Tag: regulatory relief package

In 2015, U.S. card issuers raced to start issuing EMV (Europay, Mastercard, and Visa) payment cards to take advantage of the new fraud prevention technology. Counterfeit credit card fraud rose by nearly 40% from 2014 to 2016, (Aite Group, 2017) fueled by bad actors trying to maximize their return on compromised payment card data. Today, we anticipate a similar tsunami of fraud ahead of the Social Security Administration (SSA) rollout of electronic Consent Based Social Security Number Verification (eCBSV). Synthetic identities, defined as fictitious identities existing only on paper, have been a continual challenge for financial institutions. These identities slip past traditional account opening identity checks and can sit silently in portfolios performing exceptionally well, maximizing credit exposure over time. As synthetic identities mature, they may be used to farm new synthetics through authorized user additions, increasing the overall exposure and potential for financial gain. This cycle continues until the bad actor decides to cash out, often aggressively using entire credit lines and overdrawing deposit accounts, before disappearing without a trace. The ongoing challenges faced by financial institutions have been recognized and the SSA has created an electronic Consent Based Social Security Number Verification process to protect vulnerable populations. This process allows financial institutions to verify that the Social Security number (SSN) being used by an applicant or customer matches the name. This emerging capability to verify SSN issuance will drastically improve the ability to detect synthetic identities. In response, it is expected that bad actors who have spent months, if not years, creating and maturing synthetic identities will look to monetize these efforts in the upcoming months, before eCBSV is more widely adopted. Compounding the anticipated synthetic identity fraud spike resulting from eCBSV, financial institutions’ consumer-friendly responses to COVID-19 may prove to be a lucrative incentive for bad actors to cash out on their existing synthetic identities. A combination of expanded allowances for exceeding credit limits, more generous overdraft policies, loosened payment strategies, and relaxed collection efforts provide the opportunity for more financial gain. Deteriorating performance may be disguised by the anticipation of increased credit risk, allowing these accounts to remain undetected on their path to bust out. While responding to consumers’ requests for assistance and implementing new, consumer-friendly policies and practices to aid in impacts from COVID-19, financial institutions should not overlook opportunities to layer in fraud risk detection and mitigation efforts. Practicing synthetic identity detection and risk mitigation begins in account opening. But it doesn’t stop there. A strong synthetic identity protection plan continues throughout the account life cycle. Portfolio management efforts that include synthetic identity risk evaluation at key control points are critical for detecting accounts that are on the verge of going bad. Financial institutions can protect themselves by incorporating a balance of detection efforts with appropriate risk actions and authentication measures. Understanding their portfolio is a critical first step, allowing them to find patterns of identity evolution, usage, and connections to other consumers that can indicate potential risk of fraud. Once risk tiers are established within the portfolio, existing controls can help catch bad accounts and minimize the resulting losses. For example, including scores designed to determine the risk of synthetic identity, and bust out scores, can identify seemingly good customers who are beginning to display risky tendencies or attempting to farm new synthetic identities. While we continue to see financial institutions focus on customer experience, especially in times of uncertainty, it is paramount that these efforts are not undermined by bad actors looking to exploit assistance programs. Layering in contextual risk assessments throughout the lifecycle of financial accounts will allow organizations to continue to provide excellent service to good customers while reducing the increasing risk of synthetic identity fraud loss. Prevent SID

The COVID-19 pandemic has created unprecedented challenges for the utilities industry. This includes the need to plan for – and be prepared to respond to – changing behaviors and a sudden uptick in collections activities. As part of our recently launched Q&A perspective series, Mark Soffietti, Experian’s Senior Manager of Analytics Consulting and Tom Hanson, Senior Energy Consultant, provided insight on how utility providers can evolve and refine their collections and recovery processes. Check out what they had to say: Q: How has COVID-19 impacted payment behavior and debt collections? TH: Consumer payment behavior is changing. For example, those who paid as agreed, may not currently have the means to pay and are now distressed borrowers. Or those who were sloppy payers before the pandemic may now be defaulting on a more consistent basis. MS: As we saw with the last recession when faced with economic stress, consumer and commercial payment behavior changes based on their needs and current cash flow. For example, people prioritize their car, as they need it to get to and from work, so they’ll likely pay their auto bills on time. The same goes for their credit cards, which they need to make ends meet. We expect this will also be true with COVID-19. The commercial segment will face more dramatic and challenging circumstances, where complete or partial business closures and lack of federal relief could have severe ramifications. Q: What new restrictions have been put in place surrounding debt collection efforts and outbound calls? TH: To protect consumers who may be experiencing financial distress, most states have imposed new, stringent restrictions to prevent utilities from engaging in certain collections activities. Utilities are currently not charging any late payment fees and are instead structuring payment plans. Additionally, all outbound collections efforts have been suspended and there is fieldwork being executed of services for both commercial and consumer properties. As of now, consumer and commercial fieldwork will likely not commence until after the first year or when the winter moratorium concludes. MS: The new restrictions imposed upon collections activities will likely drive consumer payment behavior. If consumers know that their utilities (i.e. energy and water) will not be shut off if they miss a payment, they will make these bills less of a priority. This will dramatically increase the amount owed when these restrictions are lifted next year. Q: Can we predict how the utilities industry will fare post-COVID-19? TH: The volume of accounts in collections and eligible for disconnect will be overwhelming. Many utility providers fear the unpaid balances consumers and commercial entities accumulate will be nearly impossible to fit into a repayment schedule. Both analyzing internal payment segments and overlaying external factors may be the best way to optimize the most critical go-forward plan. MS: The amount of people who fall into collections is going to greatly increase and utility providers need to start planning for it now to weather the storm. They will need to use data, analytics and tools to help them optimize their tasks, so they can be more efficient with their resources. Like many other industries, the utilities sector will look to increasing digitalization of their processes and having less social interaction where possible. This could mean the need and drive for expediting current smart meter programs where possible to enable remote fieldwork to assist in managing this unprecedented level of activity that is sure to overwhelm field operations (where allowed by state regulators). Q: What should utility providers be doing to plan for an uptick in collections activities post-COVID-19? TH: With regulatory mandated suspensions of collections activities for utility providers and self-selected reductions due to stay at home orders and staff protection, the backlog of payments, calls and inquiries once business resumes as normal is set to overwhelm existing capacity. More than ever, self-service options (text/web), Q&A and alternative communication methods will be needed to shepherd consumers through the collections process and minimize the strain on call center agents. Many utility providers are asking for external data points to segment their consumers by industry or by those whose employment would have been adversely impacted by COVID-19. MS: Utility providers should be monitoring consumer data in order to prepare for when they are able to collect. This will help them strategize the number of resources they will need in their call centers and out in the field performing shut off activities. Given that the rise in cases will be more volume than their call centers can handle, they will need to use their resources wisely and plan to use them efficiently when they are able to resume collections. Q: How can Experian help utility providers reduce collections costs and maximize recovery? TH: Experian can help revise collections tactics and segmentation strategies by providing insight on how consumers are paying other creditors and identifying new segmentation opportunities as we emerge from the freeze on collections activities. Collections cases will be complex, and many factors and constraints will need to balanced against changing goals, making optimization key. MS: Utilizing Experian’s credit data and models can help ensure that resources are being used efficiently (i.e. making successful calls). There is also a need to leverage ability to pay models as well as prioritization models. By using these models and tools, utility providers can optimize their treatment strategies, reduce costs and maximize dollars collected. Learn more About our Experts: Tom Hanson, Senior Energy Consultant, Experian CEM, North America Tom is a Senior Consultant within the Energy Vertical at Experian, supporting regulated energy companies throughout the U.S. He brings over 25 years of experience in the energy field and supports his clients throughout the customer lifecycle, providing expertise in ID verification, account treatment, fraud solutions, analytics, consulting and final bill/field optimization strategies and techniques. Mark Soffietti, Analytics Consulting Senior Manager, Experian Decision Analytics, North America Mark has over 15 years of experience transforming data into actionable knowledge for effective decision management. Mark’s expertise includes solution development for consumer and commercial lending across the credit spectrum – from marketing to collections.

The U.S. Senate Banking Committee passed a financial regulatory relief bill (S. 2155) in December 2017 aimed at reducing regulatory burdens on community banks, credit unions and smaller regional banks.  Committee Chairman Senator Mike Crapo (R-ID), sponsored the bill, which has strong bipartisan support, with 23 cosponsors (11 Republicans and 12 Democrats and an independent). The package is likely to be considered by the full Senate in early 2018. The legislation includes two provisions related to consumer credit reporting.  Both were adopted, in part, in reaction to the Equifax data breach. As the bill moves through the legislative process during 2018, it will be important for all participants in the consumer credit ecosystem to be aware of the potential changes in law. One provision deals with fraud alerts and credit freezes for consumers and the other deals with how medical debt is processed for veterans who seek medical treatment outside the VA system. Credit Freezes The bill amends the Fair Credit Reporting Act to provide consumers with the ability to freeze/unfreeze credit files maintained by nationwide credit reporting agencies at no cost, and would extend the time period for initial fraud alerts from 90 days to one year. The credit freeze provisions would also establish a process for parents and guardians to place a freeze on the file of a minor at no cost. The bill would require the nationwide credit reporting agencies to create webpages with information on credit freezes, fraud alerts, active duty alerts and pre-screen opt-outs and these pages would be linked to the FTC’s existing website, www.IdentityTheft.gov.  The credit freeze and minor freeze provisions would preempt State laws and create a national standard. Protections for Veterans The bill also incorporates a provision that would prohibit credit bureaus from including debt for health-care related services that the veteran received through the Department of Veterans Affairs’ Choice Program. The provision would cover debt that the veteran incurred in the previous year, as well as any delinquent debt that was fully paid or settled. The legislation would require a consumer reporting agency to delete medical debt if it receives information from either the veteran or the VA that the debt was incurred through the Veteran’s Choice Program. What’s next The bill now awaits consideration before the full Senate. Senate Majority Leader Mitch McConnell has said that the bill is a “candidate for early consideration” in 2018, but the exact timing of floor debate has yet to be scheduled. Once the package passes the Senate, it will need to be reconciled with the regulatory relief package that was passed by the House last spring.