Latest / Leaders in Lending / Winning the Lending Game: What Smart Credit Unions Are Doing Differently
Transcript
- 0:00Speaker 1: Credit scores and credit reports are a record of what
- 0:03Speaker 1: has happened. They are not a record of what will happen.
- 0:06Speaker 1: You may not know exactly what the rules are. You
- 0:08Speaker 1: may not know exactly what the rules will be. You
- 0:11Speaker 1: do know that you should understand how models work.
- 0:14Speaker 2: People want to know the answer right away if they
- 0:16Speaker 2: don't want to wait ten minutes. Some days it's in
- 0:18Speaker 2: some done frames just to then get declined, anything just
- 0:20Speaker 2: to get to climb.
- 0:21Speaker 3: Approval rates matter more than interest rate in today's work.
- 0:24Speaker 4: I think I would say facts.
- 0:31Speaker 3: Hi, Welcome to Leers and lending. Today. We're going to
- 0:33Speaker 3: be talking about how credit unions can manage risk through
- 0:36Speaker 3: smarter lending decisions and how that works within the regulatory
- 0:40Speaker 3: environment that credit unions have. Talking to Drew and Linn today,
- 0:45Speaker 3: managing lending risk has never been more complex we have.
- 0:49Speaker 3: If you think of the how lending regulations have evolved
- 0:54Speaker 3: through the years. You know, TILA came out in like
- 0:57Speaker 3: the seventies, and then you know we all the way
- 1:00Speaker 3: to sort of Dodd Frank in twenty ten, and it
- 1:03Speaker 3: just seems there's always more and more regulations that are
- 1:06Speaker 3: coming up for credit unis and banks to have to
- 1:10Speaker 3: deal with. So, how do we get regulators comfortable with
- 1:15Speaker 3: partnering with FinTechs and those FinTechs specifically that we leveraging
- 1:20Speaker 3: AI based underrating models thinking of the regulatory environment that
- 1:23Speaker 3: we're dealing with today.
- 1:24Speaker 1: Yeah, it's a good question, and I think it's a
- 1:28Speaker 1: shifting regulatory environment on a day to day basis. I
- 1:31Speaker 1: think all of us have certainly watched the changes with
- 1:35Speaker 1: the various financial regulators this year than now some court
- 1:40Speaker 1: challenges to the leadership and who's on the board and
- 1:42Speaker 1: who's not on the board, and what the rules are.
- 1:44Speaker 1: So I would recommend for a credit union or really
- 1:48Speaker 1: any lending institution, like just focus on the fundamentals. You
- 1:52Speaker 1: may not know exactly what the rules are, You may
- 1:54Speaker 1: not know exactly what the rules will be, but you
- 1:57Speaker 1: do know that you should understand how models work. You
- 2:02Speaker 1: should understand who owns which part.
- 2:05Speaker 4: Of the decision.
- 2:06Speaker 1: You should do your due diligence on any vendors that
- 2:09Speaker 1: you partner with in a traditional way where you're looking
- 2:12Speaker 1: at compliance risk, financial health, reputational risk, like even though
- 2:20Speaker 1: those things are may not be explicitly called out anymore,
- 2:22Speaker 1: like reputational risk as an example, that doesn't mean that
- 2:26Speaker 1: you don't want.
- 2:26Speaker 4: To do that for your business.
- 2:27Speaker 1: So think about from a core business standpoint, what do
- 2:31Speaker 1: you care about? What do you think the key areas
- 2:33Speaker 1: are that you should be able to both understand and
- 2:37Speaker 1: document and then how can you up level your organization
- 2:40Speaker 1: to really be confident in understanding and monitoring AI models?
- 2:45Speaker 1: And I think that's a very big challenge. And I
- 2:48Speaker 1: think similar to a lot of conversations we've had about
- 2:51Speaker 1: different sized organizations, Like there's choices of partnering. There are
- 2:54Speaker 1: many vendors, there are many consultants who.
- 2:57Speaker 4: Help in this space today.
- 2:58Speaker 1: So you may not be able to hire deep AI
- 3:02Speaker 1: experts internally you don't need to, but can you find
- 3:05Speaker 1: trusted partners that can help you do that evaluation and
- 3:07Speaker 1: help and opportunities for your team to become to kind
- 3:11Speaker 1: of deepen their subject matter expertise as it relates to.
- 3:14Speaker 4: AI and.
- 3:17Speaker 1: New and more innovative ways of evaluating risk and lending.
- 3:20Speaker 2: Yeah, and that's a good like having a good general
- 3:23Speaker 2: high level knowledge base of all things AI. I mean,
- 3:26Speaker 2: it's the topic at hand most often anymore, right, but
- 3:30Speaker 2: digging even deeper. So if you are partnered with some
- 3:32Speaker 2: type of institution that is driving AI and some metric.
- 3:36Speaker 2: How can you get more knowledge base into your internal
- 3:39Speaker 2: teams on this company, does X, Y, and Z we
- 3:43Speaker 2: kind of understand the full rails of it. Maybe we
- 3:45Speaker 2: don't understand all of it, but we have confidence in
- 3:48Speaker 2: going into a regulatory exam or speaking to regulators of
- 3:51Speaker 2: why we're comfortable with this approach and having that for
- 3:55Speaker 2: every single vendor that you have that leverages AI, so
- 3:58Speaker 2: you have the high level knowledge base and then you
- 4:00Speaker 2: have all the double clicks and everything else you're using
- 4:02Speaker 2: it for.
- 4:03Speaker 3: Right, So you don't have to be the expert thing.
- 4:06Speaker 3: You just have to partner with experts in some respects.
- 4:09Speaker 1: Yeah, well, I mean I think you have to have
- 4:11Speaker 1: some level of expertise. But like if we go back
- 4:13Speaker 1: to like thinking about how say phycostore example is created,
- 4:20Speaker 1: could you, as a credit union executive, tell me how
- 4:22Speaker 1: that number is calculating exactly? So I think think about
- 4:26Speaker 1: it that way, like you know, putting an oversight of
- 4:28Speaker 1: an AI lender, an AI vendor, or an AI model
- 4:32Speaker 1: into your overall model risk management framework, Like how do
- 4:35Speaker 1: you think about managing model risk?
- 4:37Speaker 4: How do you think about evaluating.
- 4:38Speaker 1: Model risk that does not mean that you need to
- 4:40Speaker 1: be able to build, build, and recreate the entire thing,
- 4:43Speaker 1: but you have to be able to articulate and understand
- 4:46Speaker 1: it and are doing enough kind of due diligence on
- 4:49Speaker 1: your partner to feel confident in their capabilities and their depth.
- 4:53Speaker 2: Yeah, and if you get the further digged in details,
- 4:55Speaker 2: you're able to create risk assessments if XYZ and happen.
- 4:58Speaker 2: If XYZ happened, we mitigate this way, and that just
- 5:02Speaker 2: gives more comfort to regulators on why you're able to
- 5:05Speaker 2: adopt those types of rights of partnerships.
- 5:08Speaker 3: So shifting gears a little bit. How do you believe
- 5:11Speaker 3: the credit unions are using data today to sort of
- 5:14Speaker 3: balance unsecured versus secured lending?
- 5:17Speaker 2: I would say from an organic perspective, if it's an
- 5:20Speaker 2: existing member base that's coming through to get unsecured. The
- 5:24Speaker 2: biggest thing from a data perspective today is the credit
- 5:27Speaker 2: unions have a large source of data for that consumer.
- 5:30Speaker 2: They have their in and outs via AH, they know
- 5:33Speaker 2: their cash flows, they understand their spending habits. Just because
- 5:37Speaker 2: DTI percent is X does not mean that they're an
- 5:39Speaker 2: actual DTI percent of X, right, So they're able to
- 5:42Speaker 2: leverage that from a decisioning basis. Then you think about
- 5:45Speaker 2: all of that data and different rails that you can
- 5:47Speaker 2: put it in. You're getting an output of pre approval
- 5:50Speaker 2: or denial at a snap of a finger. So I
- 5:53Speaker 2: think that's one real good aspect of comparing underwriting today
- 5:57Speaker 2: compared to the prior.
- 5:59Speaker 4: Yeah, I'm true.
- 6:00Speaker 1: If you have their main deposit account, their main transaction account,
- 6:04Speaker 1: you can learn a lot about a person's behaviors or
- 6:08Speaker 1: next like does it you know, are they buying it?
- 6:10Speaker 1: Did they recently get married? Did they maybe open a
- 6:12Speaker 1: joint account?
- 6:13Speaker 4: Like can you did they move? And can you you know?
- 6:16Speaker 1: Will they need potentially additional types of of lending to
- 6:21Speaker 1: support that. So I think using that, using that data
- 6:23Speaker 1: that they've had and have rich sources of, and using
- 6:26Speaker 1: it to figure out how they're lending or engaging with
- 6:28Speaker 1: those people.
- 6:29Speaker 2: And even if they're not a depository or using a
- 6:32Speaker 2: depository product, you can paint a picture from a credit
- 6:35Speaker 2: report and you don't need an underwriter to sit there
- 6:37Speaker 2: and look at the fifty different tradelight lines that were
- 6:40Speaker 2: opened over the past twenty years to paint that picture.
- 6:43Speaker 2: You can tell that that borrower has never missed a payment,
- 6:46Speaker 2: or maybe they'll miss a payment at month on book
- 6:50Speaker 2: thirty six, but things start to level back out. You
- 6:52Speaker 2: can kind of get sense of that. And what's nice
- 6:55Speaker 2: now is with the use of AI and with automated fashions,
- 6:57Speaker 2: you don't have to sit and read it. You can
- 7:00Speaker 2: get an output again going back to kind of like
- 7:02Speaker 2: the cash flows of their depository product to be able
- 7:04Speaker 2: to paint that picture again on a snap up, because.
- 7:06Speaker 3: It's just data.
- 7:07Speaker 2: It's just there.
- 7:08Speaker 3: It's just a bunch of data. And it's how you
- 7:10Speaker 3: actually ingest that data into some sort of an AI
- 7:12Speaker 3: system that will take data and turn into really live information.
- 7:16Speaker 3: That's yes, were for you. You know, it's really good at
- 7:18Speaker 3: this are the credit card companies right, absolutely, because and
- 7:22Speaker 3: we're talking on secure lending, right, so they have a
- 7:25Speaker 3: lens into purchasing behavior. They know that you booked a
- 7:29Speaker 3: flight to Columbus, Ohio, and so they would expect, well,
- 7:33Speaker 3: there should be a hotel charge in Columbus, Ohio, and
- 7:35Speaker 3: restaurant charges and so on, and so instead of now
- 7:38Speaker 3: I'm getting declined because I'm no longer and you know
- 7:42Speaker 3: close to home. I'm two thousand miles from home. Credit
- 7:44Speaker 3: card companies have sort of figured this out. I mean,
- 7:46Speaker 3: is this something that is there an opportunity here for creditings?
- 7:50Speaker 3: Many creditings don't own their credit card balances anymore, but
- 7:55Speaker 3: they do have partnerships where there should be some sort
- 7:57Speaker 3: of sharing of that data.
- 7:59Speaker 1: Sure, and at about years ago, when you, particularly if
- 8:01Speaker 1: you traveled internationally, you had to notify your credit cards.
- 8:05Speaker 4: Sometimes you still do.
- 8:06Speaker 1: You had to go in and say here's where I'm
- 8:08Speaker 1: going on these dates, or you risk your credit card
- 8:10Speaker 1: not working when you got on vacation. And now that
- 8:14Speaker 1: it happens organically because they're using the data to make
- 8:16Speaker 1: those make those assumptions.
- 8:19Speaker 4: Yeah, I do think that's interesting.
- 8:20Speaker 1: I think particularly with me, and I don't want to
- 8:22Speaker 1: don't want to segue too far into the open banking
- 8:25Speaker 1: kind of quagmire that's happening today because there's a lot
- 8:29Speaker 1: of competing conversations around it. But I think that's a
- 8:32Speaker 1: good question of like who owns the data? So they
- 8:35Speaker 1: may be partnering with a credit card vendor to extend
- 8:39Speaker 1: that product to their members, but that is still their member.
- 8:43Speaker 1: They still hold the economic risk. And so because they
- 8:45Speaker 1: hold that economic risk, what level of data do they
- 8:48Speaker 1: have access to and how can they use that, particularly
- 8:50Speaker 1: to make new offers. And I think that's I think
- 8:53Speaker 1: is a lot of this open banking. Like the legal
- 8:57Speaker 1: challenges play out too, I think we'll see more clarity
- 9:00Speaker 1: und what they can do in the future.
- 9:02Speaker 3: Do you think overall that data driven models outperform traditional linderwriting.
- 9:07Speaker 2: Yes, being biased since we come from upstart, of course
- 9:11Speaker 2: we use data driven models, but we're able to see
- 9:13Speaker 2: and it's not just upstarted across the board is you
- 9:17Speaker 2: have borrowers that under traditional underwriting guidelines probably wouldn't qualify
- 9:22Speaker 2: for a credit union type of credit, right, whether that
- 9:24Speaker 2: be a secured versus an unsecured type of asset. Whereas
- 9:28Speaker 2: these types of models are able to separate risk much
- 9:31Speaker 2: better than an underwriter sitting in front of a computer
- 9:34Speaker 2: or some automated prequal type of logic that, Okay, maybe
- 9:38Speaker 2: this six forty FICO borrower we would decline, but they're
- 9:42Speaker 2: really transacting more of like a prime type of borrower.
- 9:44Speaker 2: But they're too new into the system take a chance
- 9:47Speaker 2: on them, right, So I would be very biased in
- 9:50Speaker 2: saying that, yes, they're better separators of risk.
- 9:52Speaker 1: Yeah, And you think about and We've talked about this
- 9:54Speaker 1: a lot at at our company. Of course, where credit
- 9:58Speaker 1: scores and credit report sports are a record of what
- 10:01Speaker 1: has happened, they are not a record.
- 10:03Speaker 4: Of what will happen.
- 10:05Speaker 1: And while you know, we'll put the disclaimer like historical
- 10:08Speaker 1: results are in an.
- 10:10Speaker 4: Indicator of a future, there certainly.
- 10:13Speaker 1: Is that idea that that you know, if you've behaved
- 10:16Speaker 1: a certain way, particularly if you behave really risky you
- 10:19Speaker 1: could expect risky behavior. But like you're to the point
- 10:22Speaker 1: you used, what if it's a person who is, you know,
- 10:25Speaker 1: a new citizen in the US or a recent college
- 10:29Speaker 1: student who maybe didn't have the benefit of their parents
- 10:32Speaker 1: helping them build that credit profile and that credit score
- 10:34Speaker 1: growing up, but they have a a good job and
- 10:38Speaker 1: they're making money, and they are are most likely going
- 10:42Speaker 1: to pay in the future. How do you use that
- 10:44Speaker 1: data to lend to those borrowers where they may in
- 10:48Speaker 1: traditional kind of rate rate based models may may not
- 10:52Speaker 1: be lent to.
- 10:53Speaker 2: Another example of that, too, is going back to my
- 10:55Speaker 2: previous kind of comment, is the credit report has this
- 10:59Speaker 2: this whole slew of everything that this individual has transacted on.
- 11:03Speaker 2: Maybe there was a life changing event that took them
- 11:05Speaker 2: into that six point forty. But they've always been a
- 11:07Speaker 2: super prime type of consumer. But something happened along along
- 11:11Speaker 2: the way, and to your point, forward thinking, this borrower
- 11:14Speaker 2: is probably going to transact that same way. But death, divorce,
- 11:18Speaker 2: there's a bunch of different things that could bring you
- 11:20Speaker 2: into a lower fight Coban, Yeah.
- 11:22Speaker 1: And I think that trending data of like which direction
- 11:25Speaker 1: are you trending?
- 11:26Speaker 4: That can definitely be seen in the.
- 11:28Speaker 1: Credit report data. Are your balances increasing, are they decreasing?
- 11:32Speaker 1: Are the number of tradelines you have increasing decreasing? Is
- 11:35Speaker 1: your mix improving of the types of tradelines? I think
- 11:38Speaker 1: all of those things, not just like the snapshot of
- 11:41Speaker 1: what your credit report looks like today, but what does
- 11:44Speaker 1: it look like today compared to maybe two years ago.
- 11:46Speaker 1: You know, maybe you lost your job and during COVID
- 11:49Speaker 1: or you you know, had a period of time you
- 11:51Speaker 1: were underemployed. Does that mean you won't pay your bills
- 11:54Speaker 1: next year? I think that's a very different.
- 11:56Speaker 2: And another benefit of that is a standard underwriting models
- 12:01Speaker 2: they cannot train underwriter sees what they're seeing, whereas models
- 12:06Speaker 2: that are leveraging decisioning processes are able to train on
- 12:10Speaker 2: subsets of data over and over and over again based
- 12:14Speaker 2: on this credit report kind of mimics that credit report
- 12:16Speaker 2: or this cash flow mix of that cash flow, So
- 12:18Speaker 2: the output of risk and the output of approval odds
- 12:21Speaker 2: is going to be much better. Yeah.
- 12:22Speaker 3: I'm experienced enough in my career that I was making
- 12:25Speaker 3: lending decisions as a lending officer. Now it was assisted
- 12:28Speaker 3: by what was the information that was in our system
- 12:31Speaker 3: and assisted by credit report, but inherently I probably had
- 12:34Speaker 3: some bias as I was making decisions, right, And if
- 12:37Speaker 3: you think of an AI underwriting model, it's intentionally supposed
- 12:42Speaker 3: to reduce some of that bias programmatically within the algorithms, correct.
- 12:48Speaker 1: Yeah, I mean you would you assuming that you're testing
- 12:51Speaker 1: for that bias. And I think that's an important thing.
- 12:53Speaker 1: And you know, we talked a little bit earlier about
- 12:55Speaker 1: getting comfortable with ai A lending models and fareness is
- 13:00Speaker 1: a key component, and that's those are great questions to
- 13:04Speaker 1: ask your partner, your vendor. How are they testing for it?
- 13:08Speaker 1: How are they validating that? Is there any independent testing
- 13:12Speaker 1: of of fair lending within their model? You know, what
- 13:17Speaker 1: sort of demographic data do they have access to?
- 13:19Speaker 4: If so?
- 13:20Speaker 1: And how are they using it, and then as they're
- 13:22Speaker 1: making changes to that model, they're adding in new data,
- 13:24Speaker 1: new data sources. How are what does their model change
- 13:27Speaker 1: management process look like? Their fair lending testing component look like?
- 13:32Speaker 1: To get comfortable that they are choosing.
- 13:35Speaker 4: A model that you know, are there least.
- 13:38Speaker 1: Discriminatory alternatives that they could pursue that have the same output?
- 13:41Speaker 1: And I think knowing enough to ask those sorts of
- 13:44Speaker 1: questions are are the key parts even if you can't
- 13:46Speaker 1: kind of rebuild the model yourself from.
- 13:48Speaker 2: Scratch, and in most oftentimes it's more approval odds with
- 13:53Speaker 2: less bias.
- 13:54Speaker 3: Great. How do you think credit unions can prepare for
- 13:57Speaker 3: their regulatory examination and all make the specific to those
- 14:01Speaker 3: that are maybe partnering with FinTechs who may be using
- 14:05Speaker 3: AI or machine learning for the render any models.
- 14:09Speaker 4: Yeah, I can start night. I honestly would be interested.
- 14:13Speaker 1: Drew in your perspective too as a farmer credit union
- 14:16Speaker 1: CEO and very that you know the way you thought
- 14:19Speaker 1: about this as a CEO.
- 14:21Speaker 4: Of a credit union. But I think ultimately is have
- 14:25Speaker 4: a plan.
- 14:25Speaker 1: Right, like know how you want to do diligence, how
- 14:28Speaker 1: you want to think about what your use cases like,
- 14:30Speaker 1: what what do I want to solve? What am I
- 14:32Speaker 1: looking for this vendor to help me do? Is it
- 14:37Speaker 1: an end to end of all one product? Is it
- 14:39Speaker 1: multiple products? Is it a very limited scope? And uh?
- 14:44Speaker 1: And doing an RFP and asking those questions and making
- 14:47Speaker 1: sure that you're documenting that that diligence process and doing
- 14:50Speaker 1: a real risk based assessment of the value, not just
- 14:53Speaker 1: get Really it's really easy to get excited about AI
- 14:56Speaker 1: and it's shiny, and you know, there's so many things
- 14:58Speaker 1: that you can you can solve, and everyone's getting a
- 15:00Speaker 1: mandate top down, but doing your diligence, building that partnership,
- 15:06Speaker 1: finding a partner that you really can build a business
- 15:09Speaker 1: relationship with, not just a transactional vendor relationship. I think
- 15:13Speaker 1: that to me is the first thing is document that.
- 15:15Speaker 1: So when your field examiner comes in, they say, we
- 15:19Speaker 1: know you have a new partnership with X, y Z.
- 15:21Speaker 1: Tell us how it's going, and you can lay out
- 15:25Speaker 1: your work. You can kind of show your work. These
- 15:27Speaker 1: are the things that we did to get comfortable working
- 15:29Speaker 1: with this vendor and have a plan for oversight.
- 15:32Speaker 4: What does that look like annually? What does that look
- 15:34Speaker 4: like periodically? And it should be risk based, how much.
- 15:37Speaker 1: You know, if you're doing a very small bit of business,
- 15:40Speaker 1: it's you know, a couple percent of your balance sheet
- 15:42Speaker 1: with a particular vendor, you don't need to build a
- 15:45Speaker 1: whole organization around it. If it's something that's going to
- 15:47Speaker 1: be twenty five percent, you need a much more robust oversight.
- 15:51Speaker 1: So I think your oversight should be scale with both
- 15:56Speaker 1: the size of the of the fintech vendor you're working with,
- 15:58Speaker 1: but also with the size of your organization and the
- 16:01Speaker 1: importance of that product placement within your organization.
- 16:06Speaker 2: I'm just going to be transparent. So a majority of
- 16:08Speaker 2: the credit unions a little over ninety percent or Campbe's
- 16:11Speaker 2: one or Campbell's two rating, that's that's a great rating.
- 16:13Speaker 2: If you're three to four are about to become insolvent,
- 16:16Speaker 2: you probably have other things to be talking to your
- 16:18Speaker 2: field executions exactly. You shouldn't even be having those conversations.
- 16:23Speaker 2: And everything that you've built from a diligence perspective preparing
- 16:26Speaker 2: for an exam is already doing very well, or else
- 16:29Speaker 2: you wouldn't be a Campbell's one or a Cameos two.
- 16:32Speaker 2: Your lending strategy is built, your deposit strategy is built.
- 16:35Speaker 2: Everything on the back end that you're monitoring all of
- 16:37Speaker 2: that with to make sure that it is in line
- 16:39Speaker 2: with regulatory guidance is probably there in some aspect, and
- 16:42Speaker 2: you probably have the risk assessments in place to be
- 16:45Speaker 2: able to rinse and repeat here right now. If you're
- 16:48Speaker 2: starting to bring in AI types of partnerships or usage
- 16:51Speaker 2: of AI, whether it be in your branch or in
- 16:53Speaker 2: your call centers or things of that nature, you need
- 16:56Speaker 2: to do the build of what you've already built for
- 16:59Speaker 2: lending and for does it build risk assessments, become knowledgeable
- 17:02Speaker 2: that I was talking about earlier, and or be very
- 17:05Speaker 2: confident in talking about it and why it's beneficial for
- 17:09Speaker 2: your institution, because if you know, I mean, we've all
- 17:12Speaker 2: gone through exams with maybe not the NCUA, but if
- 17:17Speaker 2: you don't know what you're talking about, there's a red
- 17:18Speaker 2: flag there and they're going to double click and double
- 17:21Speaker 2: click and double click. And since you are already so
- 17:23Speaker 2: ingrained on your your lending and your deposit strategy and
- 17:26Speaker 2: all the risk that is associated with that, they're going
- 17:28Speaker 2: to start double clicking into this use of AI. And
- 17:30Speaker 2: if you're not confident, not confident in your delivery of
- 17:33Speaker 2: your knowledge base, then it's going to create issue. So
- 17:35Speaker 2: you have to build the knowledge base, build procedures, policies,
- 17:40Speaker 2: and then monitor on the back end and then recurring
- 17:42Speaker 2: what reoccurring basis.
- 17:44Speaker 3: Confidence in your governance is a very underrated character.
- 17:48Speaker 4: Yes, yep.
- 17:49Speaker 1: And knowing that it's your governance, I think that's an
- 17:51Speaker 1: important thing. Someone else that you as the credit union
- 17:53Speaker 1: to ultimately have that responsibility. You are the frontline to
- 17:56Speaker 1: your regulators. You're the front line to your examiner and
- 17:59Speaker 1: talk to them in a else if you are thinking
- 18:01Speaker 1: about a partnership in a certain area, they're there to
- 18:04Speaker 1: they will work with you, so you have you know,
- 18:06Speaker 1: I know there's been a lot of retirements and turnovers,
- 18:09Speaker 1: so I think that those like maybe kind of extended
- 18:12Speaker 1: relationships with those specific examiners have been broken in a
- 18:15Speaker 1: lot of cases. But you definitely reach out to them
- 18:19Speaker 1: in advance of a partnership and talk to them about
- 18:23Speaker 1: what you're doing. And that definitely a surprise when they
- 18:26Speaker 1: come in the door is not a good idea.
- 18:28Speaker 2: One hundred percent agree, And don't be afraid to challenge
- 18:31Speaker 2: your examiner with within respect, with right reason, within reason,
- 18:35Speaker 2: but just because the examiner thinks it should be this
- 18:38Speaker 2: way doesn't mean that it has to be that way.
- 18:40Speaker 2: If you're able to give them a good reasoning as
- 18:43Speaker 2: to why you think that this is the way that
- 18:45Speaker 2: we're doing it is sufficient enough, maybe that will create
- 18:49Speaker 2: an aha moment and then other exams. Okay, I remember
- 18:52Speaker 2: talking to x y Z from Credit Union one, two three.
- 18:55Speaker 2: They had a really good perspective. I'm going to go
- 18:57Speaker 2: with that type of approach next time I'm in the
- 18:59Speaker 2: field right and be.
- 19:00Speaker 3: Open to the regulator or the examiners opinion on games right.
- 19:04Speaker 3: You may not agree with it, but at least be
- 19:06Speaker 3: open and try and see it from their perspective. I've
- 19:08Speaker 3: been on the other side with institutions where we just
- 19:11Speaker 3: dug our heels in and said no, no, no, the way
- 19:13Speaker 3: you're saying it is, that's not the way. This is
- 19:14Speaker 3: the way that never turns out very well. It certainly
- 19:17Speaker 3: didn't for us, and as it was a good learning.
- 19:20Speaker 2: Moment that could put you into Camels three or four.
- 19:22Speaker 3: So then well, you know, hopefully not. But yes, I mean,
- 19:26Speaker 3: I guess that's that's under the management waiting. Yes, absolutely, yeah,
- 19:30Speaker 3: for sure.
- 19:31Speaker 2: Some additional drs that you don't want.
- 19:33Speaker 3: If today's episode gave you some new ideas around lending
- 19:36Speaker 3: and risk, please take a second to rate us on
- 19:38Speaker 3: Spotify or Apple or wherever you get your podcasts. It
- 19:41Speaker 3: will help more creditings find our show. Okay, it's time
- 19:43Speaker 3: for fact and fiction. We're going to break down your
- 19:45Speaker 3: opinions about managing risk and deciding whether we're on board
- 19:48Speaker 3: or not. You ready ready? Being conservative on credit risk
- 19:51Speaker 3: is costing credit unions market share factor fiction.
- 19:54Speaker 2: Fact with all capitals. You think about balance sheets with
- 19:59Speaker 2: with credit union that have tightened and maybe they started
- 20:02Speaker 2: their tightening journey post the GFC. Maybe some started tightening
- 20:08Speaker 2: during COVID and kind of have kept that trend right,
- 20:11Speaker 2: It just depends on where in the timeframe they decided
- 20:14Speaker 2: to tighten, and as a result they are now not
- 20:16Speaker 2: seeing much of a return and their margins are very
- 20:19Speaker 2: very thin. So you think about large and even mid
- 20:22Speaker 2: sized credit unions that took on this slew of lending
- 20:25Speaker 2: during COVID at very reduced rates, they're starting to see
- 20:29Speaker 2: some even pressures on margin as it relates to kind
- 20:32Speaker 2: of the inverse now where they're paying high on apy
- 20:36Speaker 2: for certificates of deposit and savings accounts. That their cost
- 20:40Speaker 2: of funds has arisen, and their cost of funds is
- 20:42Speaker 2: still super high, and those margins because they've tightened their
- 20:45Speaker 2: credits so much, it doesn't allow for them to get
- 20:48Speaker 2: those aprs that they would have originated for maybe a
- 20:50Speaker 2: six hundred type of Fyco borrow or so on and
- 20:54Speaker 2: so forth. And then even the risk segment, maybe they're
- 20:57Speaker 2: more focused on collateralized types of loans now compared to
- 21:01Speaker 2: either card or unsecured or even if they're seeing a
- 21:04Speaker 2: growth in unsecured lending, terms and tightening probably are a
- 21:08Speaker 2: little bit different than they were five ten years.
- 21:10Speaker 4: Yeah, do you think? And I would kind of add,
- 21:12Speaker 4: I think the.
- 21:14Speaker 1: Risk aversion is good to a point, but it's the
- 21:18Speaker 1: risk reward trade off, Like you know, you could you
- 21:22Speaker 1: take a little bit more risk even and even accept
- 21:24Speaker 1: slightly higher losses versus like zero losses, but make a
- 21:28Speaker 1: lot more money at the end of the day and
- 21:30Speaker 1: grow your member base and figuring out that balance is key.
- 21:34Speaker 2: Yeah, and you have to be able to if you
- 21:36Speaker 2: diversify in that sense and take on I don't know,
- 21:39Speaker 2: fifty basis points of more risk across any type of
- 21:43Speaker 2: basset that's going to have an increase to my margin
- 21:46Speaker 2: of why and if it makes sense when you're you know,
- 21:48Speaker 2: validating the CECIL methodology calculation and correlation to interest income,
- 21:52Speaker 2: then it might make sense to be more diverse and
- 21:55Speaker 2: more risk type of loans and get your margins or
- 21:57Speaker 2: your spreads back to something that's more desirable good.
- 22:01Speaker 3: Uh. Data driven lending is only as strong as the
- 22:04Speaker 3: models behind it.
- 22:05Speaker 4: Factor fiction definitely, definitely fact. I think anybody, you know,
- 22:11Speaker 4: it's kind of like that.
- 22:12Speaker 1: What's the uh lies lies and statistics or it's betraying
- 22:17Speaker 1: the quote damn lies and statistics. But but I think
- 22:22Speaker 1: anybody can take data and can misinterpret it, misuse it, uh,
- 22:27Speaker 1: well in in with good intention, right, It doesn't mean
- 22:30Speaker 1: that they're doing it with some some bad intention. But
- 22:33Speaker 1: I think how you use that data and what data
- 22:35Speaker 1: you need? Like it doesn't you don't have to use
- 22:37Speaker 1: every data point available. What are the things that are
- 22:40Speaker 1: actually meaningful to use in making and how do you
- 22:43Speaker 1: use those in making that decision?
- 22:45Speaker 4: Uh?
- 22:45Speaker 1: And so I think from that perspective, like you really
- 22:48Speaker 1: need a very strong, a very strong model that can
- 22:52Speaker 1: use that data in a powerful way because there's also
- 22:54Speaker 1: a cost to compute, so it does cost money to
- 22:56Speaker 1: run models, and it costs money to to hire high
- 23:00Speaker 1: quality vendors, and I think those things are are worth it.
- 23:03Speaker 1: But I think that the model itself is the key importance.
- 23:09Speaker 1: And even a very strong model can make very great
- 23:12Speaker 1: predictive results with smaller sets of data than a weaker
- 23:16Speaker 1: model could do with even larger amounts of data.
- 23:18Speaker 3: Good point.
- 23:19Speaker 2: I agree. Fact, going back to a prior point, you know,
- 23:22Speaker 2: models are trainable. People are trainable, but not with that
- 23:26Speaker 2: many data points. And as things shift, just because we
- 23:30Speaker 2: have fifteen hundred variables that gives you an output doesn't
- 23:33Speaker 2: mean that six aren't important right now, and then you
- 23:35Speaker 2: know six others will be important two years from now
- 23:37Speaker 2: as things evolve. So one hundred percent fact.
- 23:39Speaker 3: And that's what training does. Yeah, kind of identifies. Maybe
- 23:42Speaker 3: some variables drop off and some get better.
- 23:45Speaker 1: Yeah.
- 23:45Speaker 3: I mean the more time you have and the more
- 23:48Speaker 3: data you have, I think the more precise you can
- 23:50Speaker 3: get in terms of a predictability of your model. Ye,
- 23:53Speaker 3: approval rates matter more than interest rate in today's market.
- 23:56Speaker 1: I think I would say fact if we said approval
- 24:01Speaker 1: experience versus maybe rates like not everyone, so I would
- 24:06Speaker 1: say not everyone has to have a kind of an
- 24:09Speaker 1: instant approval, but a quicker decision and a quicker time
- 24:13Speaker 1: to kind of the end result. Whether Hey, tell me
- 24:17Speaker 1: if I'm getting a loan or not, and if I'm
- 24:19Speaker 1: getting alan, I want to get it quickly and with
- 24:21Speaker 1: as little friction as possible. If you're not going to
- 24:24Speaker 1: lend me money or for whether it's a personal loan,
- 24:27Speaker 1: a helock, a car, tell me that right up front
- 24:31Speaker 1: and tell me what I think. Yeah, I don't want
- 24:34Speaker 1: to jump through hoops to get.
- 24:35Speaker 4: To that final decision.
- 24:36Speaker 1: So I think you know that's reflected in the approval rates,
- 24:39Speaker 1: But I would almost say like instant decision rates matter
- 24:42Speaker 1: more than the rate itself. That people will do things
- 24:46Speaker 1: like consumer behavior. It's one of the big increases in
- 24:49Speaker 1: drivers Originally in personal loans was things that folks may
- 24:53Speaker 1: go to a helock or a refi for to do
- 24:57Speaker 1: things like replace the roof, or replace a data bathroom
- 25:01Speaker 1: or replace their HVAC.
- 25:03Speaker 4: You can take a personal loan. Is the rate higher? Yes?
- 25:06Speaker 1: Is the speed at which you get access to that
- 25:08Speaker 1: money also much lower with a lot less hoops to
- 25:11Speaker 1: jump through.
- 25:11Speaker 2: Absolutely, I would say fact as well to your point,
- 25:15Speaker 2: people want to know the answer right away. They don't
- 25:17Speaker 2: want to wait ten minutes, ten days, it's in some timeframes.
- 25:20Speaker 4: Just to then get declined anywhere, just to get declimbed.
- 25:22Speaker 2: And then, I mean, rate does matter to a sense
- 25:25Speaker 2: to most consumers, right, But again we've talked about this
- 25:28Speaker 2: in prior podcasts. They care more about their payment and
- 25:31Speaker 2: they care about they need the money right right away.
- 25:33Speaker 2: So I would say approval odds is more important than rate,
- 25:36Speaker 2: but make sure you're pricing right. If you're pricing correctly,
- 25:38Speaker 2: then those approval ods are going to be even greater. Right.
- 25:41Speaker 3: Thanks for watching this episode of Leaders in Lending. We'll
- 25:44Speaker 3: see you next time.