Delinquency trends and collection regulation update under the Consumer Finance Protection Bureau (CFPB)

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Transcription:

Delinquency trends and collection regulation update under the Consumer Finance Protection Bureau (CFPB)

Introducing: Edwin de Buck ING Gordon Cameron PNC Kelley Motley Experian

1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 70 MILLION 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 1M 3 Experian 4/26/2017 Experian Public Vision 2017

Timeline Fair Debt Collection Practices Act 1978 Fair Debt Collection Practices Act Reform Timeline not to scale? Great Depression 1929-1939 Gramm-Leach- Bliley Act 1999 Great Recession 2007-2009 Volcker Rule 2014 Glass- Steagall Act 1933 Dodd-Frank Act 2008 4 Experian 4/26/2017 Experian Public Vision 2017

Regulation cycle and potential targets Usually introduced at times when the economy is faced with hard times, impacted lending When times get better, deregulation is introduced to knock down the barriers established to protect All these actions impact lending to consumers and drives delinquency rates down or up, as a result Potential regulatory targets: Dodd-Frank Act Glass-Steagall Act Volcker Rule 5 Experian 4/26/2017 Experian Public Vision 2017

Billions Originations by lending product YOY change 4Q 2015 vs. 4Q 2016 Change 4Q 2011 vs. 4Q 2016 Mortgage +54% 111% Bankcard +15% 166% Auto loan and lease +10% 78% 180 160 140 120 100 80 60 40 20 800 700 600 500 400 300 200 100 Mortgage in billions HELOC +10% 150% Retail +6% 131% Personal loan -6% 104% 0 2011 Q1 2011 Q3 2012 Q1 2012 Q3 2013 Q 1 2013 Q3 Auto Loan & Lease HE Loan Personal Loan Mortgage 2014 Q1 2014 Q3 2015 Q1 2015 Q3 Bank Card HELOC Retail 2016 Q1 2016 Q3 0 Source: Experian IntelliView SM 6 Experian 4/26/2017 Experian Public Vision 2017

Average U.S. debt-to-income Debt-to-income and non-mortgage debt 16% Debt to Income Insight SM $41,000 Average non-mortgage debt 15% 15.15% 15.28% 14.85% $40,000 14% 14.25% 13.79% $39,000 Up 11% 13% 13.27% 12.76% $38,000 12% 11.85% 11.66% 11.66% $37,000 $36,000 11% $35,000 10% 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 $34,000 1Q12 1Q13 1Q14 1Q15 1Q16 7 Experian 4/26/2017 Experian Public Vision 2017

Delinquency by lending product 90-180 DPD 90-180 DPD 4Q-2016 YOY change 4Q-2015 vs. 4Q-2016 YOY change 4Q-2011 vs. 4Q-2016 0.003% 0.003% Mortgage 0.65% -12% -72% 0.002% Bankcard 1.49% +12% -44% Auto loan and lease 0.32% +16% +31% 0.002% 0.001% 0.001% HELOC 0.51% +4.0% -58% Retail 2.49% +10% -2% Personal loan 0.74% +18% -22% 0.000% 2011 Q1 2011 Q3 2012 Q1 2012 Q3 2013 Q1 2013 Q3 2014 Q1 Auto Loan & Lease HELOC Personal Loan 2014 Q3 2015 Q1 2015 Q3 Bank Card Mortgage Retail 2016 Q1 2016 Q3 Source: Experian IntelliView SM 8 Experian 4/26/2017 Experian Public Vision 2017

% of Consumers % of consumers Ability vs. willingness to pay Early and late stage delinquency by risk tier 60% 40% Risk distribution Early Late 20% 0% Exclusion Deep Subprime Subprime Nonprime Prime Super Prime 40% Income 30% Early Late 20% 10% 0% 1-20 21-30 31-40 41-50 51-60 61-70 71-80 81-90 91-100 101+ 9 Experian 4/26/2017 Experian Public Vision 2017

Ability vs. willingness to pay by risk tier Early and late stage 100% 80% 60% 40% 20% 0% Early stage Late stage Good Bad 10 Experian 4/26/2017 Experian Public Vision 2017

Ability vs. willingness to pay by income Early and late stage 100% 80% 60% 40% 20% 0% Early stage Late stage Good Bad 11 Experian 4/26/2017 Experian Public Vision 2017

CHAID analysis design Total delinquent records as of Jun 2016 Early stage delinquents (30, 60) 10% 90-day delinquent 2% Late stage delinquents (120+) 88% Decision tree analysis 12 Experian 4/26/2017 Experian Public Vision 2017

Decision tree Total population VantageScore 3.0 Early stage Late stage 13 Experian 4/26/2017 Experian Public Vision 2017

Decision tree Total population VantageScore 3.0 Early stage Late stage Total number of trades presently satisfactory that were ever 30+ days past due Total balance on trades presently 60 days delinquent reported in the last 6 months Worst present status on a trade Number of months since the most recent derogatory on trades 14 Experian 4/26/2017 Experian Public Vision 2017

Decision tree Total population VantageScore 3.0 Early stage Late stage Total number of trades presently satisfactory that were ever 30 or more days delinquent or derogatory Total credit amount on unsatisfied derogatory trades Worst present status on a trade Number of months since the most recent derogatory on trades Number of months since the most recent charge-off Number of months since the oldest 60 days delinquency on trades Number of months since the oldest derogatory occurrence on trades Number of months since the most recent 60 days or more delinquency or derogatory Number of months since the most recent 90 days or more delinquency or derogatory Number of months since the most recent derogatory on trades 15 Experian 4/26/2017 Experian Public Vision 2017

CHAID analysis Early stage Risk Level High Average Low average Low Total Bad % with ind 87.8% 54.5% 28.5% 0.0% 47.3% Good / bad ratio 0.13 0.75 2.42 N/A 1.06 % of total population 22.8% 38.3% 22.6% 16.3% % of total good 5.2% 31.1% 31.1% 32.6% % of total bad 42.2% 44.2% 13.6% 0.0% Account status 6 months later in December 2016 Account status as of June 2016 Early stage Current 30 60 90 120+ Charge-off 30 Good Good Bad Bad Bad Bad 60 Good Good Ind Bad Bad Bad 16 Experian 4/26/2017 Experian Public Vision 2017

CHAID analysis Late stage Risk Level High Average Low average Low Total Bad % with ind 96.9% 92.0% 88.3% 37.7% 89.4% Good / bad ratio 0.02 0.08 0.12 1.60 0.11 % of total population 46.7% 28.9 16.3% 8.0% % of total good 10.9% 21.3% 18.3% 49.5% % of total bad 50.7% 29.8% 16.2% 3.4% Account status 6 months later in December 2016 Account status as of June 2016 Early stage Current 30 60 90 120+ Charge-off 120* Good Good Good Ind Bad Bad Charge-off Good Good Good Ind Ind Bad 17 Experian 4/26/2017 Experian Public Vision 2017

What might deregulation mean Impact to credit market Large reform would require Congressional approval No more big banks, separating commercial and investment Positive impacts: Loan growth Consumer confidence and spending increases Increase earnings of financial institutions with rate increases and steeper yield curves Rise in interest rates Negative impacts: Weaken capital, liquidity, and resolution standards Weakening of creditworthiness Increase consumer debt to income ratios Increase consumer delinquencies 18 Experian 4/26/2017 Experian Public Vision 2017

Customer Centricity in Collections Edwin de Buck Tribe Lead Center of Expertise Collections DBNL

Edwin de Buck Tribe Lead CoE Collections, ING Domestic Banking, The Netherlands

Center of Expertise Collections ING The Netherlands SPECIAL SERVICING RETAIL NL > 100 BILLION MORTGAGES CONSUMER LOANS, CREDIT CARDS, CURRENT ACCOUNTS SMALL & MEDIUM ENTERPRISES

Mission

Collections: Finding the Optimum Customer Satisfaction Operational Costs Cost of Risk

Pillars of Customer Centricity Customer / Relationship driven Sustainable Solutions Change of Behaviour Intrinsically Motivation Willingness and Ability The right Action at the right Time for the right Customer

Operating Model of Customer Centricity Customer Journey (End-to-End) Segmentation & Differentiation (Data) System & Work instructions (Process) Education, Training and Motivation (Collector) Customer Journey and Feedback Loop (Continuously Improvement )

Tools for Customer Centricity Emotion Curve & Moments of Truth Closed Loop Customer Feedback Customer Experience Improvement Cycle (CEIC) Continuously Improvement Agile Way of Working

Customer Journey: Emotion Curve & Moments of Truth Episode 0: Context Episode 1: I Can t pay anymore Episode 2: Informed about arrears Episode 3: Phone contact with ING for payment agreement Episode 4: Repay Episode 5: Customer changes agreement Episode 6: I repaid! relief relief unrest uneasy neutral uncertain shame stress resigned/ uncertain irritated unsatisfied/ uncertain Emotional customer journey 3.0 I have to prepare myself(7+ moment) I have to cross a border to contact ING + moment) First contact: respect me (9+ moment) Contact me: inform, explain, keep me posted (9+ moment) Contact me: appreciate, respect, after care financially fit (9+ moment)

Closed Loop Customer Feedback Loop: Objectives Voice of the Customer Training and Coaching of Collectors Improve Customer Journey

Customer Experience Improvement Cycle (CEIC) MVP: Minimum Viable Product

Continuous Improvement: Small and Large Circle

Questions and answers Experian contact: Kelley Motley Kelley.Motley@experian.com 32 Experian 4/26/2017 Experian Public Vision 2017

Share your thoughts about Vision 2017! Please take the time now to give us your feedback about this session. You can complete the survey at the kiosk outside. How would you rate both the Speaker and Content? 33 Experian 4/26/2017 Experian Public Vision 2017