discussion and implications: - fair credit reporting act ... · discussion and implications: - fair...

© 2013 Acxiom Corporation. All Rights Reserved. © 2013 Acxiom Corporation. All Rights Reserved.

Discussion and Implications: - Fair Credit Reporting Act - Entity Resolution - Glimpse of The Future

© 2013 Acxiom Corporation. All Rights Reserved.

Fair Credit Reporting Act (FCRA) U.S. credit markets are the most efficient in the world at allowing households to smooth their consumption patterns over time, rather than postpone major purchases until incomes and asset holdings build to sufficient levels.

Accessible credit information “democratizes” financial opportunity.

The importance of consumer credit markets to the strength and resiliency of the U.S. economy is a direct consequence of the credit reporting system

Equally remarkable is the increased access to credit across the income spectrum over the past three decades.

- Dr. Fred Cate and Dr. Michael Staten 2


Fair Credit Reporting Act (FCRA) Access, efficiency and opportunity; the FCRA impacts price,

access, and distribution of credit Without the FCRA either the cost of credit will go up, or access to credit will be reduced There are extraordinary consumer and economic benefits derived from the current national credit system enabled by the FCRA There’s simply no doubt we’ve got a remarkable market for consumer credit in the United States; it’s intensely competitive, and we’ve made dramatic progress in terms of fairness and access for certain groups, who quite frankly, were not so well served by the marketplace ten or twenty years ago

-Dr. Michael Turner

3


Fair Credit Reporting Act (FCRA) • FCRA enacted in 1970 to promote accuracy, fairness, and

privacy of personal information assembled by Credit Reporting Agencies (CRAs).

• Sector specific “data use” law • Amended many times • Credited with creating a system of credit for “everyman” • Covers the disclosure and use of “consumer reports” • Covers the requirements of “consumer reporting

agencies” • Gives enforcement authority to the Consumer Financial

Protection Bureau (CFPB) and the Federal Trade Commission (FTC)

4


“Consumer Reports” • Very broadly defined

• Basically any information

• Bearing on a consumer’s credit worthiness, credit standing,

credit capacity, character, general reputation, personal characteristics, or mode or living

• Which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer’s eligibility for credit or insurance, employment purposes or (other permissible purposes under the FCRA)

5

*USE DRIVEN*


“Consumer Reporting Agencies”

• Equally broad

• Essentially any person that for a fee, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties

• If you provide “consumer reports, you are a “consumer reporting agency”

6


Implications of Being a “Consumer Reporting Agency”

• CRAs have a number of obligations under the FCRA -Notices to “furnishers” and “users” -Duty to provide access to “files” to consumers -Duty to reinvestigate disputes

• Information in files can only be disclosed for “permissible purposes“

• Consequences of Violation of the FCRA - The FTC and CFPB can bring enforcement actions -State attorneys general can bring enforcement actions - In some instances, criminal liability can exist

7

Acxiom as an Agent

8


Reason for Agency Relationship • Acxiom is not a CRA • Acxiom does not have a permissible purpose to

obtain Consumer Report • Agency relationship allows Acxiom to stand in the

shoes of the bureaus and process their data • Allows Acxiom to serve as a “one stop shop” for our

clients • Agent is entitled to have possession of Consumer

Reports that may not result in a firm offer of credit • Agent is entitled to full SSN • Agent is entitled to “know” the descriptions of the credit

attributes

9


Definition of “Bureau Data”

• As a general rule, any data sourced from a bureau (including name, address, SSN, date of birth, credit attributes, IDs), regardless if data is anonymous or depersonalized

• Whether Bureau Data is also a Consumer

Report depends on whether it is personally identifiable (e.g. name and credit attributes)

10


When Can Financial Institution Receive a List of Consumers and Credit?

• Only if it intends to make a firm offer of credit or insurance to each individual who meets all of the Client's previously determined criteria

• The FCRA states that for prescreening purposes, "a person may receive only - The name/address of a consumer - An identifier not unique to the consumer used solely for verifying

identity of a consumer • Other information pertaining to a consumer that does not identify the

relationship or experience of the consumer with respect to a particular creditor or other entity.”

• Client may not receive Social Security Numbers

11


File Inputs for Bureau Solution

• 300,000,000 record file from each Bureau • Other data files • Standardization, Hygiene and Correction • Front end suppressions (deceased, opt-outs, edit fails) • Scoring based on Credit Selection Criteria • Creation of the preliminary pre-screen lists • Additional last minute suppressions • Delivery of the pre-screen list to client and distribution

channel • Delivery of promotional inquiry file to the Bureaus

12


Security

SERVICE DELIVERY Project Management Implementation Consultative

Services Systems Management In

put S

ourc

es

A

Bureau Files

Enhancement

Suppressions

Customer And

Response

Dat

a In

tegr

atio

n B

Link Append

Postal Cleansing

Validation and

Reporting

NCOA

Acxiom Services

Data Hygiene

AbiliTec Demographics

Suppressions

C

Campaign Execution

SCORING Scoring Extract

Scoring

E

DATABASE ENVIRONMENT

D

Warehouse Database

CAMPAIGNS MARTS TOOLS OUTPUT

Campaign Datamart

Summarization Tables

Rapidus

Fulfillment

Campaign History

DM Vendors

Email Vendors

Call Centers

Operational Reporting

Reporting Datamart

Reporting Calculation

s

F

G

Acxiom Information Security, Privacy & Data Governance Acxiom Operational Support—Account Dedicated + Infrastructure Management

Vertical Lists

Opt Outs

Outputs

Scoring Extracts

Solicitation Files Reports

H

Bureau Solution

Database Extracts

13

Premium Mail


Name Contact and Life stage Changes

Touch Points Call

Center

Direct Marketing

Brick & Mortar

Website

Address Home Phone

Computer

Cell Phone

eMail

Customer Support

Digital Campaign

Entity Resolution… Why is it so hard?


> Recognize Consumers using: • Physical or Email Addresses • Landline or Cell Phones • Name variations, nicknames, changes,

maiden/married surnames

> Proprietary Knowledge Base • 2 billion+ historical occupancies • Patented matching algorithms • Up to 35 years of occupancy history • Multiple, contracted sources • Updated Weekly

[email protected] Becky Jones 789 Main Street

[email protected]

Rebecca Jones Link: ABC12345

Mobile: 501-252-1000

Only AbiliTec® enables complete consumer linking

Traditional Entity Resolution

15


Data Quality

Match and De-Duplicate: Identification of duplicate records within or across disparate source files and assignment of non-consistent identification keys; optional merge / purge of duplicate records

Correct and Enrich: Corrections and completions to contact information, including change of address, routing data, ZIP + 4®, Geo data, compliance and preferences, etc.

Parse and Standardize: Decomposition of data sets into distinct elements; standardization of customer records to regionally accepted formats for name, address, phone, email, and other data elements

Entity Resolution

Data Quality and Entity Recognition Can Eliminate the Challenges Associated with Information Decay, Incomplete Records and Distributed Intelligence

Recognition Management Manage and Integrate: Capabilities that enable the mastering of customer

data across an enterprise; results in a unified customer view to ensure availability of consistent information for operational and analytical systems.

Consistent: Ability to accurately recognize customers over time, across multiple channels and data sources using all available identifying information.


Prospect Data

Web Registration

Customers

• Good • Profitable • Loyal

• Average • Growth

Potential

• Poor • Headaches • Losses

Clean Match Analyze Score Segment

Explosion of Online Data Multiplies Process Gaps and Sub-Optimizes Your Data Assets

• Inability to connect online and offline contact data because • Can’t match online persona to real world person • 60% of U.S. adults use more than one e-mail address • Multiple browsers, multiple devices per person

• Inability to standardize and correct customer attributes

• Skews customer identification processes • Pollutes internal systems with incomplete and inaccurate info

* Chart: Accenture Global Content Study 2009

Most critical factors in enabling better use of consumer information (choices ranked in top three) *


Data Quality Problems and Matching Inaccuracies Affect Downstream Activities

Prospect Data

Web Registration

Customers

? •Profitable •Loyal

? •Average •Growth Potential

? •Headaches •Losses

Clean Match Analyze Score Segment

• Incomplete data discarded – shrinking your customer universe • Email and mobile can’t be linked to physical name and addresses • Incorrect scoring and segmentation hurts effectiveness


The Ripple Effects of Poor Recognition Management

Enterprise Application Implementation Failure

If the data is bad, it will be avoided, “work-arounds” will be applied that compound the problem

Cripple Cross Sell and Up Sell

Without a quality, effective view of the customer, timely targeted offers and communications are not possible

Threaten the Entire Customer Relationship

An inability to confidently recognize and care for a customer when contact is made can threaten the relationship. Enable Fraud.

Damage to Corporate Image

Incorrect offers, reaching out to inappropriate people (e.g., imprisoned, deceased), and not delivering on sales and marketing objectives effectively can cause damage to a corporate image

Negative Financial Impact Difficulty in recognizing the value of CRM, MDM or EDW purchases compounded by an inability to deliver on revenue and earnings targets


Start with DATA QUALITY

Standardization provides foundation for identifying duplicates and households Basic

Facilitates more profitable promotions Advanced

• In addition to Basic

Most stop here

Most accurate view of the consumer to:

• Improve analytics and decision making

• Reduce operational cost • Increase customer insight • Enlarge mailable universe

and maximum postal discounts

Premium • Corrects over 48% of missing or incorrect

address information

• 8% better insight on new movers

• 26% greater contact validation

• Supplies new address for 50% of the NCOALink® near matches or Moved Left No Address

Acxiom is a non-exclusive Full-Service Provider Licensee of the United States Postal Service®. The following trademarks are owned by the United States Postal Service®: United States Postal Service® NCOALink®, CASS™, DPV®, SuiteLink™, DSF2®, ZIP™; LACSLink®; ZIP Code™; First-Class™; eLOT® and ZIP + 4®


Recognition

Matching

Sort

Match and

ID Assignment

ID = 5678 Becky Smith

45 Oak St Chicago, IL

ID = 1234 Rebecca Jones

12 Main St Conway, AR

Sort records based on geographic information (ZIP™∗, Address, Last Name and First Name)

Group similar records within a geography together and attempt to match prospective records together

Traditional String-Based Matching

Becky Smith 45 Oak St Chicago IL

Rebecca Jones 12 Main St Atlanta GA


Link = ABC123 Becky Smith

45 Oak St Chicago, IL

Link = ABC123 Rebecca Jones

12 Main St Atlanta GA

Move Record

Knowledge-Based Matching

Link = ABC123

Becky Smith 45 Oak St Chicago, IL DOB: 7/4/60 Assoc=12345

Becky Wilson 123 1st Ave Phoenix AZ DOB: 7/4/60 Assoc=12345

Rebecca Jones 123 1st Ave Phoenix AZ

Rebecca Wilson 123 1st Ave Phoenix AZ

Association Name Change

Name Change

AbiliTec Knowledge

Base


Becky Smith 45 Oak St Chicago IL

Link Append Rebecca Jones [email protected]

Link = ABC123 Rebecca Jones

[email protected]

Rebecca Jones [email protected]

21


cookie 12

cookie 9

[email protected] Becky Jones-Hall 789 Main Street [email protected] Mobile: 501-252-1000

Digital Disconnect: device signature

22

cookie 1 cookie 2 cookie 3 cookie 4

device 1

device 2

device 3


cookie 10 cookie 11

Safe Haven

[email protected] one-way hashed to:

irreversible_UUID Associated to devices 1 and 3

Online Purchase

How many people purchased? How many purchases were there?

Offline Purchase

cookie 12

cookie 9


device 1

device 2

device 3


cookie 10 cookie 11

Safe Haven

[email protected] one-way hashed to: irreversible_Abilitec_ID

Associated to device 2

mailto:[email protected]



cookie 12

cookie 9

[email protected] Becky Jones-Hall 789 Main Street [email protected] Mobile: 501-252-1000

Entity Resolution - A Single View

23


device 1

device 2

device 3


cookie 10 cookie 11

Safe Haven

cookie 12

cookie 9


device 1

device 2

device 3


cookie 10 cookie 11

Safe Haven

[email protected] one-way hashed to: irreversible_Abilitec _ID

[email protected] one-way hashed to: irreversible_Abilitec_ID

Associated to devices 1 and 3

Associated to device 2

Online Purchase

Hashed Abilitec ID

Offline Purchase

Safe Haven




Reach Trust Open Accuracy


Tie Every Interaction to a Known Person

Email Capture Refer a Friend Invite a Friend

In-Store Purchase Name, Address Email Address Purchase Type Credit Card Type Merchandise

Direct Mail Birthday Reminder Offer Tailored to Me

Search Search Terms Referring URL Site Activity

TV Ad Watching

Squawk Box

Customer ID 1234

R. Jones 123 Main St.

NY, NY

Social Liked on Facebook Tweets about

Experience with Client Updates Status about

Great Experience

Online or Mobile Ad Browsing Web Impression and Click Anonymous to Client

Online Purchase Purchase, Extended Warranty Browsing Activity Email Address, Preference Center Life Events


Single view to: • Connect Your Data • Develop New Audiences • Distribute Data • Analyze Results • Optimize Campaigns

AOS™ Vision: An Integrated Marketing Platform

Data Security Rights

Mgmt

Analytics Audience

Management

APIs Campaign

Management

Reporting

PII Anon

Access

Email Page Visits Apps Behaviors Response

Search Social Demo- graphics Promo Partners Online

Imps

Integration


Online Purchase

Anonymous AbiliTec ID™

Offline Purchase

cookie 8

cookie 5

[email protected] Mobile: 501-252-1000 [email protected]

Single Person View Powered by Linking


DEVICE

cookie 6 cookie 7

3 cookie 9 cookie 10 cookie 11 cookie 12

1

2

Becky Jones-Hall 123 Main Street

DEVICE

One vs. Many


Apple Device

Facebook

Candy Crush

Segment A

High Spender

In Market for Travel

35-40

Female

Segment A

High Spender

High Online spender

New Mom

Dog Lover

Segment A

High Spender

Luxury Sedan Owner

Married

Visa User

Segment A

High Spender

Anonymous AbiliTec ID: 123

Bringing Offline / Online Together

AbiliTec ID d894ad8sae

Segment A

Cust Type High Spender

Geo New York

Income $150 – 175K

Onboarding with Anonymous AbiliTec ID™

Device Signature

Method

Tablet

Device ID DEF

Work

Device ID GHI

Home

Device ID ABC

Mobile

Device ID JKL

Cookies Associated with Anonymous AbiliTec ID: 123

Becky Jones

Offline / CRM Database

Offline Purchases

DFA Clicks/ Impressions

AbiliTec Method

=

=

Requires Accurate, Privacy-Compliant Linking


Multi-Dimensional Data View

29

DEMOGRAPHIC

IN-MARKET

SEARCH

INTEREST

PURCHASE BEHAVIOR LIFESTYLE

CRM

EMAIL

SOCIAL

VIDEO ENGAGEMENT

APP DOWNLOADS

*All logos listed herein are the property of their respective owners.

discussion and implications: - fair credit reporting act ... · discussion and implications: - fair...

Documents