CFPB’s Future May be Cloudy, but the Outlook is Bright for Credit Unions

By: Beth Planakis, Director of Marketing, Velocity Solutions.

It’s hard to believe it’s been seven years since the formation of the CFPB, but it’s easy to remember what fueled its creation – a financial crisis that Americans hadn’t seen since the Great Depression. And what was one of the most flammable fuels in the fire? Mortgages. Specifically, mortgages that consumers couldn’t afford, couldn’t understand, and for which, in years prior, would never have qualified.

So, as part of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, the CFPB was formed to protect consumers from unfair, deceptive or abusive practices in their dealings with financial services and products. Fortunately, the subprime mortgage crisis has since been reigned in, but the bureau has long monitored other types of predatory lending – namely, high-cost payday loans.

While Richard Cordray was Director of the CFPB his expectations were very clear that banks and credit unions could and should be low-cost providers of small-dollar loans, and that payday loans should be more closely regulated. So he proposed a payday lending rule and made significant progress with his agenda. On October 3, 2017, the CFPB cracked down on this “predatory practice” and issued its final payday lending rule, restricting lenders’ ability to profit from high-interest, short-term loans. The tough new restrictions were predicted to essentially decimate the storefront payday lending industry, potentially resulting in up to an 80%* plunge in payday loan volume. The $37,000 annual profit generated by the average storefront lender was estimated to become a $28,000 loss*. That’s a bleak outlook for payday lenders.

Flash forward to today. We’re now living in a post-Cordray world, with front-row seats to a helter-skelter leadership scuffle in the CFPB. Mick Mulvaney, the newly appointed Director of the CFPB, has vehemently voiced his opposition to the payday lending rule. However, it appears that the rule will not be rescinded by the CFPB itself, and it is debatable whether Congress will use its authority under the Congressional Review Act to overturn the rule.

So, what does this mean for credit unions? How can they better serve their members despite the uncertainty?

Proponents of the CFPB say it’s a watchdog agency working for American consumers, and that the payday rule will protect consumers from lenders behaving badly. Opponents believe the CFPB has too much power and that the rule is limiting consumers’ access to liquidity, and even their right to choose how to obtain that liquidity.

But whatever the outcome of the payday lending rule, credit unions have an enormous opportunity to better serve their members with small-dollar loans that are responsible, affordable and compliant.

If the rule takes effect as scheduled in 2019, consumers will be desperate for sources to obtain emergency cash with the storefront payday lenders closing shop. If the rule is overturned, it’s still just as critical to offer your members smarter, more affordable loan options, and to help educate consumers that these superior options exist. Now is the time for credit unions to step in and provide low-risk and affordable small-dollar loans for their members in need of emergency cash.

Here are the top 5 reasons this is a grand slam for credit unions, regardless of the future of the CFPB’s payday lending rule:

  1. Provide a new valuable service to your members, increasing loyalty, retention and lifetime value.
  2. Generate a new source of revenue from members paying high fees elsewhere.
  3. Protect your members from predatory lenders.
  4. Acquire new members by promoting an affordable and convenient small-dollar loan option.
  5. Work more efficiently and effectively. By joining with a partner company that offers a comprehensive, automated solution, your credit union will benefit:
    • No additional loan officers or other additional staff needed
    • Underwriting technology that is automated and proven
    • Assistance with compliance best practices
    • Data-driven marketing to educate consumers about the availability of lower-cost loans

Seize the opportunity now, and make it a resolution to implement a small-dollar, short-term loan solution in early 2018!

Velocity SolutionsVelocity Solutions is the NAFCU Services Preferred Partner for Account Holder Premium Card Rewards Program and Overdraft Management Solutions. More information and educational resources are available at nafcu.org/Velocity

*New York Times, Payday Lending Faces Tough New Restrictions by Consumer Agency, October 5, 2017.

Finding New Ways to Serve the Nation’s Underbanked

By: Lawrence Pruss, Senior Vice President and Payments Expert, Strategic Resource Management.

According to the Federal Deposit Insurance Corporation, approximately 27 percent of all American households are unbanked or underbanked – that’s 50 million individuals.

For purposes of this article, unbanked refers to individuals who don’t have a bank account and underbanked refers to those who supplement their bank account with alternative financial services like check cashers. Both underbanked and unbanked households are typically forced to rely on nonbank financial or high-rate lending solutions such as payday lending, tax refund, and settlement loans.

How did we get here? Why are so many people in the United States outside of traditional banking security in 2016? There are several reasons why, with many people falling into more than one category. This article addresses these issues and provides solutions your credit union can offer to serve the underbanked and help them become members of your credit union.

Case One: During the Great Recession from late 2007­— early 2009, many people with previously good credit had their credit history tarnished. Most financial institutions now exclude these individuals with a record of bounced checks, overdrafts, or delinquencies.

Solutions: Offer second-chance checking accounts, debit or prepaid solutions, and credit building tools generally available at local banks or credit unions.

Case Two: A significant portion of the immigrant population is underbanked. They often arrive to our country with a distrust of traditional banking systems, and depending on legal status, avoid traditional banks that require government issued identification. Increasingly stringent Know Your Customer (KYC) and other anti-money laundering regulations have exacerbated this situation.

Solutions: Develop easy account applications and use alternative identification solutions like individual taxpayer identification numbers (ITIN). The IRS issues ITIN numbers to non-citizens who are working in the U.S., but are not eligible for a Social Security number. Develop inexpensive money transfer solutions which can help alleviate high fees typically associated with transfers, and consider alternative lending scores to help qualify these individuals for financial products.

Case Three: Approximately half of the 80 million millennials in America (those between 18 and 29) are unbanked or underbanked. The 2009 Credit CARD Act put strict limits on how credit cards are marketed and issued, and an inherent skepticism of large money-making institutions and Wall Street means many young adults are hesitant to pursue credit cards and other traditional banking products. In fact, more than one-third of that population has never had a credit card.

Additionally, because of their digital communication preferences and desire for fee and pricing transparency, companies that offer clear debit, prepaid, or increasing alternative financing solutions are winning over this segment. Examples include PayPal, Google, and some of the more creative credit unions with “young and free” efforts geared toward the younger generation.

Solutions: Establish your institution as a trusted, tech-savvy brand to build loyalty with this consumer group, locking them in as future, long-term members.

Case Four: While the official unemployment number is at 5 percent, or 7.9 million people, an estimated 30 million Americans are still out of work or underemployed – an audience typically avoided by banks.

Solutions: Develop lending based on an individual’s potential. Many of these individuals have returned to school or pursued further training while being un- or underemployed. This offers a great opportunity for establishing lifelong loyalty for those institutions willing to take a chance on their future success.

The number of un- and underbanked individuals in the United States is larger than the total populations of many countries. As such, it offers a huge opportunity for American financial institutions willing to better understand “why” they are underbanked and then find ways to support them and help them reach their unique needs.

Strategic Resource Management is the NAFCU Services Preferred Partner for Vendor Cost Benchmarking and Negotiation Services.

3 Questions for Your Mobile Banking Partner (Part 1)

By: Will Furrer, Senior Vice President – Product Group, Q2  

With the ubiquity of the mobile-first member, implementing a mobile banking solution should be a top priority for your credit union. In this blog series, we will address the top three questions your credit union should ask a digital strategy company when developing a mobile banking plan.

Question 1: Does your mobile digital experience mirror your online channel?

People say the mark of a true champion is consistency. The same is true for mobile banking. Although mobile banking is seeing rapid adoption and growth by credit union members, it’s not projected to actually outpace interactions via the desktop until the year 2020.

The ability of your digital solutions vendor to provide a consistent experience—from data to workflows to functionality—should be high on the priority list as you make your selection.

Data Consistency  

When discussing mobile strategy with a possible partner, it’s important to ensure that all of your data is consistent between devices. When making buying decisions for a mobile banking partner, this attribute is often overlooked.

The accuracy of the data across devices—desktop, laptop, tablet, and mobile phone—is critically important. Without consistent data, you risk eroding the brand you work so hard to promote with your members; confused and frustrated members aren’t generally good brand promoters.

Consistent data across devices is table stakes for today’s multi-device member. Earn their trust, solidify your brand, and grow your digital channel strategy with consistency at its core.

Click for Q2 Case Study – Flexibility 

Dependable Experience

The branch used to be the central touchpoint for most credit unions. Today, however, more interactions are happening outside the branch than ever before.

Providing a dependable brand experience on any device, anytime, that’s in line with what your members need and desire, should be paramount in your decision making. The language and workflows your members are accustomed to on their computers should mirror that of their mobile devices.

The same care should be taken with the digital experience you provide your members, as the care you demonstrate when members are in the lobby of your credit union.

Click for Q2 Case Study – User Experience 

Reliable Functionality

Finally, where the rubber meets the road is with functionality. What members want is the ability to do everything they can do online on their mobile devices. Scheduling bill payments, aggregating accounts, categorizing expenditures and setting language preferences – all the value they’re afforded on their laptops and desktops, they also demand on their mobile devices.

Strengthen your credibility with your mobile members by ensuring they have access to all the features and functionality they have on their desktops, with a mobile banking tool that has the reliable functionality they can count on.

Click for Q2 Case Study – Brand/User Experience 

Look for Part 2 of our blog series for Questions 2 & 3 of what to ask your mobile banking partner, and to learn about implementing a mobile strategy.

 

Q2 is the NAFCU Preferred Partner for Single Platform Virtual Banking Solutions—Including Online and Mobile—for Community and Regional Financial Institutions. Learn more about Q2 by visiting www.nafcu.org/q2.

Card Data Breach Loss Prevention Checklist

By Ann Davidson, VP of Risk Consulting at Allied Solutions

Many of the large-scale card data breaches in 2015 involved the compromise of magnetic stripe data on both credit and debit cards. The data compromised in most of these card breaches involved either track 1 or track 2 magnetic stripe fraud (POS 90), as determined by the merchant during the transaction authorization. Because the track information can be duplicated, there will likely be a high risk for future fraud exposure if you opt not to block and reissue these cards.

For an in-depth look into payment card fraud risks that many credit unions are being hit hard with right now, watch Allied’s webinar “Card Fraud on the Rise: How Financial Institutions Can Help Prevent It.”

Card Data Breach Loss Prevention Checklist:

  • Evaluate the compromised card number to help determine if the risk is high
    • A high risk involves the full unaltered magnetic stripe data from track 1 and/or track 2 – track 1 carries the cardholder name; track 2 does not
  • Confirm you’re utilizing “name matching” if track 1 data was part of the breach
  • Review card associations’ alerts and act immediately on at risk card data outlined in alert
  • Analyze at risk open card accounts to determine which cards are/are not still active
  • Review other card accounts to find out which cards are non-active and have already been closed due to fraud
  • Identify the fraud pattern to uncover the common point of compromise (CPP)
    • This is where the breach took place, not where the fraud occurred
    • Once discovered, report the CPP immediately
  • Block and reissue impacted, open card numbers when magnetic stripe has been compromised
  • Accelerate the reissuance of active cards prior to their expiration date
  • Consider reissuing the card 30 to 180 days before the date of expiration
  • Ask the card association(s) to take recovery action related to any expenses
  • Report the fraud to the Visa Fraud Reporting System and/or MasterCard’s Safe System, as this is a requirement under the card association(s) rules

Watch Allied’s webinar “Card Fraud on the Rise: How Financial Institutions Can Help Prevent It” to learn more about payment card fraud risks.

Allied Solutions is the NAFCU Services Preferred Partner for Insurance- Bond, Creditor Placed (CPI), Guaranteed Asset Protection (GAP), and Mechanical Breakdown Protection (MBP). More educational resources and partner contact information are available at www.nafcu.org/allied.