Tag: regulations

“Disruption has caused enormous amounts of innovation,” said Jennifer Schulz, CEO of Experian, North America. “We must continue to be the disruptors in our industry which takes effort, data, technology, bright minds and vision for what the future will be.” Schulz kicked off the 39th Vision conference with a future-focused keynote delivered to a crowd of more than 400 attendees. Alex Lintner, Group President, Experian Consumer Information Services, talked about the next phase of great, highlighting the digital transformation that has taken place in the generations of the past and the disruption and innovation happening today and in the future. Keynote speaker: Dr. Mohamed A. El-Erian Dr. Mohamed A. El-Erian, renowned economist and author, President of Queens’ College, Cambridge, Chief Economic Advisor at Allianz, Chair of President Obama’s Global Development Council and Former CEO and Co-Chief Investment Officer of PIMCO, spoke about the Fed, inflation, negative interest rates and the labor market, as well as the importance of inclusion. El-Erian, who said he reads the Financial Times religiously, acknowledged that we will make mistakes on the journey as we work to be even more inclusive. To navigate what’s ahead, he said we will need resilience, optionality and agility. “It’s important to connect with information, acknowledge the insecurity, in a language people understand, in order to connect,” he said.     Session highlights – day 1 The conference hall was buzzing with conversations, discussions and thought leadership. Buy Now Pay Later A large audience was in attendance for a session that introduced Experian’s Buy Now Pay Later Bureau™ and explored how it’s the first and only solution of its kind — serving consumers, BNPL providers, financial institutions and regulators. Identity Identity is constantly evolving, and while biometrics and authentication may have become ubiquitous, there is much activity around the concepts of eIDs, identity wallets and identity networks. Experian is making identities personal and helping businesses to recognize, manage and connect customer identities in new ways using data, analytics and technology. Marketing In today’s hypercompetitive world, businesses need to engage the freshest data and increase velocity when it comes to time to market. An average of 120 days won’t cut it. Ascend Marketing speeds time to market and helps achieve higher ROI. Regulatory Landscape With so much happening at Capitol Hill, a panel of experts from DC discussed a number of topics and proposals (and their impacts), including the defense for risk-based pricing, the impact of suppressing negative data, and trending topics like Buy Now Pay Later and data portability. All the while, the tech showcase had a constant flow of attendees with demos ranging from data and decisioning to financial inclusion and technology. This is just the beginning. And as Schulz said, “There’s more to do.” More insights from Vision to come. Follow @ExperianVision to see more of the action.

Lenders are under pressure to improve access to financial services, but can it also be a vehicle for driving growth? With the global pandemic and social justice movements exposing societal issues of equity, financial institutions are being called upon to do their part to address these problems, too. Lenders are increasingly under pressure to improve access to the financial system and help close the wealth gap in America.  Specifically, there are calls to improve financial inclusion – the process of ensuring financial products and services are accessible and affordable to everyone. Financial inclusion seeks to remove barriers to accessing credit, which can ultimately help individuals and businesses create wealth and elevate communities. Activists and regulators have singled out the current credit scoring system as a significant obstacle for a large portion of U.S. consumers.  From an equity standpoint, tackling financial inclusion is a no-brainer: better access to credit allows more consumers to secure safer housing and better schools, which could lead to higher-paying jobs, as well as the ability to start businesses and get insurance. Being able to access credit in a regulated and transparent way underpins financial stability and prosperity for communities and is key to creating a stronger economic system. Beyond “doing the right thing," research shows that financial inclusion can also fuel business growth for lenders.  Get ahead of the game  There is mounting regulatory pressure to embrace financial inclusion, and financial institutions may soon need to comply with new mandates. Current lending practices overlook many marginalized communities and low-income consumers, and government agencies are seeking to change that.  Government agencies and organizations, such as the Consumer Financial Protection Bureau (CFPB) and Office of the Comptroller of the Currency (OCC), are requiring greater scrutiny and accountability of financial institutions, working to overhaul the credit reporting system to ensure fairness and equality.  As a lender, it makes good business sense to tackle this problem now. For starters, as more institutions embrace Corporate Social Responsibility (CSR) mandates—something that's increasingly demanded by shareholders and customers alike—financial inclusion is a natural place to start. It demonstrates a commitment to CSR principles and creates a positive brand built on equity.  Further, financial institutions that embrace these changes gain an early adopter advantage and can build a loyal customer base. As these consumers begin to build wealth and expand their use of financial products, lenders will be able to forge lifelong relationships with these customers.  Why not get a head start on making positive organizational change before the law compels it?  Grow your business (and profits)  To be sure, financial inclusion is a pressing moral imperative that financial institutions must address. But financial inclusion doesn't come at the expense of profit. It represents an enormous opportunity to do business with a large, untapped market without taking on additional risk. In many instances, unscorable and credit invisible consumers exhibit promising credit characteristics, which the conventional credit scoring system does not yet recognize.  Consider consumers coming to the U.S. from other countries. They may have good credit histories in their home countries but have not yet established a credit history here. Likewise, many young, emerging consumers haven't generated enough history to be categorized as creditworthy. And some consumers may simply not utilize traditional credit instruments, like credit cards or loans. Instead, they may be using non-bank credit instruments (like payday loans or buy-now-pay-later arrangements) but regularly make payments.  Ultimately, because of the way the credit system works, research shows that lenders are ignoring almost 20 percent of the U.S. population that don't have conventional credit scores as potential customers. These consumers may not be inherently riskier than scored consumers, but they often get labelled as such by the current credit scoring system. That's a major, missed opportunity!  Modern credit scoring tools can help fill the information gap and rectify this. They draw on wider data sources that include consumer activities (like rent, utility and non-bank loan payments) and provide holistic information to assist with more accurate decisioning. For example, Lift Premium™ can score 96 percent of Americans with this additional information—a vast improvement over the 81 percent who are currently scored with conventional credit data.1 By tapping into these tools, financial institutions can extend credit to underserved populations, foster consumer loyalty and grow their portfolio of profitable customers.  Do good for the economy  Research suggests that financial inclusion can provide better outcomes for both individuals and economies. Specifically, it can lead to greater investment in education and businesses, better health, lower inequality, and greater entrepreneurship.  For example, an entrepreneur who can access a small business loan due to an expanded credit scoring model is subsequently able to create jobs and generate taxable revenue. Small business owners spend money in their communities and add to the tax base – money that can be used to improve services and attract even more investment.  Of course, not every start-up is a success. But if even a portion of new businesses thrive, a system that allows more consumers to access opportunities to launch businesses will increase that possibility.  The last word  Financial inclusion promotes a stronger economy and thriving communities by opening the world of financial services to more people, which benefits everyone. It enables underserved populations to leverage credit to become homeowners, start businesses and use credit responsibly—all markers of financial health. That in turn creates generational wealth that goes a long way toward closing the wealth gap.  And widening the credit net also enables lenders to uncover new revenue sources by tapping new creditworthy consumers. Expanded data and advanced analytics allow lenders to get a fuller picture of credit invisible and unscorable consumers. Opening the door of credit will go a long way to establishing customer loyalty and creating opportunities for both consumers and lenders.  Learn more

The collections landscape is changing as a result of new and upcoming legislation and increased expectations from consumers. Because of this, businesses are looking to create more effective, consumer-focused collections processes while remaining within regulatory guidelines. Our latest tip sheet has insights that can help businesses and agencies optimize their collections efforts and remain compliant, including:   Start with the best data Keep pace with changing regulations Focus on agility Pick the right partner Download the tip sheet to learn how to maximize your collections efforts while reducing costs, avoiding reputational damage and fines, and improving overall engagement. Download tip sheet

The Telephone Consumer Protection Act (TCPA), which regulates telemarketing calls, autodialed calls, prerecorded calls, text messages and unsolicited faxes, was originally passed in 1991. Since that time, there have been many rulings and updates that impact businesses’ ability to maintain TCPA compliance.   Recent TCPA Changes   On December 30, 2020, the Federal Communications Commission (FCC) updated a number of TCPA exemptions, adding call limits and opt-out requirements, and codifying exemptions for calls to residential lines.   These changes, along with other industry changes, have added additional layers of complication to keeping compliant while still optimizing operations and the consumer experience.   Maintaining TCPA Compliance   Businesses who do not maintain TCPA compliance could be subject to a lawsuit and paying out damages, and potential hits to their reputation.   With the right partner in place, businesses can maintain data hygiene and accuracy to increase right-party contact (and reduce wrong-party contact) to keep collections streamlined and improve the customer experience.   Using the right technology in place, it’s easier to:   Monitor and verify consumer contact information for a better customer experience while remaining compliant. Receive and monitor daily notifications about changes in phone ownership information. Maintain compliance with Regulation F by leveraging a complete and accurate database of consumer information.   When searching for a partner, be sure to look for one who offers data scrubbing, phone type indicators, phone number scoring, phone number identity verification, ownership change monitoring, and who has direct access to phone carriers.   To learn more about how the right technology can help your business maintain TCPA compliance, visit us or request a call. 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.

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.  

Have you seen the latest Telephone Consumer Protection Act (TCPA) class action lawsuit? TCPA litigations in the communications, energy and media industries are dominating the headlines, with companies paying up to millions of dollars in damages. Consumer disputes have increased more than 500 percent in the past five years, and regulations continue to tighten. Now more than ever, it’s crucial to build effective and cost-efficient contact strategies. But how? First, know your facts. Second, let us help. What is the TCPA? As you’re aware, TCPA aims to safeguard consumer privacy by regulating telephone solicitations and the use of prerecorded messages, auto-dialed calls, text messages and unsolicited faxes. The rule has been amended and more tightly defined over time. Why is TCPA compliance important? Businesses found guilty of violating TCPA regulations face steep penalties – fines range from $500 to $1500 per individual infraction! Companies have been delivered hefty penalties upwards of hundreds of thousands, and in some cases, millions of dollars. Many have questions and are seeking to understand how they might adjust their policies and call practices. How can you protect yourself? To help avoid risk for compliance violations, it’s integral to assess call strategies and put best practices in place to increase right-party contact rates. Strategies to gain compliance and mitigate risk include: Focus on right and wrong-party contact to improve customer service: Monitoring and verifying consumer contact information can seem like a tedious task, but with the right combination of data, including skip tracing data from consumer credit data, alternative and other exclusive data sources, past-due consumers can be located faster. Scrub often for updated or verified information: Phone numbers can continuously change, and they’re only one piece of a consumer’s contact information. Verifying contact information for TCPA compliance with a partner you can trust can help make data quality routine. Determine when and how often you dial cell phones: Or, given new considerations proposed by the CFPB, consider looking at collections via your consumers’ preferred communication channel – online vs. over the phone. Provide consumers user-friendly mechanisms to opt-out of receiving communications At Experian, our TCPA solutions can help you monitor and verify consumer contact information, locate past-due consumers, improve your right-party contact rates and automate your collections process. Get started

2019 is here — with new technology, new regulations and new opportunities on the docket. What does that mean for the financial services space? Here are the five trends you should keep your eye on and how these affect your credit universe.   1. Credit access is at an all-time high With 121 million Americans categorized as credit-challenged (subprime scores and a thin or nonexistent credit file) and 45 million considered credit-invisible (no credit history), the credit access many consumers take for granted has appeared elusive to others. Until now. The recent launch of Experian BoostTM empowers consumers to improve their credit instantly using payment history from their utility and phone bills, giving them more control over their credit scores and making them more visible to lenders and financial institutions. This means more opportunities for more people. Coupled with alternative credit data, which includes alternative financial services data, rental payments, and full-file public records, lenders and financial institutions can see a whole new universe. In 2019, inclusion is key when it comes to universe expansion goals. Both alternative credit and consumer-permissioned data will continue to be an important part of the conversation.   2. Machine learning for the masses The financial services industry has long been notorious for being founded on arguably antiquated systems and steeped in compliance and regulations. But the industry’s recent speed of disruption, including drastic changes fueled by technology and innovation, may suggest a changing of the guard. Digital transformation is an industry hot topic, but defining what that is — and navigating legacy systems — can be challenging. Successfully integrating innovation is the convergence at the center of the Venn diagram of strategy, technology and operations. The key, according to Deloitte, is getting “a better handle on data to extract the greatest value from technology investments.” How do you get the most value? Risk managers need big data, machine learning and artificial intelligence strategies to deliver market insights and risk evaluation. Between the difficulty of leveraging data sets and significant investment in time and money, it’s impossible for many to justify. To combat this challenge, the availability and access to an analytical sandbox (which contains depersonalized consumer data and comparative industry intel) is crucial to better serve clients and act on opportunities in lenders’ credit universe and beyond. “Making information analysis easily accessible also creates distinct competitive advantages,” said Vijay Mehta, Chief Innovation Officer for Experian’s Consumer Information Services, in a recent article for BAI Banking Strategies. “Identifying shifts in markets, changes in regulations or unexpected demand allows for quick course corrections. Tightening the analytic life cycle permits organizations to reach new markets and quickly respond to competitor moves.” This year is about meaningful metrics for action, not just data visualization.   3. How to fit into the digital-first ecosystem With so many things available on demand, the need for instant gratification continues to skyrocket. It’s no secret that the financial services industry needs to compete for attention across consumers’ multiple screens and hours of screen time. What’s in the queue for 2019? Personalization, digitalization and monetization. Consumers’ top banking priorities include customized solutions, omnichannel experience improvement and enhancing the mobile channel (as in, can we “Amazonize” everything?). Financial services leaders’ priorities include some of the same things, such as enhancing the mobile channel and delivering options to customize consumer solutions (BAI Banking Strategies). From geolocation targeting to microinteractions in the user experience journey to leveraging new strategies and consumer data to send personalized credit offers, there’s no shortage of need for consumer hyper-relevance. 33 percent of consumers who abandon business relationships do so because personalization is lacking, according to Accenture data for The Financial Brand. This expectation spans all channels, emphasizing the need for a seamless experience across all devices.   4. Keeping fraudsters out Many IT professionals regard biometric authentication as the most secure authentication method currently available. We see this technology on our personal devices, and many companies have implemented it as well. Biometric hacking is among the predicted threats for 2019, according to Experian’s Data Breach Industry Forecast, released last month. “Sensors can be manipulated and spoofed or deteriorate with too much use. ... Expect hackers to take advantage of not only the flaws found in biometric authentication hardware and devices, but also the collection and storage of data,” according to the report.   5. Regulatory changes and continued trends  Under the Trump Administration, the regulatory front has been relatively quiet. But according to the Wall Street Journal, as Democrats gain control of the House of Representatives, lawmakers may be setting their sights on the financial services industry — specifically on legislation in response to the credit data breach in 2017. The Democratic Party leadership has indicated that the House Financial Services Committee will be focused on protecting consumers and investors, preserving sector stability, and encouraging responsible innovation in financial technology, according to Deloitte. In other news, the focus on improving accuracy in data reporting, transparency for consumers in credit scoring and other automated decisions can be expected to continue. Consumer compliance, and specifically the fair and responsible treatment of consumers, will remain a top priority.   For all your needs in 2019 and beyond, Experian has you covered. Learn more

There’s no question today’s consumers have high expectations. As financial services companies wrestle with the laws and consumer demands, here are a few points to consider: While digital delivery channels may be new, the underlying credit product remains the same. With digital delivery, adhere to credit regulations, but build in enhanced policies and technological protocols. Consult your legal, risk and compliance teams regularly. Embrace the multitude of delivery methods, including email, text, digital display and beyond. When using the latest technology, you need to work with the right partners. They can help you respect the data and consumer privacy laws, which is the foundation on which strategies should be built. Learn more

How will the FinCEN revisions impact your business? (Part 2) I recently discussed the new FinCEN requirements to Customer Due Diligence. This time, I’d like to focus on the recent FinCEN advisory regarding “email-compromise fraud.” This new advisory sheds additional light on the dual threats of both Email Account Compromise impacting the general public and Business Email Compromise that targets businesses. FinCEN has rightly identified and communicated several high-risk conditions common to the perpetration of scams such as varied languages, slight alterations in email addresses, out-of-norm account and transaction information, and social engineering in the form of follow-up requests for additional transfers. In addition to introducing operational standards to detect such conditions, institutions also would benefit from these other tactics and focal points as they respond to email requests for financial transfers: Email validation and verification — use of third-party vendor services that can deliver a measurable level of confidence in the association of an email address to an actual, true identity. Multifactor authentication — use of dual-step or out-of-band verification of the requested transaction using alternate channels such as phone. Robust KYC/CIP at application and account opening to ensure that name, address, date of birth and Social Security number are verified and positively and consistently linked to a single identity, as well as augmented with phone and email verification and association for use in customer communications and multifactor authentications. Customer transactional monitoring in the form of establishing typical or normal transfer activity and thresholds for outlying variations of concern. Known and suspected fraud databases updated in real time or near real time for establishing blacklist emails to be segmented as high risk or declines upon receipt. Identity application and transactional link analysis to monitor for and detect the use of shared and manipulated email addresses across multiple transaction requests for disparate identities. Access to device intelligence and risk assessment to ensure consistent association of a true customer with one or more trusted devices and to detect variance in those trusted associations. Which of these 7 tactics are you using to stop email-compromise fraud?

How will the FinCEN revisions impact your business? (Part 1) Some recently published FinCEN revisions and advisories are causing a stir. First, let’s look at revisions to Customer Due Diligence that require compliance by May 2018. Under the updated requirements for Customer Due Diligence, covered financial institutions must expand programs, including Customer Identification Programs (CIP), to include Beneficial Owners of Legal Entity customers. Under the new rule, financial institutions must collect and verify identity information (name, address, date of birth, Social Security number or passport number for foreign individuals):  For each Natural Person with at least 25% ownership in the Legal entity and  For an individual with significant responsibility for managing or controlling the business — for example, a chief executive officer, a chief financial officer, a chief operating officer, a managing member, a general partner, a president, a vice president or a treasurer The U.S. Treasury estimates that illicit proceeds generated in the United States alone total $400 billion annually. These requirements are intended to prevent anonymous access to financial systems through shielded or minority ownership. While the effort to stem the tide of illicit proceeds is laudable, the impact to business may be significant. Most organizations will need to audit their data collection practices, and many will need to make changes to either data collection or workflow processes to ensure compliance. While quite simple and straightforward on paper, the standardization of additional CIP policies and procedures tend to create substantive impact to the customer experience as well as operational resource allocations and utilization. Covered financial institutions should already be discussing with their current or prospective fraud risk and identity management vendors to ensure that: There is a clear path to altering both data collection and verification of these additional identity elements. Clear and accurate benchmarking around expected verification rates is available ahead of the compliance date to allow for operational workflow design to accommodate both ‘verifications’ and ‘referrals stemming from lack of full verification.’ Service providers are granting access to best-in-class data assets and search & match logic related to identity element verification and risk assessment, along with multi-layered options to reconcile those initial verification ‘fails.’ Full business reviews and strategy design sessions are underway or being scheduled to align and document overall objectives of the program, benchmarking of leading industry practices, current and future state gaps, near- and long-term initiatives and a prioritized roadmap, a viable business case toward additional investment in services and resources, and a plan of execution. Will this impact your business? Will you need to make any changes? Click here to read part two - FinCEN and email-compromise fraud.

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.