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Michael Sisk is a New York-based journalist who has covered business and the financial markets for 15 years, including stints as the investor editor at Red Herring, editor-at-large at American Banker, and contributing editor at Bank Technology News. His articles have appeared in numerous publications, including American Banker, Barron's, Crain's New York Business, Inc., Institutional investor, Strategy + Business and Worth. Michael has co-written and edited three books; the most recent was Merge Ahead: Mastering the Five Enduring Trends of Artful M&A (McGraw-Hill 2009).
Tony Hadley, Senior Vice President of Public Policy, ExperianTony Hadley is Senior Vice President of Public Policy for Experian, where he has led the regulatory agenda relating to consumer reporting, financial markets, direct marketing and advertising, e-commerce, and privacy for 15 years. He advises the Experian Global Risk Management Council on such activities in the Americas, EMEA and Asia Pacific. Tony represents Experian before a number of trade groups and alliances. These include the Direct Marketing Association's (DMA), the Consumer Data Industry Association, the Internet Advertising Bureau, the Internet Alliance, the U.S. Chamber of Commerce, the American Financial Services Association, the Consumer Bankers Association, and the U.S. Chamber of Commerce. Tony is Chairman of the National Business Coalition on E-commerce and Privacy.
Carmen Hearn, Senior Director Consumer Information Services, ExperianCarmen Hearn leads the product marketing team within Consumer Information Services that has responsibility for acquisitions, Experian Data Integrity ServicesSM and the Experian Credit EducatorSM product. Carmen joined Experian in January 2014. She has held several leadership roles within the financial services industry, including Capital One, HSBC / Household and Providian. Carmen has more than 25 years senior level experience overseeing the use and reporting of consumer / credit data, as well as consumer / business data needs pertaining to risk management. She also has provided thought leadership and played key roles related to compliance and audit across multiple verticals, which included auto, cards, consumer finance, mortgage, private-label cards, retail banking, small business and commercial lending. Carmen has sat on several advisory and industry council boards and has been a guest speaker in both the United States and abroad on the merits of credit scoring, consumer credit data and automated underwriting. She holds a bachelor’s degree in English from the University of California at Los Angeles and currently resides in Irvine, CA.
The regulatory environment continues to be a hot topic in the media today driven largely by efforts to protect the consumer
► Violation of rules put in place to protect the consumer have resulted in heavy fines to various size banks and lenders alike
Understanding rules for data furnishers can help organizations avoid heavy fines and remain compliant
Consumers, Regulators and YouUnderstanding data furnisher rules
Duty of furnishers
Obligations under the Fair Credit Reporting Act (FCRA)
Section 623: Responsibilities of furnishers of information to credit reporting agencies Provide accurate information Prohibited from reporting information with known errors Provide notice of a dispute Duty to investigate and respond to a dispute
Regulation V (part 1022): Responsibilities policies and procedures concerning the accuracy and integrity of furnished information Furnishers must implement written policies and procedures to ensure the accuracy
and integrity of information furnished to the credit bureau Policies and procedures must be appropriate relative to furnisher’s size, complexity
and nature of business Policies and procedures must be reviewed periodically to ensure continued effectiveness
Recent regulatory changes have created an urgency to further expedite our ability to ‘clean up’ the credit eco system and to focus on the consumer
On December 11, 2014 the Consumer Financial Protection Bureau (CFPB) announced that they will now require credit reporting agencies (CRA’s) to provide accuracy reports on data furnishers that identify key risk areas for consumers
Consumers, Regulators and YouRecent CFPB announcement
New reporting requirements
Furnisherswith the most disputes
Industrieswith the most overalldisputes
Furnisherswith high overalldisputes relativeto industry
Each industry has its own set of challenges such as:
Scope of products
Cost of doing business
Data management
Technology advancement
Operational efficiencies
Customer experience
There are a common set of best practices that can help to turn recent commentary and regulatory findings into actionable information to ensure a positive customer experience
Maintaining a full 360 degree view of data reporting, from raw data submissions to the consumer credit profile, is critical to ensuring regulatory compliance and minimizing reputational and financial risk
While an organization may have specific and unique challenges based on the industry and markets they serve, there are commonalities that all data providers exhibit from a product, reporting and regulatory perspective
Consumers, Regulators and YouChallenges within the industry
Report data on monthly basis | Report in Metro 2 format | Regulated by the FTC, OCC, FCRA, CFPB | Dispute management obligations
Unique
Common
Auto Credit card Collections Mortgage
Third party processors
Repossessions
Medical debt
Missing originating information (third party collections)
Identification and contact information problematic
While data reporting is voluntary, data furnishers must adhere to complete and accurate reporting of consumer credit data as mandated in the current Fair Credit Reporting Act (FCRA)
Experian offers reporting tools and metric packages and provides insight and analysis into consumer tradeline and dispute data
Consumers, Regulators and YouExperian’s data quality tools and packages
Data Integrity ServicesSM
Data reporting toolsCustom data review
packages
Metric Report™*
Annualized metric report**
DataArc™ DataArc Plus™DataArc
Custom™
* Offered to select clients currently** Not yet offered, currently being built
Peer dashboards provide a means to benchmark your statistics against a similar peer group Compare peer dispute metrics including: DNR rate, dispute rate, and dispute reason
Consumers, Regulators and YouExperian’s data quality tools and packages
Consumers, Regulators and YouExperian Data Integrity ServicesSM What our clients are saying…
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… if we hadn’t engaged Experian, we might have implemented routines that would have caused downstream negative impact and potential additional consumer harm.
Top-10 financial institution
The data, delivery, consultation and thought leadership were very detailed. We confirmed positive aspects of our reporting and identified recommendations for best-in-class changes.
Top-10 financial institution(Card division)
This was an excellent exercise and an investment no other bureau has undertaken with us, ever. The insight we gained was very valuable.
Lenders should consider that in light of the heavily regulated environment, reporting accurate and complete credit data has significant benefits to the consumer
Our joint obligation is to create a healthy credit eco system and support the choices consumers make as part of their financial journey
Consumers, Regulators and YouConsumer benefit of reporting
Consumers, Regulators and YouConsumer benefit of reporting
Most decisions to grant credit – including mortgage loans, auto loans, credit cards, and private student loans – include information contained in credit reports as part of the lending decision. These reports are also used in other spheres of decision-making, including eligibility for rental housing, setting premiums for auto and homeowners insurance in some states, or determining whether to hire an applicant for a job.”
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— Consumer Financial Protection Bureau, Key Dimensions and Processes in the U.S. Credit Reporting System, December 2012
“Credit reports play an increasingly important role in the lives of American consumers…”
There is currently a gap in awareness within the industry and for the consumer regarding the impact of an accurate and complete credit report
Financial institutions have the opportunity to communicate directly with consumers to create awareness leveraging social media
► Consumers can also share and inform each other creating further engagement
Consumers, Regulators and YouEducating the consumer
GapConsumer
BenefitConsumer awareness
¹ CivicScience, “Insight Report: Social Media Now Equals TV Advertising in Influence Power on Consumption Decisions”, Oct 2014
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43% of U.S. Internet users said that social media “chatter” had the most influence on what they bought... Up 22 percentage points year over year... Those who were most likely to be influenced by comments or recommendations on social media were ages 18 to 29.¹