Managing Credit Risk Through Embedded Intelligence in On-line Transaction

| March 29, 2017

Managing Credit Risk
Through Embedded Intelligence in On-line Transaction Processing:
First Union National Bank, Charlotte, NC1
First Union National Bank (FUNB) is the nation’s sixth largest banking company with $9.3
billion in total stockholders’ equity and $17.2 billion in market capitalization. FUNB offers a
diverse array of products such as 401(k) plans, checking and savings accounts tailored to
customer needs, investment banking, certificates of deposit, mutual funds, credit cards and other
loan products. FUNB has presence in 12 eastern states and Washington, DC It recently acquired
of First Fidelity Bancorporation on January 1, 1996, giving it a customer base of about 12
million customers from Connecticut to Florida.
On June 30, 1996, FUNB had assets of $139.9 billion. The bank’s network has 1,981 offices -the nation’s largest branch banking system. It also has the nation’s fifth largest automated teller
machine network. In addition, First Union is pioneering one of the first direct banks on the
Over the years, FUNB has been working towards developing a leading position in several
markets, including deposits and credit cards, on the assumption that scale is an essential element
of keeping unit costs low. First Union has the leading deposit share in its home state of North
Carolina; it ranks second in Florida, New Jersey and the Washington, DC, and third in
Connecticut. The company serves eight of the 10 richest counties in the US.
Since 1993 FUNB has nearly tripled the size of its credit card portfolio. This growth was
achieved through targeted, national market solicitations aimed at providing geographic diversity
and by trying to attract high quality, revolving credit customers. It was the 14th largest issuer of
credit cards in the nation as of June 30, 1996. FUNB also offers on-line credit card applications
over the Internet.
This case focuses on the credit card business of FUNB.
FUNB’s problem was simple: to minimize the dollar loss incurred as a result of credit card fraud.
Why is this a difficult problem?
Traditionally, credit card issuers have been concerned about losses due to defaults — borrowers
not paying back their charges, but in the last few years, a new kind of loss has also arisen.
Financial fraud is not a petty theft situation but a high stakes business that “employs” a

This case was prepared by Professor Vasant Dhar for purposes of class discussion and not to illustrate appropriate
or inappropriate handling of an administrative situation.

significant number of individuals. It is organized crime that exploits several aspects of electronic

a side effect of the “electronization” of commerce is that more and more information about
individuals is publicly available without people even being aware of this
individuals want as little red tape as possible; they don’t want to be questioned about the
legitimacy of every transaction
control systems are never perfect. There are invariably “holes” in most systems that criminals
try and find become they are plugged

Because of the large amounts of money involved, organized crime gets into the game. And this
means sophisticated methods of theft. Criminals are constantly looking for innovative ways to
exploit availability of credit.
To prevent losses, issuers engage in credit screening. Screening occurs at a number of levels.
Issuers routinely have a “pre booking” process involving the screening of applicants,
determining which ones are “safe” enough for credit cards to be issued.
Screening at the transaction level is a lot more difficult. Transaction level fraud occurs when a
legitimate credit card or account is illegally used or taken over by a criminal. It must be detected
in real time. This is the problem FUNB decided to focus on.
Why is detecting a fraudulent credit transaction a difficult problem?
First, credit is an easy medium for criminals to exploit because of the difficulty of discriminating
between a legitimate and a fraudulent transaction. Criminals are capable of getting a lot of
information about individuals such as social security numbers and other key pieces of data
without much difficulty. When they take over a credit card or an account, this information
provides them easy access to high priced goods and services such as jewelry, airline tickets, etc.
Once criminals know that they have an exploitable credit card, they first “test” it by engaging in
seemingly “normal” activity, and then hit the card hard and fast, extracting as much of its
available credit line as quickly as possible. Often, this behavior is not much different from that of
the legitimate holder of the card. In other words, detecting fraud is a subtle and complex: there
are no obvious patterns that stand out as pathological behavior.
Second, banks must minimize the risk of denying legitimate transactions, also referred to as the
“type II error” in statistics. Embarrassment and inconvenience are a sure way of losing
customers: you have to be virtually certain before intervening. This increases the likelihood of
approving bad transactions, or the “type I error”.
Third, customers are not always available to verify the legitimacy of a transaction even when the
bank deems it important enough to do so. People are often not available by phone, sometimes for
days. Besides, criminals may also pose as the customer, especially when they are armed with
sensitive customer information. Criminals have been known to completely “take over” a bank

account, sometimes changing the billing address to their own without the real customer being
aware of this situation!
Until a few years ago, banks were largely unable to combat the increasing fraud. The process of
trying to unearth fraud was woefully inadequate. Mary Ann Miller, manager of fraud prevention
in the Customer Direct Access Division at First Union described the problem as follows:
“In 1991, a lot of your information came from Issuers Clearinghouse Reports.
These had information such as social security numbers, phone numbers and
addresses of known problematic cards in the last 30, 60, and 90 days. This
information is useful for screening out transactions coming from cards that are
known to be bad — it is a useful pre-booking fraud tool. However, the information
is not relevant in finding fraud that is under way now. To deal with transaction
level fraud, we used to specify some crude “filters” that consisted of broad
parameters such as “cash transactions over $1000”, which an on-line system
would use to flag transactions. But these kept our printers really busy. We would
get reams of output. These reams would be taken over to analysts who would
spend hours or days analyzing them, trying to judge which ones might be
fraudulent. In the early 90s, days could go by without finding a fraudulent
transaction. As a result, we devoted more analyst effort, but it was just that: more
effort, a more labor intensive process that did not scale well. We needed a system
to do this, a system whose costs could be amortized over a large number of
Figure 1 shows a general schematic of the situation. The problem was there was no good model
of a fraudulent profile. Without such a model, the bank could at best put transactions through
crude filters, which represented their best guesses the kinds of things you might see in risky
The trouble was that these filters were much too loose: while many fraudulent transactions might
correspond to them, there were a lot more legitimate ones that also fit them. Without any way to
discriminate, analysts were deluged with a lot of irrelevant data. They were required to exercise
too much judgment, and their performance depended largely on their experience, expertise,
motivation, and luck. The bottom line was that analysts simply could not handle the volume of
output that flowed into them. The odds of catching fraudulent transactions were extremely low,
reflected by the fact that they sometimes went for days without catching a single bad transaction.
Clearly, this was not a scaleable approach to the problem.

(dozens per minute)

Crude Filters
(dozens per minute)

(dozens per minute)

Analyst Review
(dozen per hour
i.e. severe overloading)

Authorization Code
(dozens per minute)
Figure 1

In a sense, the situation called for developing better filters. But not only did they have to be
better, they also had to be dynamic, since the profile of bad transactions can keep changing: the
bank might detect a pattern, but criminals realize that their current approach no longer works,
and alter their strategy. By definition, the bank is always playing catch up. They could not take
the approach of developing “the correct” filters. Rather, the filters needed to be flexible enough
to adapt to new kinds of fraudulent activity, while “not forgetting” the past. In a sense, they had
to be capable of evolving in tandem with fraudulent behavior!
By the same token, the problem required that a solution scale well across different customers: the
bank’s customer base would keep changing, requiring that the system scale to handle different
types and larger numbers of customers. For example, if FUNB decided to develop a system for
handling each “profile” of customer (i.e. “urban professional”), they would need to be able to
extend the system easily to handle new profiles.
While a system had to be flexible enough to handle the evolving subtleties of criminal behavior,
FUNB managers felt that their approval process should also be able to express and test certain
“profiles” that they might hypothesize as being potentially problematic and hence worth
checking out statistically.
For example, if experts felt that things like “three month payment history trend” or “number of
address changes in the last six months” might indicate something about consumer behavior (such
as propensity to default), the system should be able to track this information and allow an analyst
to query the existing database with such a filter. This would require a system to compute and
store such statistics when directed by an analyst.
FUNB also realized that it would never be able to eliminate fraud completely either in principle
or practically. The only way to do this would be to call customers to approve each transaction.
Customers would not tolerate this. Practically speaking, it was important to determine when a
transaction was deemed sever enough to get approval from the customer. The goal, therefore,
was not have the most accurate system, but one that would keep fraud to “reasonable limits”.
Furthermore, it was important to limit the calls to the customer. Figure 2 shows the “desired”
process envisioned by FUNB as the first step. The idea was that each transaction would be
scored to reflect the probability of it being a bad transaction. The idea was that each transaction
would be scored to reflect the probability of it being a bad transaction. It would then be passed
on to a “Case Management System” that would decide whether to put it into a “queue” for

further analysis by an analyst. The outcome of this analysis would in turn affect the score
assigned to the next transaction.

(dozens per minute)

Scored transaction
(dozens per minute)

Case Management
System queues
(dozens per minute)

Case analysis for
transactions exceeding
threshold score
(a few per hour)

(dozens per minute)
Figure 2

Finally, FUNB also realized that their data would always contain a certain number of errors.
Some of these would be in the demographic data. More importantly, perhaps, there would always
be some “bad” transactions that would have been classified as good, i.e. not detected as bad.
Some of these might never be rectified.
1. What type of decision problem (classification, estimation, prediction, clustering,
association, etc.) was the bank facing? Justify your answer.
2. What type of model would you consider to be most appropriate for that problem? Justify
your answer.
3. Who would be the intended user for the model that you would propose to the bank? How
would the model be used?
4. Explain why the key drawbacks/limitations of the type of model that you chose in
Question 2 are not significant factors in this context.

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