The Top 6 Concerns about
Risk Based Lending...
1.
"We prefer to keep our loan program
simple"
2.
"We're concerned about our members
reactions"
3.
"We have a limited lending
staff"
4.
"We're concerned about
discrimination”
5.
"We have concerns about regulatory
compliance"
6.
"Risk based lending stands in
opposition to the credit union philosophy—since
it charges a higher rate to those who are least
able to afford it.
1.
"We prefer to keep our loan program
simple"
Risk based lending can be as difficult or as
easy as you make it. If you start from
scratch—risk based lending can be very
difficult—as well as costly, time consuming, and
confusing.
This lending package is the result of extensive
research, development, and testing. The
foundation is in place and the basic parameters
are established. You can either start
immediately (using my suggested start-up
parameters), or easily customize the program for
your own membership.
As far as “simplicity” is concerned—the very
heart of this program is that it is a complete,
tested, and simple solution.
2.
"We're concerned about our members
reactions"
When our credit union adopted this program, we
felt there may be some initial member
resistance. Instead, we found immediate support
from our members as they quickly recognized our
increased ability to level the borrowers playing
field for the entire membership.
-
Low–risk borrowers returned
to the credit union for their borrowing
needs -- as they now received the lower
interest rate that they had earned and
deserved;
-
Average-risk member still
received the same competitive rates—but with
improved and faster service. Plus, they now
had the option to qualify for even lower
rates in the future.
-
Higher-risk members had a
much better chance of loan approval at the
credit union—as risk based lending allowed
us to offset higher risk levels with rates
that were still significantly below finance
companies.
3.
"We have a limited lending
staff"
Then you definitely need this
program. The guidelines are already established
and standardized -- thereby reducing the
pressure on your loan officers.
Your loan officers will process more loans -- in
less time -- with greater consistency and
accuracy. Plus, you will have the ability to
better monitor and control your loan default
risk factors.
4.
"We're concerned about
discrimination”
Discrimination, in any form, is wrong. But,
here’s some food for thought…
Which type of
lending program leaves you open to potential
abuse and/or charges of discrimination?
-
A program that relies on the
subjective decisions from
individual loan officers. Loan officers
with different personalities, training,
and/or hidden bias’. Or,
-
A program with clearly
defined parameters and tiers.
One that uses a nationally based scoring
system that was developed by a professional
credit evaluation organization. A program
that allows exception approvals within
clearly established guidelines.
Also consider
which system is actually discriminatory?
-
A single-rate program that,
by its very nature, can only serve the needs
of your “average member”, or
-
A tiered-rate program that
offers the flexibility and options that
allow you to “level the playing field” and
better meet the needs of your entire
membership?
5.
"We have concerns about regulatory
compliance"
Regulations are usually enacted
to either: protect the credit union from acts
that lead to insolvency; or, to protect its
members from acts of discrimination (intentional
or overt) due to race, gender, age, etc.
In regards to solvency: this program provides
the tools that will help you better monitor and
manage your loan portfolio. Since loans make up
the largest portion of your asset base -- any
measures that reduce loan default risk will have
a positive impact on over-all solvency.
Regarding discrimination—although risk based
lending charges different members—different
rates, it is not discriminatory since all
members are required to meet the same
predefined, standardized credit underwriting
requirements – which are within the reach of
each and every one of your credit union members.
Risk scores ignore all discriminating factors
and focuses on how the applicant has handled
past credit.
In contrast, traditional single-rate programs,
which depend on loan officer “subjectivity”, are
more prone to personal bias and therefore more
likely to violate anti-discrimination
regulations.
6.
"Risk based lending stands in
opposition to the credit union philosophy—since
it charges a higher rate to those who are least
able to afford it.
I
originally thought that also—until I dug deeper.
Traditional one-rate lending mandates that
higher risk loan applications are denied in
order to limit potential write-offs. These
members are then forced to seek other lenders --
who charge a much higher rate of interest.
Risk based lending allows your credit union to
charge a slightly higher interest rate so
that you can serve their borrowing needs—and
still do it at rates that are significantly
below those charged by many other lenders.
When we think of
fairness in the credit union,
we must focus on equal access to
credit
rather than equal rates.
Now consider
your savings program. Do you use a tiered
dividend rate?
Some credit union managers consider this as a
form of discrimination against low income
members. Since many of these members lack the
financial resources to reach the higher dividend
tier requirements – they are being denied the
opportunity to earn a better rate of return on
their savings. On the surface—it may seem
so—but when you dig deeper—you get a different
picture.
Tiered savings
rates encourages "savings oriented" members to
maintain a higher savings balance—thereby
insuring the availability of loan funds for
those members with the greatest borrowing needs
(the low balance saver).
In other words, although the low balance saver
receives less in dividend payments—they receive
a greater value through reduced borrowing costs.
The reduced loan interest expense usually more
than offsets any difference in dividend tier
rates. As a result, the entire membership
benefits from a tiered rate savings program—some
directly (your savers) and others indirectly
(your borrowers).
By the same token, a tiered-rate lending program
serves the needs of a greater portion of your
credit union membership. Through risk based
lending, you are able to issue a greater number
of “managed risk” loans—thereby meeting the
borrowing needs of a larger segment of your
membership.
The increased loan volume, in turn, results in
additional income (when compared to alternative
investments), which provides funds for higher
dividends and additional reserves for the credit
union—thereby benefiting the entire credit union
and insuring its continued survival. Once again,
we arrive at a win-win-win situation. Your
savers benefit—your borrowers benefit—and
management benefits.
Please Click Here for the "Bottom Line"