HMDA and Public Access to New Data

How HMDA data and increased transparency can affect fair lending.

HMDA submission season is just around the corner and your institution’s data will be under close scrutiny by more than regulators. Litigators, advocates and the general public can view the data and possibly use it to identify institutions at fair lending risk. But since HMDA data alone is not enough, this can lead to misinterpretation, unwarranted accusations and loss of reputation. To help mitigate these issues, maintaining HMDA data integrity is essential.

The Home Mortgage Disclosure Act (HMDA) was created to enhance the monitoring of lending patterns and to ensure financing needs are met across a diverse field of potential borrowers. Submitting loan origination and application data on borrower demographics and loan features enables enforcement agencies to identify financial institutions who excel at fair lending and those that require further investigation. In order to accommodate that goal, new data points were added in hopes to further keep biases in check and reduce barriers to homeownership for protected classes.

The new data delivers a deeper understanding of institutional borrowing practices. Regulatory agencies can now apply comprehensive data screening, data monitoring and statistical modeling routines across all lenders subject to HMDA reporting requirements. In addition, many of the new HMDA data fields, like age, credit score and debt-to-loan ratio, can be used for more effective identification of institutions with elevated potentials of fair lending risks.

With the release of the new data, 2020 is the first time members of the public will have greater access to some of the key determinants of underwriting and pricing decisions. Be assured, litigators and advocacy groups will be taking a close look for any sign of unfair practices. Since disparities are estimated after a broader range of pricing and underwriting factors are applied, litigators can present more credible fair lending cases that on the surface appear to be true than with previous HMDA data sets. Furthermore, journalists will also have access to the data, possibly increasing marketing and reputational risks.

Peer analysis also benefits from the new data. Because it is accumulated from all covered financial institutions, it is particularly helpful for defining local and national benchmarks. Peer comparisons can be expanded beyond penetration rates in minority census tracts to include APR, total loan costs, product features and so on. A clearer picture is presented, allowing regulators to more accurately compare benchmarks and identify institutions with elevated fair lending risks.

With more public access to HMDA data, regulators advise caution when interpreting this data, especially if it leads to accusations or conclusions of discrimination. According to a FFIEC Press Release, “HMDA data alone cannot be used to determine whether a lender is complying with fair lending laws. The data do not include some legitimate credit risk considerations for loan approval and loan pricing decisions. Therefore, when regulators conduct fair lending examinations, they analyze additional information before reaching a determination about an institution’s compliance with fair lending laws.”

In today’s world, businesses rise and fall on the whims of public perception. An unsubstantiated claim of discriminatory lending practices based on misinterpreted data could have far-reaching consequences. What can financial institutions do to protect themselves? Understand your data, especially when underwriting and pricing decisions can create and identify disparities. Realize how your data can be interpreted by public regulators, advocacy groups, journalists and litigators. And then be prepared to tell your story and/or present the corrective and preventive actions taken.

The only way to minimize or eliminate risk is to consistently monitor and analyze your own data for pricing, underwriting and redlining risk. Keeping data clean and relevant is essential for accurate interpretation. In addition, separate assessments should be conducted to identify possible anomalies generated by the expanded data fields. This can be an intensive undertaking. Automated compliance software for HMDA reporting will help ensure data accuracy. At the same time, it will help identify fair lending risk points in the application and origination process. When combined with analysis and interpretation, you should be able to identify any additional risk factors.

Marquis can provide a turnkey solution when combining industry-leading tools like CenTrax NEXT compliance software with the experienced and intuitive skills of the Marquis Compliance Professional Services experts. These services can make a great difference in your HMDA reporting process by regularly monitoring and cleaning your data and then helping you understand the HMDA Integrity Analysis. With cleaner data and a deeper understanding of how it can be interpreted, your institution will be better able to respond when your HMDA data is used by regulators and the public to evaluate fair lending risks.

Six Relevant Data Sources to Create Better Connections

It’s clear. In today’s data-rich environment, retailers must optimize the consumer experience to drive business through actionable insights. 83%[1] of marketers exceed their forecasted return on investment (ROI) by implementing personalization driven by data. 91%[2] of consumers assume brands will recognize and remember them. With first-year churn at 50% for financial institutions, it’s understood that personalization can help reverse that trend.

 “Data is the new oil. It’s valuable, but if unrefined it cannot really be used.”

Dave Humby, Chief Data Scientist at Starcount

Oil starts as crude and is only usable after it’s been refined. The same goes for data. To make it actionable and provide a personalized experience, we need to draw from multiple data sources. The following six data resources will help align your audience with your marketing efforts and help you create timely and relevant communications.

Key Data Source 1: Demographics

Demographics, the study of a population and its components, provide insight into a household’s composition, including finances, life events, buying activities, buying behavior and major purchases. They also deliver facts, like age, gender, income level, race and ethnicity. These components help create solid customer/member profiles and are the foundation of any successful campaign.

Demographics, in combination with your core data, help determine segmentation, where they exist and their basic characteristics. Armed with this knowledge, you can confidently develop your marketing strategy and plan.

However, demographic data is limited. “It offers a singular view, like a snapshot in time,” offers Amy McConnell, VP of Marketing Strategy at Marquis, a financial services market leader. “To really harness the power of demographics, you should use this intelligence in conjunction with other data sources.”

Key Data Source 2: Psychographics

Psychographic data sets explore values, attitudes, interests and personality. From them, we can gain a deeper understanding of our financial institutions’ customers/members. This intelligence gives us insight on where they work, play and how they spend their money. All of which aids in understanding who our customers/members are and how to best reach them.

These insights into individual tendencies enable you to build a robust behavior profile, deepen your understanding of segment behavior and assist with strategic media placement. “Psychographics allow you to target smarter by knowing and finding who needs your financial institution’s services,” McConnell added, “They also help drive retention and enhance product offerings based on usage patterns.”

Key Data Source 3: Propensity

Propensity data defines who is in the market for a specific product, like an auto or mortgage loan, and who is likely to have products elsewhere. Drawn from transactions, online and social tracking, surveys and more, propensity data predicts brand affinity along with customer/member preferences and behavior. This data enables strategic targeting and allows you to implement a mirroring effect. However, propensity information is only the likelihood a consumer is interested in specific product, not a guarantee. It’s best to couple this information with other relevant data sources.

Key Data Source 4: Mapping

Mapping converts data into visual references based on location. The visual effect creates a new perspective, making customer/member and prospect clusters as well as their proximity to you and competitors’ financial institutions more visible. For example, in an area dominated by apartment buildings, a personal loan may seem appropriate; however, when demographic, psychographic, and propensity data are overlaid, the dwellers may be more prone to be in the market for a mortgage. It is important to partner with your compliance affiliates to avoid regulatory concerns and mitigate any risks with the usage of mapping and demographic data for marketing perspectives.

Key Data Source 5: Credit Scores

Credit score data leverages a secondary credit risk ranking to help create segments and determine opportunities. A strong credit score is a great indicator for prequalified offers and prescreening for credit increases and activations. However, credit monitoring services, like FICO, are highly regulated. If used with close monitoring and approval from compliance affiliates, the data can help create a powerful and personalized experience to delight your customers/members and strengthen your connection.

Key Data Source 6: Credit Monitoring

Credit monitoring data allows you to know what customers/members are doing outside of your financial institution. “What if you could monitor what your customers and members are doing outside of your organization and take action on it?” asks Andrew Lampkins, SVP of Marketing Client Relationships at Marquis. Credit monitoring helps drive timely and relevant marketing messages at the right time.

Data Management and Reporting

With the vast amount of intelligence collected from these sources, interpreting the data often can be daunting, time consuming, and utilize multiple resources. Using a partner to collect and interpret the data may help to alleviate the strain. Companies like Marquis put their experience and expertise at their client’s disposal. Marquis’ insights help develop strategic marketing plans based on their data, the institutions unique customer/member base and the financial institution’s product offerings.

Without measurable results, ROI can be attributable to other sources. Marquis also offers reporting tools to help their clients discover what campaigns are successful and where programs can improve. The Marquis NEXT Reporting Tool delivers a complete view of campaigns, from product performance to opening rates. Lampkins adds, “A tool like Marquis NEXT is ideal to see the growth of new products due to your campaigns.”

Go Forth and Personalize!

Data is valuable. The insight it provides is the basis of any personalization which guides us on who to target, what consumers want, when they want it and where they are most likely to view the message.

For these reasons, these six data sources are essential to your marketing strategy. They are the keys to winning campaigns with compelling offers and a personalized experience. You’ll gain valuable insights, allowing you to learn more about your audience and their needs. Multiple data sources will also uncover new marketable segments that enable continuous growth. Most importantly, personalized content with the right message delivered at the right time creates loyal and lifelong customers/members who will turn to you first for their financial needs.

[1] Invesp https://www.invespcro.com/blog/data-driven-marketing/

[2] Accenture https://www.accenture.com/_acnmedia/pdf-77/accenture-pulse-survey.pdf

Getting Your Message Across Without Shouting in a Storm

In a little more than a decade since the global financial crisis, things are looking up, especially for U.S. financial institutions. With the calmer waters comes fierce competition. On top of brick-and-mortars, Fintech and Neobanks are hitting their stride while Big Data companies like Amazon and Google are jumping on the lending wagon. Consumers are bombarded with messaging from all sides. How can your bank or credit union’s voice be heard through all this static?

Attracting and Retaining Households

Although it’s true that spending is up, acquiring new households is down and retaining current ones is an issue. Half of all accounts are single-service households. This presents potential retention issues, especially since new single-service households are 50% more likely to leave within a year. The likelihood of leaving halved if they add just one more product. With four products, the potential for leaving decreases to a mere 5%. Concerted efforts to add at least one more product to a household is essential for retention. But it has to be personalized and sent at the right time to the right person. Flooding households with untargeted messaging just doesn’t work, whereas a vehicle loan offer aimed at households with teenagers might do the trick.

Meeting Consumer Expectations

Today’s consumer voluntarily supplies enough information for brands to know and predict their preferences. Nearly three-quarters of global consumers expect brands to treat them as individuals, not anonymous parts of a larger whole. In a world of anonymous avatars and usernames, they expect brands to use the data to approach them as individuals with relevant, personalized experiences. That includes financial institutions.

The Backbone of Effective Marketing Efforts

It’s no secret. If properly utilized, Big Data enables the personalization consumers are looking for. When properly interpreted, you’ll know who your customers/members are, what they need, and when to engage them. Take it one step further to increase growth and profitability by leveraging the data for Growth Analytics.

The Analytics Growth Engine

Growth Analytics is used to identify growth attributes and metrics. An Analytics Growth Engine gives direction and purpose to your Growth Analytics by combining artificial and human intelligence to deliver insights to fuel consistent and predictable revenue growth.

Mark Gibson, Senior Consulting Associate at Capital Performance Group, suggests that growth engines for financial institutions need to have specialized stages.

Stage 1 – Prospecting

Stage 2 – Acquisition

Stage 3 – Onboarding

Stage 4 – Activation & Utilization

Stage 5 – Relationship Expansion

By using data and analytics as tools at each stage, you’ll have precise and scalable data that measurably improves performance and efficiency.

The Super Tools

A strong marketing plan is based on how consumers learn about and buy financial services. It’s about the journey from the prospect to full engagement. Gibson’s Analytics Growth Engine model requires data be applied as a tool to each stage of the process. These tools – Segmentation, Targeting, Engagement Strategies, Life Stage Marketing and Customer Value and Attrition Propensity – lead to a deeper understanding of customer/member needs. In turn, offers are more pertinent to targeted consumers and likely to elicit a response.

Putting It All Together

You have your Analytics Growth Engine. You have your super tools. When the tools are applied, insights will be more meaningful, leading to increased sales, deeper relationships and stronger retention.

Segmentation is the foundation of any targeted marketing strategy. Before prospecting, determine who your best customers/members are, what products and services they use and where they are on their financial journey.

Use Targeting at Stage 1 Prospecting to find prospects who resemble your best account holders. Combine predictive and look-alike modeling with third-party data to target individuals with potential for best value and profitability based on your Segmentation analysis.

Use the Engagement tool to define the onboarding process. Understand what services and products a fully-onboarded customer/member uses. Realize the vision by applying the Engagement tool to Stage 2 and 3 of your Analytics Growth Engine to develop a personalized approach for each customer/member. Then, use the Engagement tool for reboarding to increase activation and utilization.

Life Stage Marketing is perhaps the most important tool for customer/member personalization. Apply it to Stage 4 Relationship Expansion to understand where each customer/member is on their financial journey. Now, you can give relevant advice and predict what products make sense for your customer right now. For instance, a HELOC is meaningless to a 20-year-old college student, but a student checking account might do the trick. This tool helps deliver the right message at the right time.

You’ve reached Stage 5 – Relationship Expansion and your prospect is fully-engaged. Use the Customer Value and Attrition Propensity tool to determine their value to your organization. This allows you to fix a value on retention efforts in both time and money by targeting accounts that historically realize the most value.

You Are Not Alone

Developing a robust Growth Analytics program driven by a strong Analytics Growth Engine is essential in today’s banking landscape. However, most financial services marketers are short on time, training and manpower. Even though financial institutions have remarkably more data than other lines of business, many are unprepared to make the most of this opportunity. But consumers expect us to know who they are and what they want before they even know themselves. If we don’t deliver, we risk losing both prospects and current customers/members. That’s where a company like Marquis can help by leveraging the strength of technology, analysts and creative services needed to extend your reach.

Marquis works closely with your team to develop a strong marketing plan dedicated to attracting new customers/members, expanding product adoption and increasing product use. The Marquis team assembles data sources and provides the tools and expertise to analyze and understand customer/member relationships and opportunities. Using Big Data and Growth Analytics, companies like Marquis become your partner, helping you elevate performance and increase effectiveness. They become your Analytics Growth Engine.

Time for Action

To successfully compete in the current environment, you must engage with customers/members on a deeply personal level and develop a marketing strategy that meets consumers’ expectations of personalization. An Analytics Growth Engine puts your vast amount of data into context to discover new opportunities and promote revenue growth. It’s how you attract prospects and engage with those customers/members most likely to add new products. It makes your message heard in the ultra-competitive world of retail and business finance.

Image courtesy of Mark Gibson, Senior Consulting Associate, Capital Performance Group.

The SCRA – What to Do When Compliance is the Only Option

When duty calls, our military members don’t always have the time or means to care for their finances. The Servicemembers Civil Relief Act (SCRA) requires creditors to reduce interest rates on certain loans, prohibits foreclosures without a court order and allows servicemembers to terminate motor vehicle and domicile in certain instances.

Something to come home to.

The SCRA safeguards active duty servicemembers, reservists, active-duty members of the National Guard and, in limited instances, spouses and dependents. It calls for postponing or suspending certain financial obligations taken on before service began and, for a specified period, post-service. This is how financial institutions help our troops maintain their pre-service financial standing so they can come home to something that’s still worthwhile.

Noncompliance has a cost.

SCRA examiners concentrate on key areas; no reduced APR on loans and credit cards, foreclosures without a court order, repossessions, and apartment and vehicle lease terminations. If active members are not properly identified, a financial institution may be liable for fines, penalties and settlements. In today’s pro-service atmosphere, the reputation hit can lead to the loss of current customers and the distancing of new ones.

Be proactive.

Although required to inform banks and credit unions of their service status, the onus of identifying active military members and affording them their SCRA protections and benefits falls directly upon the financial institution. When a SCRA request is submitted, it is vital to record where it is routed, who reviews it, who approves benefits and who informs the borrower about request status. Your Compliance Management System (CMS) can help make that happen with effective policies and procedures.

Training—It all begins with knowingwhat to look for and how to proceed. Offer regular SCRA training to employees, especially those extending or servicing loans and credit. They should understand compliance obligations to identify active military and ensure they receive the proper protections and benefits. Then make sure employees have the knowledge and tools to identify qualified servicemembers and their dependents.

Internal Controls—Provide clear policies and procedures for SCRA compliance requirements, servicemember identification, loan documentation and other relevant material that demonstrate your institution is doing all it can to be in compliance with the SCRA.

Monitoring—As with all compliance requirements, regular monitoring is essential to ensure SCRA policies and procedures are effective. With the often unforgiving nature of SCRA exams, internal reviews and audits can be a preemptive strike against noncompliance as they identify policy exceptions requiring corrective action.

Identification—In addition to documentation provided by the servicemember, there are two powerful tools you can easily access to identify and monitor customers eligible for protection; the Defense Manpower Data Center (DMDC) and your Customer Information System (CIS). The DMDC is essential to identify and authenticate status. Your CIS, through onboarding and other customer touchpoints, can identify and flag accounts of servicemembers and their dependents.

Complaints—A clearly documented procedure dedicated to SCRA complaints and their path to resolution may prevent issues from coming under the microscope of examiners and give a heads-up to similar problems.

The Benefit of Outside Compliance Experts

The SCRA is one of our oldest protections acts, with similar temporary statutes initiated as early as the Civil War. Made permanent law in 1940, the Act is often updated and riddled with ambiguities, making it open to interpretation, a recipe for misperception and noncompliance. Understanding and staying up to date with the SCRA create a drain on manpower for an already overworked compliance team. An outside party can help navigate these murky waters and alleviate demands, allowing the team to concentrate on other compliance issues.

Marquis Compliance Professional Services, known for their expertise and personal service, are well-versed in all aspects of compliance, including SCRA requirements. They can perform audits and assessments to ensure you have the necessary policies, processes and procedures in place and define areas that need attention. By utilizing third-party compliance experts, you’ll have a fresh view of your SCRA compliance practices and how to improve them.

Conclusion

Self-identification as active military to financial institution is not always a priority for our servicemembers. However, financial institutions are often answerable for servicemembers not afforded the protection and benefits of the SCRA. A robust CMS with clearly defined SCRA policies and procedures is essential. Third-party experts, like Marquis Compliance Professional Services, can help your bank or credit union stay in compliance and away from violations.