must record all general conventions and limitations. For model risk management and governance, focus areas should follow the expanded Office of the Comptroller of the Currency (OCC) Guidance from Bulletin 2011-12. This guidance includes expanded requirements for model validations including not just standard back testing, but also benchmarking, effective challenge, sensitivity analysis and stress testing. It also expands the guidance beyond just validation to model development and usage, implementation, governance and controls. In response to these OCC expanded guidance requirements, one of our clients was seeking an industry expert to serve as an independent third party to 1) conduct industry best practice and benchmarking in areas of reject inference methodologies and 2) validate production models used for risk underwriting, line assignment, pricing and targeting. After a full review and assessment, we provided the client with a clear road map to improve the process to conduct reject inference through knowledge transfer and best practices. We established a best-in-class approach to annual model validations on a model inventory consisting of retail, small business and wealth segment portfolios. We also delivered expedited results that also identified alternative methods of validation that assess variability in point estimates, as well as comply with OCC requirements for precision, ranking and population measurement statistics. Through our work, the client was able to leverage Experian to establish a global approach to reject inference methodologies, to augment existing staffing and to offshore resources in a cost-effective manner. There are three primary areas of loss forecasting, stress testing and capital adequacy planning: International —  Basel accord National — U.S. Dodd-Frank Act Stress Testing (DFAST), including Comprehensive Capital Analysis and Review (CCAR) supervisory review Internal — Allowance for Loan and Lease Losses requirements Although there are similarities, there are also important differences among each of these three requirements and practices. For these reasons, most financial institutions in the United States are still providing and managing them separately. This obviously creates a strain on internal staff and resources. One of our clients had an initial compliance strategy in place but did not have the sufficient in-house staff and resources required to create, document and review its modeling and stress testing to satisfy regulators and internal auditors. The organization needed a consultant that could work closely with its in-house team to support sophisticated models that were tailored to meet its specific compliance obligations. We worked closely with the client’s team to provide extensive consulting support for a complex set of loss-forecasting models and other tools, applying industry best practices to fully document the models. Throughout the process, our consulting team discovered and identified content gaps to help ensure that all documentation was complete. We also provided ad hoc analytics to support the client’s model development effort and strategic and tactical guidance on stress testing model development for compliance. This enabled the client to develop primary and challenge models for DFAST’s CCAR requirements, as well as internal stress scenarios. It also provided the client with the following tangible business benefits: balance compliance with maximum profitability and revenue; provided knowledge sharing and best practices to help empower client employees; helped refine models based on feedback from internal and external governance organizations; supported models with academic research to help align the correct model to the correct processes; and provided assistance with model implementation and application. Click here for a recent video I did on how capital-adequacy positions are becoming crucial in analyst recommendations.