Auto Finance Fraud

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Perspectives on Fraud in Indirect Auto Finance
Ted Brown & Bart V. del Cimmuto BenchMark Consulting International Introduction Three scenarios have, unfortunately, become increasingly common in the world of indirect auto finance. In the first scenario, a small group of fraud perpetrators develop phony business entities to bilk a lender out of four high-end luxury vehicles in rapid succession. In the second scenario, a lender grants a loan to a creditworthy applicant, but the account becomes delinquent soon after it is booked. Collections personnel contact the customer only to discover that she does not drive the vehicle, but simply “signed for” her grandson so that he could take delivery of the car. The customer refers collections efforts to the unobligated grandson. In the final case, a heavily obligated applicant for a luxury SUV lists fictitious additional income from rental properties to persuade the prospective lender of his ability to handle a higher car payment and, hopefully, to receive a lower rate. While these situations range greatly in severity, they have one thing in common – they all represent fraud. The disparity of these types of fraud also illustrates some of the central problems confronting lenders as they assess fraud risk and implement interdiction and remediation strategies. Fraud is often unreported, or under-reported, and lenders may have differing definitions of what constitutes fraud and varying reporting policies. In general, the incidence of fraud appears to be rising. Lenders have been forced to maintain front-line defenses against fraud perpetrators and to strengthen back-office fraud loss mitigation competencies, due to higher levels of increasingly sophisticated frauds. Defining Fraud Industry experience and research suggest three main types of common fraudulent activity. The introductory scenarios provide an illustration of each. Identity theft (including true name fraud) is commonly known and has received considerable exposure in recent years, but is far from a new idea. This type of fraud involves usurping the name and credit credentials of a third party to gain credit under false pretenses. It may also involve the creation of fictitious entities or individuals. In either variant, the lender unlucky enough to grant credit in this circumstance is left with the daunting challenge of first determining who, in fact, has the collateral. In the case of a straw purchase, the identity of the borrower is clearly known and the borrower’s identity and credit experience are accurately represented. What is not known to the lender is who truly intended to purchase, drive and make payments on the collateral. The second scenario presented is a classic example of a straw purchase and one that many credit analysts are trained to spot, particularly when the intended vehicle seems out of character for the applicant. Straw purchase fraud can result from either dealer or customer sources. In some cases, uninformed customers may become the unwitting accomplices in a dealer’s attempt to get a deal approved by incompletely representing the true parties to the transaction. In other instances, the dealer may become the unwitting accomplice when a more streetwise perpetrator sends only the straw party into the dealership to effect the

Copyright © 2004. BenchMark Consulting International, NA, Inc. All Rights Reserved.

purchase. In either case, lenders’ policies regarding to what extent straw purchases are considered fraud vary widely. Experience with lenders also suggests that straw purchases may be viewed less seriously in different regions of the country. The final type of fraud, the material misstatement, is probably the least likely to be considered and reported as a fraud account. Like a straw purchase, this type of fraud can spring from both applicant and dealer sources, but may also be the genuine result of an innocent mistake in data entry. Common examples of material misstatements include falsifying income, falsifying educational credentials (to qualify for college graduate incentive programs) and overstating the length of time at residence or job. The impact of these actions is clear – they induce a lender to take credit risk at a price they otherwise may not have agreed to take. Overall Trends in Fraud Comprehensive fraud statistics are not commonly available on an industry-wide basis. However, it is possible to draw inferences on the overall level of fraudulent activity confronting indirect auto lenders based on publicly available data. Due to the high profile of identity theft, several sources of data are available that point to an increasing incidence of fraud. In 2003, the Federal Trade Commission (FTC) estimated the incidence of identity theft to have increased between 2002 and 2003 at a 30% rate. This change represents a slowing from an overall average annual growth rate in reported incidents of identity theft of 98% from 2000 through 2003. It is important to note that these are reported incidents of identity theft based on complaints entered into the FTC’s Identity Theft Clearinghouse database and this trend is affected by consumers’ willingness to report such incidents. A detailed FTC report in 2001 indicated that credit cards were much more likely targets of identity theft perpetrators than were vehicle loans/leases. In 2001, 26% of total identity theft victims’ information was used in an attempt to obtain new credit card accounts. This same study indicated that only 1.8% of victims’ information was used in an attempt to obtain auto loans/leases. Clearly, financial products resulting in greater liquidity, such as credit cards and personal loans, are more

attractive targets for identity theft perpetrators. Does this mean that indirect lenders have little to fear? A study of identity theft conducted on behalf of the FTC indicates that the average loss for the most severe instances of identity theft is $10,200. Given the average amount financed and anecdotal evidence suggesting that high-end vehicles are more likely targets, it is apparent that the low incidence of identity theft in indirect lending may be partially offset by higher loss severity when compared to other forms of identity theft. Jim Ray, Director of Credit Operations and Customer Services for Porsche Financial Services, states that the incidence of identity theft is “definitely on the rise,” and identity thieves clearly focus on higher-end vehicles. Another pitfall faced by lenders is victims’ willingness to report instances of identity theft fraud. The same FTC-sponsored survey reported that only 22% of total identity theft victims reported the misuse of their information to at least one credit bureau. This percentage increased to 37% for victims of new account fraud, only. Fortunately, the propensity for victims to report misuse of their personal data to credit bureaus increased as loss severity increased. However, the overall low rate of bureau reporting, particularly for small loss incidents, means that lenders cannot rely solely on credit bureau alerts to highlight potentially fraudulent applications. This is particularly true, since the small dollar value frauds that are least likely to prompt victims to contact credit bureaus could be precedents for larger targets, like vehicle loans. Interdiction: Originations Strategies Preventing fraudulent offerings from being approved is the goal of fraud detection strategies within originations functions. These efforts typically exist on various successive levels within the credit decisioning process. The first line of defense against fraudulent offerings is the use of credit bureau fraud alerts as exclusionary criteria in auto-decisioning models. As mentioned previously, these alerts are necessarily a small portion of an overall strategy, since many potentially fraudulent applications may be received without any bureau fraud alert. “You see the fraud alerts, but it’s too late,” says Mr. Ray. The next level of defense begins with the credit analyst. According to Kent Archambo, Process Leader for
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Credit and Funding at Volkswagen Credit, their perceived decline in the level of fraudulent applications may result, in large part, from, “better efforts at controlling fraud prior to approval due to more seasoned buyers.” Credit analysts are catching more potential fraud up front, thus less is escalated to senior risk management personnel. Mr. Ray stresses, “taking it down to the fundamentals,” by verifying basic elements, like home phone numbers and employment data, on suspicious deals. Improved buyer training and experience would also have the secondary advantage of freeing risk management personnel to devote more effort towards the most serious cases. Some lenders maintain proprietary fraud databases to track names and addresses associated with fraudulent applications and booked accounts. In some cases, lenders use this database in conjunction with their application processing system to automatically generate their own fraud warnings when data entered on an offering matches their fraud database. The dealer relationship is a key third element of lenders’ fraud prevention strategies. In an indirect lending environment, lenders rely on dealers to accurately identify and represent applicants. Reinforcing the long-term value of the lender/dealer relationship provides dealers with a critical incentive to vigorously screen customers and to prevent the submission of fraudulent applications. William Fields, Director of Automotive Service Centers for Volkswagen Credit cites the fact that their “dealers value the overall relationship” as a prime contributor to Volkswagen Credit’s overall fraud prevention strategy. Mr. Fields used the example of unscrupulous auto brokers as an illustration of what can happen when the dealer/customer connection is weakened. “Some brokers may not be as diligent as dealers in identifying fraud,” Mr. Fields explains. He stated there appears to be a higher prevalence of fraudulent broker deals in areas with intense sales pressure, such as the western U.S. The use of dealer-entered applications may also have a positive side effect on fraud prevention efforts. According to Mr. Archambo, the use of dealer-entered applications results in more complete information being conveyed to the credit analyst, since incomplete applications will not be passed to the application processing system. Strong dealer relations support efforts to increase the use of dealer-entered application channels.

According to Mr. Ray, “Strong dealer relationships are the key to all of this.” Porsche Financial Services sponsors dealer training on fraud prevention and actively makes dealer finance and insurance personnel aware of the potential for fraud. He indicated that some dealers have even improved their delivery procedures, an area of dealership operations that may have previously received little attention, in response to fraud occurrences. Remediation: Collections & Servicing Strategies Despite any lender’s best efforts to prevent fraudulent applications from being booked, some eventually get through. Commonly, fraud perpetrators may make several payments before defaulting as means to avoid immediate detection and to support the acquisition of additional fraudulent credit. Nevertheless, lenders rely heavily on first/early payment default reports to quickly identify fraudulent accounts. Lenders also may use internal reporting to form early warning systems. Fraud accounts are most commonly dealt with in the course of normal collections treatments, particularly as skip accounts. It is in this context that servicing personnel may receive fraud training as an element of skip tracing skill development. Unfortunately, until an account defaults, there is little action that a lender can take, unless they can demonstrate that their collateral is in jeopardy. For this reason, fraud remediation is usually within the purview of collections. Recent trends in fraudulent activity may be influencing lenders’ willingness to prosecute fraud perpetrators. Traditionally, lenders may have been reluctant to prosecute fraud cases and simply content to recover their collateral in order to avoid publicity. Mr. Archambo states that Volkswagen Credit considers prosecution “on a case by case basis.” The desire to maintain positive dealer relations may limit lenders from increasing the extent to which they pursue dealer recourse on fraudulent accounts. Many lenders will only request dealer recourse in clearly defined cases where a dealer’s actions have contributed to the fraud loss. Mr. Archambo states that Volkswagen Credit will require recourse only when dealers are “directly involved in, or aware of, the fraud” and that they will usually work with the dealer to

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recover the collateral, if possible, to help reduce the dealer’s financial exposure. Porsche Financial Services takes a collaborative approach once a fraudulent account is identified by assembling a team consisting of the assigned collector, collections management, the responsible buyer and the sales personnel assigned to the originating dealer. The goal of this team is to formulate a plan to assess the extent of the fraud and to prevent future occurrences. Mr. Ray’s experience suggests that a fraudulent activity is, “generally not a one-car deal.” Summary Returning to the three introductory examples of fraud, it is possible to relate them to actual cases of indirect lending fraud. The first example in which a small, organized fraud ring used phony business entities in a version of a true name is based on an actual lender case. The lender constructed a web of common elements between the fraudulent applications to determine the actual identity

of the perpetrators. While the lender was not able to recover their collateral, it was through strong dealer relationships that the fraud ring was brought to justice. A dealer employee recognized one of the perpetrators while working a different dealership and helped facilitate a sting operation with law enforcement authorities. Straw purchases, long a part of the indirect lending environment, were recently used in an organized fashion in southern California to defraud lenders of 207 vehicles totaling $8.5 million dollars in losses. Finally, the most seemingly innocuous type of fraud, the material misstatement, has become so common that some lenders have taken extensive measures to verify the validity of customer statements. According to Mr. Archambo, Volkswagen Credit verifies a significantly higher proportion of applicant information than it has in the past. Mr. Fields summarized the lender’s position on the verification of questionable applicant data, “If we cannot perform a direct verification, it’s likely that the deal will not be approved.”

Bart V. del Cimmuto is a consultant at BenchMark Consulting International with more than 15 years of experience in indirect auto finance. He specializes in Indirect Lending and Consumer Finance and associated business process design. Ted Brown is the Auto Finance Practice Manager at BenchMark Consulting International. He has extensive background and experience in the indirect auto finance industry, strategic planning, consolidations and corporate restructuring. BenchMark Consulting International has specialized in improving the financial services industry since 1988. The company is a management consulting firm that improves the profitability of its financial services clients through the delivery of management decision making information and change management services to realize the benefits of business process changes. BenchMark Consulting International’s expertise is in the designing, managing and measuring of operational processes. The firm has worked with 20 of the top 25 (in asset size) commercial U.S. banks, all the captive automotive finance corporations, several of the largest consumer finance corporations and many regional banks throughout the United States. Internationally, BenchMark Consulting International has worked with the five largest Canadian commercial banks, more than 20 European organizations in eight different countries, in addition to financial institutions in Latin America and Asia. BenchMark Consulting International is a wholly owned subsidiary of Fidelity Information Services, Inc., with clients in more than 50 countries and territories, provides application software, information processing management, outsourcing services and professional IT consulting to the financial services and mortgage industry. BenchMark Consulting International has dual headquarters in Atlanta, Georgia, and Munich, Germany. For more information about the company, visit the Web site at www.benchmarkinternational.com.

BenchMark Consulting International
3535 Piedmont Road, Suite 950 Atlanta, Georgia 30305 (404) 442-4100

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