TO: Chief Executive Officers of all National Banks, Department and Division Heads, and all Examining Personnel

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1 AL 96-7 Subject: Credit Card Preapprved Slicitatins TO: Chief Executive Officers f all Natinal Banks, Department and Divisin Heads, and all Examining Persnnel PURPOSE The purpse f this advisry letter is t alert natinal banks t risks assciated with preapprved slicitatins f credit cards. While sme f the infrmatin presented can als apply t credit cards issued thrugh ther means such as a cmpleted applicatin, this Advisry Letter is fcused n preapprved slicitatin prgrams where a credit card issuer uses a list f ptential custmers frm which it will make a firm ffer f credit. The Advisry Letter discusses hw prper risk assessment, cntrls, and planning can achieve the desired prtfli quality even in a perid f adverse ecnmic trends. BACKGROUND An increase in cmpetitin in the credit card business, rapid prtfli grwth rates, and the availability f diverse credit card prducts have all changed the nature f credit card lending in recent years. Althugh accunting fr nly a relatively small percentage f ttal cmmercial bank assets, credit card lans have grwn faster than any ther type f cnsumer lans ver the past 3 years. Recently there have been prnunced increases in the rates f default and delinquency fr credit card lans. Aggressive cmpetitin recently has pressured sme banks t frg custmary and effective testing f new credit card prducts and preapprved slicitatin campaigns in hpes f capturing a prduct market befre a cmpetitr. Despite the relatively small average lan size and high net interest margins in credit card lending, the default and delinquency trends are areas f cncern fr bth bankers and regulatrs. Althugh this advisry discusses risks assciated with preapprved slicitatins fr credit cards, the OCC cautins that similar risks may arise as banks use preapprved slicitatins fr ther types f cnsumer lending such as hme equity lines, small business and installment lans. The OCC has identified certain weaknesses in sme preapprved slicitatin prgrams which can impair management's ability t prmptly recgnize and respnd t existing and ptential risks in their prtflis. These weaknesses are: Lack f a cmprehensive and independent risk management functin. Failure t adequately test and analyze ptential markets fr credit card slicitatins. Adverse selectin f slicited custmers resulting in a higher than expected verall risk prfile f bked accunts.

2 Changes in underwriting criteria t increase card riginatins withut prper testing and fllw up r withut analysis f prir experience. Failure t adequately mnitr the actual perfrmance f new prducts cmpared with initial prjectins. MANAGING RISKS IN CREDIT CARD LENDING Identifying and Mnitring Risk The risk management functin, which may be lcated within the credit card area, prmtes early and accurate identificatin f existing and ptential prblems, identifies the need fr plicy revisins, and prvides management with the infrmatin it needs t respnd prmptly t changes. At a minimum, the risk management functin shuld include respnsibility fr: Perfrming prduct analyses t serve as the basis fr underwriting, marketing, and prtfli management decisins. Ensuring that marketing initiatives reflect levels f risk acceptable t management. Managing and maintaining decisin making systems which may include scring systems. Mnitring the perfrmance f the prtfli, including the perfrmance f specific prducts, marketing initiatives, analysis by riginatin (vintages) r ther cmmn factr, and ther perfrmance measures. Analyzing delinquencies and lsses in the prtfli and identifying causes f changes r trends. Ensuring cmpliance with cnsumer prtectin laws and regulatins. Reprting apprpriate risk management infrmatin t senir management and the bard f directrs. Testing New Markets Marketing is critical t the success r failure f a credit card peratin. As apprpriate, management shuld require that marketing staff: Dcument each marketing initiative as apprpriate. Track and analyze successes and failures f previus prduct initiatives t help refine current and future ffers. Use sufficient mdeling technlgy t segment and target apprpriate markets. Invlve all applicable areas in the prduct planning prcess

3 t avid subsequent prblems due t inadequate systems and staffing. Allw fr adequate time t test market a prduct and mnitr its credit quality befre the prduct is fully implemented. Reprt apprpriate market testing infrmatin t senir management and the bard f directrs. Targeting Creditwrthy Custmers When a bank decides t ffer a prduct t an identified market, it has in mind individuals that fit a certain custmer prfile. Adverse selectin ccurs when thse respnding t a prduct ffering have, n average, different credit prspects than the targeted ppulatin. This may ccur because the bank des nt fully understand the market r is using nncurrent infrmatin in its analysis. Adverse selectin may result in a prduct that is ffered at a price that des nt cver the ptential risk fr a given market as well as in greater-than-anticipated lsses in respnse t a slicitatin. Management can minimize adverse selectin by: Reviewing prduct and underwriting guidelines t ensure cnsistency with the bank's lng-term bjectives and desired custmer prfile. Setting pricing at levels that cmpensate fr risk while remaining cmpetitive in the market. Cnducting nging testing f risk-based price assumptins t determine if adverse selectin has been cntrlled fr future prduct fferings. Using the prescreened list f brrwers prmptly after receipt frm the credit bureau t help ensure that credit is extended nly t individuals meeting the specified standards. Using a deadline fr ffer acceptance. Prperly Testing Slicitatin Offers A bank shuld gather apprpriate data and devte sufficient resurces t analyze the effect f changes in underwriting criteria n its credit card prtfli. Befre lwering cutff scres t increase credit card riginatins, a bank shuld test a sample f lans and analyze any prir experience, as apprpriate, t determine whether the level f risk can be managed, apprpriately priced, and is cnsistent with the bank's verall strategic bjectives. The testing shuld: Take place ver an apprpriate perid f time befre changes t underwriting standards are fully implemented. Use apprpriate systems and analytical tls t analyze

4 results. Use perfrmance data frm recently acquired accunts fr mdeling and frecasting purpses. Mnitr warning signs f market deteriratin, such as increases in persnal bankruptcies, which may affect the accuracy f mdel assumptins. Use analysts with experience in interpreting the mdels and frecasts selected. Mnitring the Perfrmance f Accunts Bked thrugh Slicitatins Banks shuld perfrm regular analyses f new slicitatins and prducts t cmpare actual perfrmance with initial assumptins. Peridic reprts and analyses n the perfrmance f individual mailings shuld include the fllwing infrmatin: Data t measure prtfli quality f slicited accunts such as trends in delinquencies, bankruptcies, lsses, behavir scre distributins, and usage f the accunt. Infrmatin n new business by initiative, surce, and prduct. Detail n credit quality indicatrs such as credit scre distributin. Prtfli statistics that can be tracked against cmparable industry statistics. RISKS IN CREDIT CARD LENDING The preapprved slicitatin activities discussed in this advisry letter expse a bank t credit, transactin, liquidity, strategic, reputatin, and cmpliance risk. These risks are summarized belw. A mre detailed discussin f these risks and their management fr credit card prtflis can be fund in The Credit Card Lending sectin f the Cmptrller's Handbk. Credit Risk The risk t earnings r capital f an bligr's failure t meet the terms f any cntract with the bank r therwise fail t perfrm as agreed. Aggressive slicitatin prgrams may increase the bank's credit risk if the resulting credit card accunts experience higher than prjected delinquencies and lsses. Transactin Risk The risk t earnings r capital arising frm prblems with service r prduct delivery. An influx f new accunts frm a slicitatin may increase risk if a bank is unable t prcess the respnses in an accurate r timely manner. Liquidity Risk The risk t earnings r capital arising frm a bank's inability t meet its bligatins when they cme due

5 withut incurring unacceptable lsses, including the inability t manage unplanned decreases r changes in funding surces. Higher risk assets, resulting frm weaknesses in slicitatin prgrams, may be difficult t securitize r sell and thus impact a bank's liquidity. Higher than anticipated delinquencies r lsses in securitized pls may lead t market pressure n the bank t prvide additinal supprt t the pl. OCC Bulletin prvides additinal infrmatin n the risks assciated with securitizatin prgrams. Strategic Risk The risk t earnings r capital arising frm adverse business decisins r imprper implementatin f thse decisins. Failure t adequately test a new market, analyze test results, and refine subsequent slicitatin ffers may result in unsuccessful marketing effrts r accunts that d nt perfrm as anticipated. Reputatin Risk The risk t earnings r capital arising frm negative public pinin. Prly underwritten r perfrming receivables can affect a bank's reputatin as a credit card issuer and as an underwriter f credit card securitizatins. This creates a risk that future credit enhancements fr securitizing credit card receivables may be mre cstly, reduced, r may nt be available. If a bank's reputatin as an underwriter is impaired, future accessibility t financial markets may be limited r cst mre. Cmpliance Risk The risk t earnings r capital arising frm negative public pinin. Preapprved slicitatins must cmply with the FFIEC Interagency Plicy Statement n Prescreening by Financial Institutins and the Fair Credit Reprting Act (see OCC BB 91-50). The Fair Credit Reprting Act is a cnsumer prtectin law which carries civil liability fr negligent and willful nncmpliance. RISK MANAGEMENT OPTIONS Inadequate management f risks in credit card lending can lead t prtfli deteriratin and may have negative balance sheet and earnings implicatins. Apprpriate respnses t prtfli deteriratin may include: Limiting slicitatins. Tightening credit standards. Increasing the quality f analysis f ptentially creditwrthy brrwers by prviding the credit bureau with cmprehensive credit criteria t prescreen applicants. Increasing the experience f staff assigned t cnduct such analyses. Onging mnitring f the payment perfrmance f high-risk custmers in existing accunts.

6 Tracking accunts experiencing adverse trends. Strengthening cllectin effrts. A bank with a deterirating credit card prtfli may need t reassess its allwance fr lan and lease lss (ALLL) allcatins and its capital psitin. Greater inherent lss in the credit card prtfli may require additinal ALLL allcatins under GAAP. Increased verall risk caused by declining credit quality r weakening risk management practices may require the supprt f additinal capital. CONCLUSION The OCC encurages each natinal bank invlved in credit card lending t evaluate its business plan, current peratins, and risk management cntrl systems. Management shuld take apprpriate actin t limit its expsure t unwarranted risks. ORIGINATING OFFICE Questins cncerning this advisry letter shuld be addressed t the Office f Chief Natinal Bank Examiner at (202) Jimmy F. Bartn Chief Natinal Bank Examiner Date: September 26, 1996

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