Discussion and Implications:

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- Fair Credit Reporting Act

- Entity Resolution

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Fair Credit Reporting Act (FCRA)

U.S. credit markets are the most efficient in the world at allowing households to smooth their consumption patterns over time, rather than postpone major purchases until

incomes and asset holdings build to sufficient levels. Accessible credit information “democratizes” financial opportunity.

The importance of consumer credit markets to the strength and resiliency of the U.S. economy is a direct consequence of the credit reporting system

Equally remarkable is the increased access to credit across the income spectrum over the past three decades.

- Dr. Fred Cate and Dr. Michael Staten

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Fair Credit Reporting Act (FCRA)

Access, efficiency and opportunity; the FCRA impacts price, access, and distribution of credit

Without the FCRA either the cost of credit will go up, or access to credit will be reduced

There are extraordinary consumer and economic benefits

derived from the current national credit system enabled by the FCRA

There’s simply no doubt we’ve got a remarkable market for

consumer credit in the United States; it’s intensely competitive, and we’ve made dramatic progress in terms of fairness and access for certain groups, who quite frankly, were not so well served by the marketplace ten or twenty years ago

- Dr. Michael Turner

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Fair Credit Reporting Act (FCRA)

• FCRA enacted in 1970 to promote accuracy, fairness, and

privacy of personal information assembled by Credit Reporting Agencies (CRAs).

• Sector specific “data use” law

• Amended many times

• Credited with creating a system of credit for “everyman”

• Covers the disclosure and use of “consumer reports”

• Covers the requirements of “consumer reporting

agencies”

• Gives enforcement authority to the Consumer Financial

Protection Bureau (CFPB) and the Federal Trade Commission (FTC)

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“Consumer Reports”

• Very broadly defined

• Basically any information

• Bearing on a consumer’s credit worthiness, credit standing,

credit capacity, character, general reputation, personal characteristics, or mode or living

• Which is used or expected to be used or collected in

whole or in part for the purpose of serving as a factor in

establishing the consumer’s eligibility for credit or insurance, employment purposes or (other permissible purposes under the FCRA)

5

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“Consumer Reporting Agencies”

• Equally broad

• Essentially any person that for a fee, regularly engages

in whole or in part in the practice of assembling or evaluating consumer credit information or other

information on consumers for the purpose of furnishing consumer reports to third parties

• If you provide “consumer reports, you are a “consumer

reporting agency”

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Implications of Being a

“Consumer Reporting Agency”

• CRAs have a number of obligations under the FCRA

-Notices to “furnishers” and “users”

-Duty to provide access to “files” to consumers

-Duty to reinvestigate disputes

• Information in files can only be disclosed for “permissible

purposes“

• Consequences of Violation of the FCRA

- The FTC and CFPB can bring enforcement actions

-State attorneys general can bring enforcement actions

-In some instances, criminal liability can exist

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Acxiom as an

Agent

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Reason for Agency Relationship

• Acxiom is not a CRA

• Acxiom does not have a permissible purpose to

obtain Consumer Report

• Agency relationship allows Acxiom to stand in the

shoes of the bureaus and process their data

• Allows Acxiom to serve as a “one stop shop” for our

clients

• Agent is entitled to have possession of Consumer

Reports that may not result in a firm offer of credit

• Agent is entitled to full SSN

• Agent is entitled to “know” the descriptions of the credit

attributes

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Definition of “Bureau Data”

• As a general rule,

any

data sourced from a

bureau (including name, address, SSN, date of

birth, credit attributes, IDs), regardless if data is

anonymous or depersonalized

• Whether Bureau Data is also a Consumer

Report depends on whether it is personally

identifiable (

e.g. name and credit attributes)

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When Can Financial Institution Receive

a List of Consumers and Credit?

• Only if it intends to make a firm offer of credit or

insurance to each individual who meets all of the Client's previously determined criteria

• The FCRA states that for prescreening purposes, "a

person may receive only

- The name/address of a consumer

- An identifier not unique to the consumer used solely for verifying

identity of a consumer

• Other information pertaining to a consumer that does not identify the

relationship or experience of the consumer with respect to a

particular creditor or other entity.”

• Client may not receive Social Security Numbers

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File Inputs for Bureau Solution

• 300,000,000 record file from each Bureau

• Other data files

• Standardization, Hygiene and Correction

• Front end suppressions (deceased, opt-outs, edit fails)

• Scoring based on Credit Selection Criteria

• Creation of the preliminary pre-screen lists

• Additional last minute suppressions

• Delivery of the pre-screen list to client and distribution

channel

• Delivery of promotional inquiry file to the Bureaus

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Security

SERVICE DELIVERY

Project Management Implementation Consultative

Services Systems Management

Input S our c e s A Bureau Files Enhancement Suppressions Customer And Response Da ta I nt e gr a ti on B Link Append Postal Cleansing Validation and Reporting NCOA Acxiom Services Data Hygiene AbiliTec Demographics Suppressions C Campaign Execution SCORING Scoring Extract Scoring E DATABASE ENVIRONMENT D Warehouse Database CAMPAIGNS

MARTS TOOLS OUTPUT

Campaign Datamart Summarizatio n Tables Rapidus Fulfillmen t Campaign History DM Vendors Email Vendors Call Centers Operational Reporting Reporting Datamart Reporting Calculation s F G

Acxiom Information Security, Privacy & Data Governance

Acxiom Operational Support—Account Dedicated + Infrastructure Management

Vertical Lists Opt Outs Outputs Scoring Extracts Solicitation Files Reports H Bureau Solution Database Extracts 13 Premiu m Mail

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Name _{Contact and}

Life stage Changes Touch Points Call Center Direct Marketing Brick & Mortar Website Address Home Phone Computer Cell Phone eMail Customer Support Digital Campaign Entity Resolution… Why is it so hard?

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> Recognize Consumers using:

• Physical or Email Addresses • Landline or Cell Phones

• Name variations, nicknames, changes,

maiden/married surnames

> Proprietary Knowledge Base

• 2 billion+ historical occupancies • Patented matching algorithms

• Up to 35 years of occupancy history

• Multiple, contracted sources • Updated Weekly

[email protected] Becky Jones 789 Main Street

[email protected]

Rebecca Jones

Link: ABC12345

Mobile: 501-252-1000

Only AbiliTec®_enables

complete consumer linking

Traditional Entity Resolution

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Data Quality

Match and De-Duplicate: Identification of duplicate records within or across disparate source files and assignment of non-consistent identification keys; optional merge / purge of duplicate records

Correct and Enrich: Corrections and completions to contact information, including change of address, routing data, ZIP + 4®_{, Geo data, compliance and}

preferences, etc.

Parse and Standardize: Decomposition of data sets into distinct elements; standardization of customer records to regionally accepted formats for name, address, phone, email, and other data elements

Entity Resolution

Data Quality and Entity Recognition Can Eliminate the Challenges Associated with Information Decay,

Incomplete Records and Distributed Intelligence

Recognition

Management _{Manage and Integrate:}_{Capabilities that enable the mastering of customer}

data across an enterprise; results in a unified customer view to ensure availability of consistent information for operational and analytical systems.

Consistent: Ability to accurately recognize customers over time, across multiple channels and data sources using all available identifying information.

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Clean Match Analyze Score Segment

Explosion of Online Data Multiplies Process

Gaps and Sub-Optimizes Your Data Assets

• Inability to connect online and offline contact data because • Can’t match online persona to real world person

• 60% of U.S. adults use more than one e-mail address • Multiple browsers, multiple devices per person

• Inability to standardize and correct customer attributes

• Skews customer identification processes

• Pollutes internal systems with incomplete and inaccurate info

* Chart: Accenture Global Content Study 2009

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Data Quality Problems and Matching

Inaccuracies Affect Downstream Activities

Prospect Data Web Registration Customers ? • Profitable _{• Loyal} ? • Average • Growth Potential ? • Headaches _{• Losses}

Clean Match Analyze Score _Segment

• Incomplete data discarded – shrinking your customer universe • Email and mobile can’t be linked to physical name and addresses • Incorrect scoring and segmentation hurts effectiveness

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The Ripple Effects of Poor Recognition

Management

Enterprise Application Implementation Failure

If the data is bad, it will be avoided, “work-arounds” will be applied that compound the problem

Cripple Cross Sell and Up Sell

Without a quality, effective view of the customer, timely targeted offers and communications are not possible

Threaten the Entire Customer Relationship

An inability to confidently recognize and care for a customer when contact is made can threaten the relationship. Enable Fraud.

Damage to Corporate Image

Incorrect offers, reaching out to inappropriate people (e.g., imprisoned, deceased), and not delivering on sales and marketing objectives effectively can cause damage to a corporate image

Negative Financial Impact

Difficulty in recognizing the value of CRM, MDM or EDW purchases compounded by an inability to deliver on revenue and earnings targets

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Start with DATA QUALITY

Standardization provides foundation for identifying duplicates and households Basic Facilitates more profitable promotions

Advanced

• In addition to Basic Most stop

here

Most accurate view of the consumer to:

• Improve analytics and decision making

• Reduce operational cost

• Increase customer insight

• Enlarge mailable universe and maximum postal discounts

Premium

• Corrects over 48% of missing or incorrect address information

• 8% better insight on new movers • 26% greater contact validation

• Supplies new address for 50% of the NCOALink®_{near matches}

or Moved Left No Address

Acxiom is a non-exclusive Full-Service Provider Licensee of the United States Postal Service®_{. The following}

trademarks are owned by the United States Postal Service®_:_{United States Postal Service}®_NCOALink®_{, CASS™, DPV}®_, SuiteLink_{™, DSF}2®_{, ZIP™}_{; LACS}Link®_{; ZIP Code™; First-Class™; eLOT}®_and_{ZIP + 4}®

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Recognition

Matching Sort Match and ID Assignment ID = 5678 Becky Smith 45 Oak St Chicago, IL ID = 1234 Rebecca Jones 12 Main St Conway, AR

Sort records based on geographic

information (ZIP™∗, Address, Last Name and First Name) Group similar records within a geography together and attempt to match prospective records together

Traditional String-Based Matching

Becky Smith 45 Oak St Chicago IL Rebecca Jones 12 Main St Atlanta GA Rebecca Jones 12 Main St Atlanta GA Link = ABC123 Becky Smith 45 Oak St Chicago, IL Link = ABC123 Rebecca Jones 12 Main St Atlanta GA Move Record Knowledge-Based Matching Link = ABC123 Becky Smith 45 Oak St Chicago, IL DOB: 7/4/60 Assoc=12345 Becky Wilson 123 1st_Ave Phoenix AZ DOB: 7/4/60 Assoc=12345 Rebecca Jones 123 1st_Ave Phoenix AZ Rebecca Wilson 123 1st Ave Phoenix AZ Association _Name Change Name Change AbiliTec Knowledge Base Rebecca Jones 12 Main St Atlanta GA Becky Smith 45 Oak St Chicago IL

Link Append Rebecca Jones

[email protected] Link = ABC123 Rebecca Jones [email protected] Rebecca Jones [email protected] 21

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cookie 12 cookie 9

[email protected] Becky Jones-Hall _{789 Main Street} Mobile: 501-252-1000 [email protected]

Digital Disconnect: device signature

22 cookie 1 cookie 2 cookie 3 cookie 4 device 1 device 2 device 3 cookie 5 cookie 6 cookie 7 cookie 8 cookie 10 cookie 11 Safe Haven [email protected] one-way hashed to: irreversible_UUID

Associated to devices 1 and 3

Online Purchase

How many people purchased? How many purchases were there?

Offline Purchase cookie 12 cookie 9 cookie 1 cookie 2 cookie 3 cookie 4 device 1 device 2 device 3 cookie 5 cookie 6 cookie 7 cookie 8 cookie 10 cookie 11 Safe Haven [email protected] one-way hashed to: irreversible_Abilitec_ID

Associated to device 2

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cookie 12 cookie 9

[email protected] Becky Jones-Hall _{789 Main Street} Mobile: 501-252-1000 [email protected]

Entity Resolution - A Single View

23 cookie 1 cookie 2 cookie 3 cookie 4 device 1 device 2 device 3 cookie 5 cookie 6 cookie 7 cookie 8 cookie 10 cookie 11 Safe Haven cookie 12 cookie 9 cookie 1 cookie 2 cookie 3 cookie 4 device 1 device 2 device 3 cookie 5 cookie 6 cookie 7 cookie 8 cookie 10 cookie 11 Safe Haven [email protected] one-way hashed to: irreversible_Abilitec _ID

[email protected] one-way hashed to: irreversible_Abilitec_ID Associated to devices 1 and 3 Associated to device 2 Online Purchase Hashed Abilitec ID Offline Purchase Safe Haven

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Reach Trust Open

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Tie Every Interaction to a Known Person

Email Capture  Refer a Friend  Invite a Friend In-Store Purchase  Name, Address  Email Address  Purchase Type

 Credit Card Type

 Merchandise Direct Mail  Birthday Reminder  Offer Tailored to Me Search  Search Terms  Referring URL  Site Activity TV Ad  Watching Squawk Box Customer ID 1234 R. Jones 123 Main St. NY, NY Social  Liked on Facebook  Tweets about

Experience with Client

 Updates Status about Great Experience

Online or Mobile Ad

 Browsing Web

 Impression and Click

 Anonymous to Client

Online Purchase

 Purchase, Extended Warranty

 Browsing Activity

 Email Address, Preference Center

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Single view to:

• Connect Your Data

• Develop New Audiences • Distribute Data

• Analyze Results

• Optimize Campaigns

AOS™ Vision: An Integrated Marketing Platform

Data Security Rights Mgmt Analytics Audience Management APIs Campaign Management Reporting PII Anon Access Email Page

Visits Apps Behaviors Response

Search Social Demo-

graphics Promo Partners Online

Imps

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[email protected] Mobile: 501-252-1000 [email protected]

Single Person View Powered by Linking

cookie 1 cookie 2 cookie 3 cookie 4 DEVICE cookie 6 cookie 7 3 cookie 9 cookie 10 cookie 11 cookie 12 1 2 Becky Jones-Hall 123 Main Street DEVICE One vs. Many

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© 2013 Acxiom Corporation. All Rights Reserved. Apple Device Facebook Candy Crush Segment A High Spender In Market for Travel 35-40 Female Segment A High Spender High Online spender New Mom Dog Lover Segment A High Spender Luxury Sedan Owner Married Visa User Segment A High Spender Anonymous AbiliTec ID: 123

Bringing Offline / Online Together

AbiliTec ID d894ad8sae

Segment A

Cust Type High Spender

Geo New York

Income $150 – 175K Onboarding with Anonymous AbiliTec ID™ Device Signature Method Tablet Device ID DEF Work Device ID GHI Home Device ID ABC Mobile Device ID JKL

Cookies Associated with

Anonymous AbiliTec ID: 123

Becky Jones Offline / CRM Database Offline Purchases DFA Clicks/ Impressions AbiliTec Method = =

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Multi-Dimensional Data View

29 DEMOGRAPHIC IN-MARKET SEARCH INTEREST PURCHASE BEHAVIOR LIFESTYLE CRM EMAIL SOCIAL VIDEO ENGAGEMENT APP DOWNLOADS