-- by Dan Buell

Towards the end of 2007, the management of Bay Area Credit Service embarked on an agressive strategy to dramatically enhance the company's market position and increase its collection revenues.  These goals could be achieved only through superior performance at competitive rates.  At the same time, though, the company needed to drastically reduce internal operating expenses while facing significant competition.  The company's major goals for 208 included:

*  Earn a much larger share of business from one of the nation's top five cellular phone service providers;

*  Become a major collections partner for one of the nation's largest banking institutions;

*  Earn more than 50 percent of the market in the pre-charge-off, early-out segment for the nation's largest landline communications provider;

*  Enhance the company's position in the secondary collections tier.

It's an interesting case study.  Navigate to the link to learn more: 

http://www.experian.com/whitepapers/index.html


--by Matt Ehrlich

On Friday, October 30th, the FTC again delayed enforcement of the “Red Flags” Rule – this time until June 1, 2010 – for financial institutions and creditors subject to the FTC’s enforcement.   Here’s the official release: http://www.ftc.gov/opa/2009/10/redflags.shtm

But this doesn’t mean, until then, businesses get a free pass.  The extension doesn’t apply to other federal agencies that have enforcement responsibilities for institutions under their jurisdiction.  And the extension also doesn’t alleviate an institution’s need to detect and respond to address discrepancies on credit reports.

Red Flag compliance

Implementing best practices to address the identity theft under the Red Flags Rule is not just the law, it’s good business. 
The damage to reputations and consumer confidence from a problem gone unchecked or worse yet – unidentified – can be catastrophic.  I encourage all businesses – if they haven’t already done so – to use this extension as an opportunity to proactively secure a Red Flags Rule to ensure Red Flag compliance.  It’s an investment in protecting their most important asset – the customer.



 


--by Kari Michel

Most lenders use a credit scoring model in their decision process for opening new accounts; however, between 35 and 50 million adults in the US may be considered unscoreable with traditional credit scoring models. That is equivalent to 18-to-25 percent of the adult population. 

Due to recent market conditions and shrinking qualified candidates lenders have placed a renewed interest in assessing the risk of this under served population.  Unscoreable consumers could be a pocket of missed opportunity for many lenders. To assess these consumers, lenders must have the ability to better distinguish between consumers with a clear track record of unfavorable credit behaviors versus those that are just beginning to develop their credit history and credit risk models.

Unscoreable consumers can be split out into three populations:

• Infrequent credit users:  Consumers who have not been active on their accounts for the past six months, and who prefer to use non-traditional credit tools for their financial needs.

• New entrants:  Consumers who do not have at least one account with more than six months of activity; including young adults just entering the workforce,  recently divorced or widowed individuals with little or no credit history in their name, newly arrived immigrants, or people who avoid the traditional system by choice.

• Thin file consumers:  Consumers who have less than three accounts and rarely utilize traditional credit and likely prefer using alternative credit tools and credit score trends.

A study done by VantageScore® Solutions, LLC shows that a large percentage of the
unscoreable population can be scored with VantageScore* and a portion of these are credit-worthy (defined as the population of consumers who have a cumulative likelihood to become 90 days or more delinquent is less than 5 percent).  The following is a high-level summary of the findings for consumers who had at least one trade:

Lenders can review their credit decisioning process to determine if they have the tools in place to assess the risk of those unscoreable consumers.  As with this population there is an opportunity for portfolio expansion as demonstrated by the VantageScore study.

*VantageScore is a generic credit scoring model introduced to meet the market demands for a highly predictive consumer score. Developed as a joint venture among the three major credit reporting companies (CRCs) – Equifax, Experian and TransUnion.


 



-- By Kelly Kent

Source: Experian-Oliver Wyman Market Intelligence Reports

Analyzing recent trends from vintages published in the Experian-Oliver Wyman Market Intelligence Reports, there are numerous insights that can be gleaned from just a cursory review of the results.

Mortgage Trends

As noted in an earlier posting, recent mortgage vintages show a broad range of behaviors between more recent vintages and older, more established vintages that were originated before the significant run-up of housing prices seen in the middle of the decade. As below, the 30+ delinquency levels for mortgage vintages in 2005, 2006, and 2007 approach and in two cases exceed 10% of trades in the last 12 months of performance, and have spiked from historical trends, beginning almost immediately after origination. On the other end of the spectrum, the vintages from 2003 and 2002 have barely approached or exceeded 5% for the last 6 or 7 years.

Bankcard Trends

As one would expect, the 30+ delinquency trends demonstrated within bankcard vintages are vastly different from the trends of mortgage vintages. Firstly, card delinquencies show a clear seasonal trend, with a more consistent yearly pattern evident in all vintages, resulting from the revolving structure of the product. The most interesting trends within the card vintages do show that the more recent vintages, 2005 to 2008, display higher 30+ delinquency levels, especially the Q2 2007 vintage, which is far and away the underperformer of the group.Within Within each vintage pool, an analysis can extend into the risk distribution and details of the portfolio and further segment the pool by credit score, specifically VantageScore. In the chart below, an alarming trend is evident. This chart provides the 30+ delinquency levels for the subset of VantageScore A and VantageScore B consumers at the time of origination. In other words, the loans in this pool are only for the most creditworthy customers at the time of origination. The noticeable trend is that while these consumers were largely resistant to deteriorating economic conditions, each vintage segment has seen a spike in the most recent 9-12 months. Given that these consumers tend to have the highest limits and lowest utilization of any Vantage Score band, this trend encourages further account management consideration and raises flags about overall bankcard performance in coming months.

As shown, even a basic review of vintage pools and the subsequent analysis opportunities that result from this data can be extremely useful. This analysis can add a new perspective to risk management, supplementing more established analysis techniques, and further enhancing the ability to see the risk within the risk.


--by Keir Breitenfeld

Well, here we are at the beginning of November and The Red Flags Rule has been with us for nearly two years now.  And to add to that, the FTC’s November 1, 2009 enforcement date has passed (I know I’ve said that before).  There is little value in me chatting about the core requirements of the Red Flags Rule at this point.  Instead, I’d like to shed some light on what we are seeing and hearing these days from our clients and industry experts related to this initiative:

Red Flags Rule client comments

1. Most clients have a solid written and operational Identity Theft Prevention Program that arguably meets their interpretation of the Red Flags Rule requirements.

2. Most clients have a solid written and operational Identity Theft Prevention Program in place that creates a boat-load of referrals due to the address mismatches generated in their process(es) and the requirement to do something with them.

3. Most clients are now focusing on ways in which to reduce the number of referrals generated and procedures to clear the remaining referrals via a cost-effective and automated manner…of course, while preventing fraud and staying compliant..

In 2008, a key focus at Experian was to help educate the market around the Red Flags Rule concepts and requirements.

The concentration in 2009 of Red Flags Rule concepts has nearly fully shifted to assisting the market in creating risk-based authentication programs that leverage holistic views of a consumer, flexible tools that are pointed to a consumer based on that person’s authentication and risk profile. There is also an overall decisioning strategy that balances risk, compliance, and resource constraints.

Spirit of Red Flags Rule
The spirit of the Red Flags Rule is intended to ensure all covered institutions are employing basic identity theft prevention procedures (a pretty good idea).  I believe most of these institutions (even those that had very robust programs in place years before the rule was introduced) can appreciate this requirement that brings all institutions up to speed.  It is now, however, a matter of managing process within the realities of, and costs associated with, manpower, IT resources, and customer experience sensitivities.


 


--by Wendy Greenawalt

This blog kicks off a three part series exploring some common myths regarding credit attributes. Since Experian has relationships with thousands of organizations spanning multiple industries, we often get asked the same types of questions from clients of all sizes and industries. One of the questions we hear frequently from our clients is that they already have credit attributes in place, so there is little to no benefit in implementing a new attribute set.

Our response is that while existing credit attributes may continue to be predictive, changes to the type of data available from the credit bureaus can provide benefits when evaluating consumer behavior. To illustrate this point, let’s discuss a common problem that most lenders are facing today-- collections. Delinquency and charge-off continue to increase and many organizations are having difficulty trying to determine the appropriate action to take on an account because consumer behavior has drastically changed regarding credit attributes.

New codes and fields are now reported to the credit bureaus and can be effectively used to improve collection-related activities. Specifically, attributes can now be created to help identify consumers who are rebounding from previous account delinquencies. In addition, lenders can evaluate the number and outstanding balances of collection or other types of trades.  This can be achieved while considering the percentage of accounts that are delinquent and the specific type of accounts affected after assessing credit risk. The utilization of this type of data helps an organization to make collection decisions based on very granular account data.  This is done while considering new consumer trends such as strategic defaulters. Understanding all of the consumer variables will enable an organization to decide if the account should be allowed to self-cure.  If so, immediate action should be taken or modification of account terms should be contemplated. Incorporating new data sources and updating attributes on a regular basis allows lenders to react to market trends quickly by proactively managing strategies. 

 


--by Matt Ehrlich

In my last entry, I talked about the challenges clients face in trying to meet multiple and complex regulatory requirements, such as FACT Act’s Red Flags Rule and the USA Patriot Act.  While these regulations serve both different and shared purposes, there are some common threads between the two:

1. You must consider the type of accounts and methods of account opening: The type of account offered - credit or deposit, consumer or business – as well as the method of opening – phone, online, or face-to-face – has a bearing on the steps you need to take and the process that will be established.

2. Use of consumer name, address, and identification number:The USA Patriot Act requires each of these – plus date of birth – to open a new account.  Red Flags stops short of “requiring” these for new account openings, but it consistently illustrates the use of these Personally Identifiable Information (PII) elements as examples of reasonable procedures to detect red flags.

3. Establishing identity through non-documentary verification:Third party information providers, such as a credit reporting agency or data broker, can be used to confirm identity, particularly in the case where the verification is not done in person.

Knowing what’s in common means you can take a look at where to leverage processes or tools to gain operational and cost efficiencies and reduce negative impact on the customer experience.  For example, if you’re using any authentication products today to comply with the USA Patriot Act and/or minimize fraud losses, the information you collect from consumers and authentication steps you are already taking now may suffice for a large portion of your Red Flags Identity Theft Prevention Program. 

And if you’re considering fraud and compliance products for account opening or account management – it’s clear that you’ll want something flexible that, not only provides identity verification, but scales to the compliance programs you put in place, and those that may be on the horizon.



 


--by Mike Sutton

I recently interviewed a number of Experian clients to determine how they believe their organizations and industry peers will prioritize collections process improvement over the next 24 months. Additional contributions were collected by written surveys. Here are several interesting observations:

Improve Collections survey results:

Financial services professionals, in general, ranked “loss mitigation / risk management improvement” as the most critical area of focus.

Credit unions were the financial services group’s exception and placed” customer relationship management / attrition control” at the top of their priority list.

Healthcare providers ranked both “general delinquency management” and “improving cash flow / receivables” as their primary area of focus for the foreseeable future.

Almost all of the first-party contributors, across all industries polled, ranked “operational expense management / cost reductions” as being very important or at least a high priority. This category was also rated the most critical by utilities.

“External partner management (agencies, repo vendors and debt buyers)” also ranked high, but did not stand out on its own, as a top priority for any particular group.

All of the categories mentioned above were considered important by every respondent, but the most urgent priorities were not consistent across industries.

 



 



--by Matt Ehrlich

While the FACT Act’s Red Flags Rule seems to capture all of the headlines these days, it’s just one of a number of compliance challenges that banks, credit unions, and a myriad of other institutions face on a daily basis.  And meeting today’s regulatory requirements is more complicated than ever.  Risk managers and compliance officers are asked to consider many questions, including:

1. Do FACTA Sections 114 and 315 apply to me?
2. What do I have to do to comply?
3. What impact does this have on the customer’s experience?
4. What is this going to cost me in terms of people and process?

Interpretation of the law or guideline – including who it applies to and to whom it does not - varies widely.  Which types of businesses are subject to the Red Flags Rule?  What is a “covered account?”  If you’re not sure, you’re not alone - it’s a primary reason why the Federal Trade Commission (FTC) continues to postpone enforcement of the rule, while this healthy debate continues.

And by the way, FTC – it’s almost November 1st…aren’t we about due for another delay? But we’re not talking about just protecting consumers from identity theft and reducing fraud and protecting themselves using the Identity Theft Prevention Program.

The USA Patriot Act and “Know Your Customer” requirements have been around much longer, but there are current challenges of interpretation and practical application when it comes to identifying customers and performing due diligence to deter fraud and money laundering.  Since Customer Identification Programs require procedures based on the bank’s own “assessment of the relevant risks,” including types of accounts opened, methods of opening, and even the bank’s “size, location, and customer base,” it’s safe to say that each program will differ slightly – or even greatly.

So it’s clear there’s a lack of specificity in the regulations of the Red Flags Rule which cause heartburn for those tasked with compliance…but are there some common themes and requirements across the two?  The short answer is Yes.  In my next post, I’ll talk about the elements in common and how authentication products can play a part in addressing both.


 


-- by Keir Breitenfeld

In my previous three postings, I’ve covered basic principles that can define a risk-based authentication process, associated value propositions, and some best-practices to consider.

Finally, I’d like to briefly discuss some emerging informational elements and processes that enhance (or have already enhanced) the notion of risk-based authentication in the coming year.  For simplicity, I’m boiling these down to three categories:

1. Enterprise Risk Management – As you’d imagine, this concept involves the creation of a real-time, cross channel, enterprise-wide (cross business unit) view of a consumer and/or transaction.  That sounds pretty good, right?  Well, the challenge has been, and still remains, the cost of developing and implementing a data sharing and aggregation process that can accomplish this task.  There is little doubt that operating in a more silo’d environment limits the amount of available high-risk and/or positive authentication data associated with a consumer…and therefore limits the predictive value of tools that utilize such data.  It is only a matter of time before we see more widespread implementation of systems designed to look at a single transaction, an initial application profile, previous authentication results, or other relationships a consumer may have within the same organization -- and across all of this information in tandem.  It’s simply a matter of the business case to do so, and the resources to carry it out.

2. Additional Intelligence – Beyond some of the data mentioned above, some additional informational elements emerging as useful in isolation (or, even better, as a factor among others in a holistic assessment of a consumer’s identity and risk profile) include these areas:  IP address vs. physical address comparisons; device ID or fingerprinting; and biometrics (such as voice verification).  While these tools are being used and tested in many organizations and markets, there is still work to be done to strike the right balance as they are incorporated into an overall risk-based authentication process.  False positives, cost and implementation challenges still hinder widespread use of these tools from being a reality.  That should change over time, and quickly to help with the cost of credit risk.

3. Emerging Verification Techniques – Out-of-band authentication is defined as the use of two separate channels, used simultaneously, to authenticate a customer.  For example: using a phone to verify the identity of that person while performing a Web transaction.  Similarly, many institutions are finding success in initiating SMS texts as a means of customer notification and/or verification of monetary or non-monetary transactions.  The ability to reach out to a consumer in a channel alternate to their transaction channel is a customer friendly and cost effective way to perform additional due diligence.



 


-- by Keir Breitenfeld
 
In my last blog posting, I presented the foundational elements that enable risk-based authentication.  These include data, detailed and granular results, analytics and decisioning.  The inherent value of risk-based authentication can be summarized as delivering an holistic assessment of a consumer and/or transaction with the end goal of applying the right authentication and decisioning treatment at the right time.  The opportunity, especially, to minimize fraud losses using fraud analytics as part of your assessment is significant.

What are some residual values of risk-based authentication? 

1. Minimized fraud losses involves the use of fraud analytics, and a more comprehensive view of a consumer identity (the good and the bad), in combination with consistent decisioning over time.  This analysis will outperform simple binary rules and more subjective decisioning.

2. Improved consumer experience.  By applying the right authentication and  treatment at the right time, consumers are subjected to processes that are proportional to the risk associated with their identity profile.  This means that lower-risk consumers are less likely to be put through more arduous courses of action, preserving a streamlined and often purely “behind the scenes” authentication process for the majority of consumers and potential consumers.  In other words, you are saving the pain for the bad guys -- and that can be a good thing.

3. Operational efficiencies can be successful with the implementation of a well-designed program. Much of the decisioning can be done without human intervention and subjective contemplation.  Use of score-driven policies affords businesses the opportunity to use automated authentication processes for the majority of their applicants or account management cases.  Fewer human resources will be required which usually means lower costs.  Or, it can mean the human resources you possess are more appropriately focused on the applications or transactions that warrant such attention.

4. Measurable performance is critical because understanding the past and current performance of risk-based authentication policies allows for the adjustment over time of such policies.  These adjustments can be made based on evolving fraud risks, resource constraints, approval rate pressures, and compliance requirements, just to name a few.  Given its importance, Experian recommends performance monitoring for our clients using our authentication products. 

In my next posting, I’ll discuss some best practices associated with implementing and managing a risk-based authentication program.

 


 


Red Flags Rule and commercial accounts

-- by Kristan Keelan

Most financial institutions are well underway in complying with the FTC’s ID Theft Red Flags Rule by:

1.  Identifying covered accounts  
2.  Determining what red flags need to be monitored
3.  Implementing a risk based approach 

However, one of the areas that seems to be overlooked in complying with the rule is the area of commercial accounts.  Did your institution include commercial accounts when identifying covered accounts?  You’re not alone if you focused only on consumer accounts initially.

Keep in mind that commercial credit and deposit accounts also can be included as covered accounts when there is a “reasonably foreseeable risk” of identity theft to customers or to safety and soundness.

Start by determining if there is a reasonably foreseeable risk of identity theft in a business or commercial account, especially in small business accounts.   Consider the risk of identity theft presented by the methods used to open business accounts, the methods provided to access business accounts, and previous experiences with identity theft on a business account.

I encourage you to revisit your institution’s compliance program and review whether commercial accounts have been examined closely enough.



 


-- by Kristan Keelan

What do you think of when you hear the word “fraud”?  Someone stealing your personal identity?  Perhaps the recent news story of the five individuals indicted for gaining more than $4 million from 95,000 stolen credit card numbers?  It’s unlikely that small business fraud was at the top of your mind.   Yet, just like consumers, businesses face a broad- range of first- and third-party fraud behaviors, varying significantly in frequency, severity and complexity. Business-related fraud trends call for new fraud best practices to minimize fraud.

First let’s look at first-party fraud.  A first-party, or victimless, fraud profile is characterized by having some form of material misrepresentation (for example, misstating revenue figures on the application) by the business owner without  that owner’s intent or immediate capacity to pay the loan item.  Historically, during periods of economic downturn or misfortune, this type of fraud is more common.  This intuitively makes sense — individuals under extreme financial pressure are more likely to resort to desperate measures, such as misstating financial information on an application to obtain credit.  

Third-party commercial fraud occurs when a third party steals the identification details of a known business or business owner in order to open credit in the business victim’s name.  With creditors becoming more stringent with credit-granting policies on new accounts, we’re seeing seasoned fraudsters shift their focus on taking over existing business or business owner identities.

Overall, fraudsters seem to be migrating from consumer to commercial fraud.   I think one of the most common reasons for this is that commercial fraud doesn’t receive the same amount of attention as consumer fraud.  Thus, it’s become easier for fraudsters to slip under the radar by perpetrating their crimes through the commercial channel.   Also, keep in mind that businesses are often not seen as victims in the same way that consumers are.  For example, victimized businesses aren’t afforded the protections that consumers receive under identity theft laws, such as access to credit information.   These factors, coupled with the fact that business-to-business fraud is approximately three-to-ten times more “profitable” per occurrence than consumer fraud, play a role in leading fraudsters increasingly toward commercial fraud.
 


-- by Kelly Kent

In a recent article, www.CNNMoney.com reported that Federal Reserve Chairman, Ben Bernanke, said that the pace of recovery in 2010 would be moderate and added that the unemployment rate would come down quite slowly, due to headwinds on ongoing credit problems and the effort by families to reduce household debt.’

While some media outlets promote an optimistic economic viewpoint, clearly there are signs that significant challenges lie ahead for lenders. As Bernanke forecasts, many issues that have plagued credit markets will sustain themselves in the coming years. Therefore lenders need to be equipped to monitor these continued credit problems if they wish to survive this protracted time of distress.

While banks and financial institutions are implementing increasingly sophisticated and thorough processes to monitor fluctuations in credit trends, they have little intelligence to compare their credit performance to that of their peers.  Lenders frequently cite that they are concerned about their lack of awareness or intelligence regarding the credit performance and status of their peers.  Marketing intelligence solutions are important for management of risk, loan portfolio monitoring and related decisioning strategies.

Currently, many vendors offer data on industry-wide trends, but few vendors provide the information needed to allow a lender to understand its position relative to a well-defined group of firms that it considers its peers. As a result, too many lenders are performing benchmarking using data sources that are biased, incomplete, inaccurate, or that lack the detail necessary to derive meaningful conclusions.

If you were going to measure yourself personally against a group to understand your comparative performance, why would you perform that comparison against people who had little or nothing in common with you? Does an elite runner measure himself against a weekend warrior to gauge his performance? No; he segments the runners by gender, age, and performance class to understand exactly how he stacks up.

Today’s lending environment is not forgiving enough for lenders to make broad industry comparisons if they want to ensure long-term success. Lenders cannot presume they are leading the pack, when, in fact, the race is closer than ever.

 


-- by Keir Breitenfeld

The term “risk-based authentication” means many things to many institutions.  Some use the term to review to their processes; others, to their various service providers.  I’d like to establish the working definition of risk-based authentication for this discussion calling it:  “Holistic assessment of a consumer and transaction with the end goal of applying the right authentication and decisioning treatment at the right time.” 

Now, that “holistic assessment” thing is certainly where the rubber meets the road, right? 

One can arguably approach risk-based authentication from two directions.  First, a risk assessment can be based upon the type of products or services potentially being accessed and/or utilized (example: line of credit) by a customer.  Second, a risk assessment can be based upon the authentication profile of the customer (example: ability to verify identifying information).  I would argue that both approaches have merit, and that a best practice is to merge both into a process that looks at each customer and transaction as unique and therefore worthy of  distinctively defined treatment.

In this posting, and in speaking as a provider of consumer and commercial authentication products and services, I want to first define four key elements of a well-balanced risk based authentication tool: data, detailed and granular results, analytics, and decisioning.

1.  Data: Broad-reaching and accurately reported data assets that span multiple sources providing far reaching and comprehensive opportunities to positively verify consumer identities and identity elements.

2.  Detailed and granular results: Authentication summary and detailed-level outcomes that portray the amount of verification achieved across identity elements (such as name, address, Social Security number, date of birth, and phone) deliver a breadth of information and allow positive reconciliation of high-risk fraud and/or compliance conditions.  Specific results can be used in manual or automated decisioning policies as well as scoring models,

3.  Analytics:  Scoring models designed to consistently reflect overall confidence in consumer authentication as well as fraud-risk associated with identity theft, synthetic identities, and first party fraud.  This allows institutions to establish consistent and objective score-driven policies to authenticate consumers and reconcile high-risk conditions.  Use of scores also reduces false positive ratios associated with single or grouped binary rules.  Additionally, scores provide internal and external examiners with a measurable tool for incorporation into both written and operational fraud and compliance programs,

4.  Decisioning: Flexibly defined data and operationally-driven decisioning strategies that can be applied to the gathering, authentication, and level of acceptance or denial of consumer identity information.  This affords institutions an opportunity to employ consistent policies for detecting high-risk conditions, reconcile those terms that can be changed, and ultimately determine the response to consumer authentication results – whether it be acceptance, denial of business or somewhere in between (e.g., further authentication treatments).

In my next posting, I’ll talk more specifically about the value propositions of risk-based authentication, and identify some best practices to keep in mind.

 

 


 


-- by Kari Michel

In August, consumer bankruptcy filings were up by 24 percent over the past year and are expected to increase to 1.4 million this year.  “Consumers continue to turn to bankruptcy as a shield from the sustained financial pressures of today’s economy,” said American Bankruptcy Institute’s Executive Director Samuel J. Gerdano.

What are lenders doing to protect themselves from bankruptcy losses? In my last blog, I talked about the differences and advantage of using both risk and bankruptcy scores. Many lenders are mitigating and managing bankruptcy losses by including bankruptcy scores into their standard account management programs. 

Here are some ways lenders are using bankruptcy scores:

• Incorporating them into existing internal segmentation schemes for enhanced separation and treatment assessment of high risk accounts;

• Developing improved strategies to act on high-bankruptcy-risk accounts
       • In order to manage at-risk consumers proactively and
       • Assessing low-risk customers for up-sell opportunities.

Implementation of a bankruptcy score is recommended given the economic conditions and expected rise in consumer bankruptcy. When conducting model validations/assessments, we recommend that you use the model that best rank orders bankruptcy or pushes more bankruptcies into the lowest scoring ranges.  In validating our Experian/Visa BankruptcyPredict score, results showed BankruptcyPredict was able to identify 18 to 30 percent more bankruptcy compared to other bankruptcy models.  It also identified 12 to 33 percent more bankruptcy compared to risk scores in the lowest five percent of the score range.  This supports the need to have distinct bankruptcy scores in addition to risk scores.


 


-- by Kennis Wong

As I said in my last post, when consumers and the media talk about fraud and fraud risk, they are usually referring to third-party frauds. When financial institutions or other organizations talk about fraud and fraud best practices, they usually refer to both first- and third-party frauds.

The lesser-known fraud cousin, first-party fraud, does not involve stolen identities. As a result, first-party fraud is sometimes called victimless fraud. However, being victimless can’t be further from the truth. The true victims of these frauds are the financial institutions that lose millions of dollars to people who intentionally defraud the system.

First-party frauds happen when someone uses his/her own identity or a fictitious identity to apply for credit without the intention to fulfill their payment obligation. As you can imagine, fraud detection of this type is very difficult. Since fraudsters are mostly who they say they are, you can’t check the inconsistencies of identities in their applications. The third-party fraud models and authentication tools will have no effect on first-party frauds.

Moreover, the line between first-party fraud and regular credit risk is very fuzzy. According to Wikipedia, credit risk is the risk of loss due to a debtor's non-payment of a loan or other line of credit. Doesn’t the definition sound similar to first-party fraud? In practice, the distinction is even blurrier. That’s why many financial institutions are putting first-party frauds in the risk bucket.

But there is one subtle difference: that is the intent of the debtor.  Are the applicants planning not to pay when they apply or use the credit?  If not, that’s first-party fraud. To effectively detect frauds of this type, fraud models need to look into the intention of the applicants.
 


-- By Kelly Kent

Source: Experian-Oliver Wyman Market Intelligence Reports

In the most recent release of the Experian-Oliver Wyman Market Intelligence Reports, each product report contains a series of vintage data reports that shed light on the delinquency, charge-off, and prepayment trends discussed earlier in this series.

These examples of vintage pool curves are taken from the Q2 2009 release and pertain to the mortgage product.

Vintage performance - delinquency
The performance metrics of each vintage are the essence of the benchmarking process. Having properly weighed and balanced each vintage pool, a comparison can be made to the performances of each pool. In the chart shown here, “30+ delinquency rates as % of
trades,” each vintage pool is tracked based on the months on book since its origination. For instance, the longest trend line belongs to the oldest vintage, Q2 2002, and reflects the 30+ delinquency rates over the past 84 months. Conversely, the newest vintage, Q2 2008, is the shortest trend line and reflects only the performance for the past 12 months for those trades. In this chart, it can be easily observed that the delinquency levels for the vintages from 2005, 2006, and 2007 deviate significantly from the older vintages and have spiked for the past 12 to 18 months while older vintages have behaved more consistently.

Distribution of trades
As mentioned earlier, vintage pools are defined by the score at origination for each of the loans within the pool. This is significant in that the distribution of loans will impact the ability to correctly benchmark against each pool. For instance, the chart shown here displays the distributions in each vintage pool, by VantageScore band. 

Despite the clear advantages of using vintage analysis, a benchmarking exercise will require significant weighing and balancing to ensure that the risk profiles of the portfolios are comparable.

Vintage performance - prepayment
Less prominent to delinquency trends are the prepayment trends of each pool. From the moment of origination, each pool begins to change its composition as a result of prepayments/closures which need to be considered in any analysis in order to understand the changing composition of each pool. It is vital that a user understand the shifting risk profile of each vintage, over time. The risk profile, by VantageScore for instance, may skew away from the higher quality consumers over time as prepayment removes them from the pool, leaving only the lowest-scoring consumers in the pool.

These are just three examples of the data required in order to perform vintage analysis. For the sake of brevity, other aspects of these analyses, such as geographic footprint, have been excluded.  These would also add significant insight to the analysis results.


 



-- By Kelly Kent

Vintage analysis, specifically vintage pools, present numerous useful opportunities for any firm seeking to further understand the risks within specific portfolios. While most lenders have relatively strong reporting and metrics at hand  for their own loan portfolio monitoring...these to understand the specific performance characteristics of their own portfolios -- the ability to observe trends and benchmark against similar industry characteristics can enhance their insights significantly.

Assuming that a lender possesses the vintage data and vintage analysis capability necessary to perform benchmarking on its portfolio, the next step is defining the specific metrics upon which any comparisons will be made. As mentioned in a previous posting, three aspects of vintage performance are often used to define these points of comparison:

1. Vintage delinquency including charge-off curves, which allows for an understanding of the repayment trends within each pool. Specifically, standard delinquency measures (such as 30+ Days Past Due (DPD), 60+ DPD, 90+ DPD, and charge-off rates) provide measures of early and late stage delinquencies in each pool.

2. Payoff trends, which reflect the pace at which pools are being repaid. While planning for losses through delinquency benchmarking is a critical aspect of this process, so, too, is the ability to understand pre-repayment tendencies and trends. Pre-payment can significantly impact cash-flow modeling and can add insight to interest income estimates and loan duration calculations.

As part of the Experian-Oliver Wyman Market Intelligence Reports, these metrics are delivered each quarter, and provide a consistent, static pool base upon which vintage benchmarks can be conducted.

Clearly, this is a rather simplified perspective on what can be a very detailed analysis exercise. A properly conducted vintage analysis needs to consider aspects such as: lender portfolio mix at origination; lender portfolio footprint at origination; lender payoff trends and differences from benchmarked industry data in order to properly balance the benchmarked data against the lender portfolio.
 



-- By Wendy Greenawalt

The combined impact of rising unemployment, increasing consumer debt burdens and decreasing home values have caused lenders to shift resources away from prospecting and acquisitions to collection and recovery activities. As delinquencies and charge-off rates continue to increase, the likelihood of collecting on delinquent accounts decreases -- because outstanding debts mount for consumers and their ability to pay declines. Integrating optimized decisions into a collection strategy enables a lenders to assign appropriate collection treatments by assessing the level of risk associated with a consumer while considering a customer’s responsiveness to particular treatment options.  

Specifically, collections optimization uses mathematical algorithms to maximize organizational goals while applying constraints such as budget and call center capacity  -- providing explicit treatment strategies at the consumer level -- while producing the highest probability of collecting outstanding dollars. Optimization can be integrated into a real-time call center environment by targeting the right consumers for outbound calls and assigning resources to consumers most likely to pay.  It can also be integrated into traditional lettering campaigns to determine the number and frequency of letters, and the tone of each correspondence. The options for account treatment are virtually limitless and, unlike other techniques, optimization will determine the most profitable strategy while meeting operational and business constraints without simplification of the problem.

By incorporating optimization into a collection strategy that includes a predictive model or score and advanced segmentation, an organization can maximize collected dollars, minimize the costs of collection efforts, improve collections efficiency, and determine which accounts to sell off – all while maximizing organizational profits.


 

 

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