Global Market
Update No. 6
Current &
Future Trends:
The Comprehensive
Reporting Issue
With so much to do, organisations
will need to have their implementation
plans in place with clear prioritisation
of initiatives.
Experian has worked with many
organisations across the world to do
just this. As such, we are able to help
lenders understand the opportunities
and also the potential pitfalls in the
adoption of this new legislation.
Regards
Nigel Butler
Director, Experian Decision Analytics
Experian and global independent research both confirm that use of positive credit bureau data increases
the predictive power of traditional or negative only credit bureau models. The introduction of positive
data allows new and enhanced bureau-based value added analytic products and services to be created,
which can be used independently or in combination with improved traditional credit bureau scores.
Let’s explore Experian’s global experience
of the benefits of positive data across two
customer life cycle touch points, Originations
Prospecting
and Collections (refer to Figure 1 for the full
lifecycle touch points):
Originations
Used in combination with internally
developed application scores, more
predictive bureau scores leads to better
Data
informed accept or reject decisions.
More accurate risk prediction also creates
An
a ‘swap set’, in particular for marginal
a l y ti c s
applications around the cut-off score, i.e.
previously accepted higher risk applications
t
can now be declined, and vice versa. This
leads to improved portfolio quality.
Retention
ess
sin
Bu
Lenders will also need to be smarter in the
way that they use Credit Reference Bureaux
(CRBs). Optimal multi-bureau capabilities
and strategies will ensure improved, and
cost effective, decision-making. Lenders
also need to be considering how, and which,
new models will be developed and utilised
to improve risk assessment, customer
affordability and/or loss likelihood.
A key element of the reform is the ability for more comprehensive data to be provided to a credit
reporting agency. Research shows that comprehensive credit reporting (or positive data) provides
richer information on a consumer’s payment performance and levels of commitment. This can
assist lenders to make more accurate credit risk assessments throughout the customer life cycle.
t
un e n
co
Ac gem
a
M an
Historically credit data has predominately
been used within originations as a “knockout” for high risk accounts. The legislative
changes enable more granular use of data
but across the entire lifecycle, including
collections. Combining the new information
with internal data sources and/or other
customer profiling (such as Mosaic),
enables lenders to target actions at
specific customer groups.
In 2006, the Australian Government requested the Australian Law Reform Commission, (“ALRC”)
to conduct a review of the Privacy Act 1988 to determine if the Act gave sufficient privacy protection
to the Australian public. After two years, the ALRC released its report to the Government and as a
result of the recommendations made by the ALRC, legislation has passed to enable significant reform.
ew
N
For some, this might still seem a long
way off but there is a great deal to be done.
Organisations need to start by considering
how they are going to approach this
change, be it as an early adopter or
a market follower.
Comprehensive Credit Reporting – Use of Credit Bureau Based Analytics
throughout the Customer Life Cycle
Cr
o
Up s s s e
sel ll
l
There is still much to be done but it is now
clear that come April 2014, the new credit
reporting framework will be in place.
Let’s talk about it.
Col
Rec lecti
ove on
rie s
s
Welcome to the 6th
edition of the Experian
Decision Analytics Global
Market Update series.
After a long and winding
journey, over many years,
Comprehensive Credit
Reporting (CCR) is finally…
almost… here.
Reactivation
When used to drive origination strategies,
bureau scores can improve initial credit
limit assignment and make risk based
pricing more effective by rewarding good
Figure 1: Where positive data can be used throughout
customers rather than only penalising
the customer life cycle under Australian legislation
bad ones.
perationally, availability of limits in the positive reporting environment improves internal serviceability
O
models, can reduce the need for verification (e.g. customer stated limits can be verified against those
held on the bureau), and help with meeting responsible lending obligations under the National
Consumer Credit Protection Act (“NCCP”).
At a macro level, bureau based benchmarking services allow organisations to compare their individual
portfolio level performance against the market and their peers. This allows an organisation to determine
the best course of action into future strategic acquisition strategies. Globally, Experian provides a suite
of bureau based analytical metrics to allow organisations to effectively benchmark themselves.
Account Management and Collections
Use of bureau data outside originations is not currently widespread due to its cost and the limited
use on a small, high risk population. In the positive data environment, repayment history over the last
24 months will be available and this richer information will lead to the development of bureau based
models and scores that will provide good support account management and collections strategies.
For example, globally, Experian has developed bureau based collections scores that predict likelihood
of payment in the next 3 months for currently delinquent accounts. Recovery models have also been
developed that predict likelihood that non-paying accounts in default will respond to further debt
recovery action.
When used in collections strategies, collections scores can result in significant cost savings by treating
accounts with a high likelihood of repayments with fewer or more cost effective actions or none at all.
Similarly, recovery models can lead to higher recovered balances, through the application of analytics
to prioritise resources to accounts with higher likelihood of paying back.
About Jean Abraham
Jean has worked in credit risk management for 15 years, primarily with
Experian Decision Analytics but also with ANZ on their Basel II program.
He has an Analytics background, with extensive project experience in
delivering analytical solutions including Basel II loss metrics for Retail
portfolios. This is complemented by experience in design and delivery
of decision solutions, principally for originations. More recently Jean has
developed a particular interest in Comprehensive Credit Reporting, its
impact on lenders and the industry and helping lenders prepare for
the new legislation.
Changing laws and what they mean.
Multi-bureau: What are the benefits?
As a result of the passing of the Privacy Amendment Act, the collection,
use and storage of personal information by Government Agencies and
private sector organisations will change. Consequently these entities will
now need to carefully consider their existing arrangements and those
currently under negotiation to ensure compliance by March 2014. For
those people involved in implementing and working through the new
regime; the work has just begun.
Today the predominant use of bureau data is at the point of application and
generally only one bureau is called. However, with the arrival of Experian to
the market there is now the opportunity to use all three bureaux.
The new legislation provides a lot of new opportunities including
streamlining and improving the credit application and decision process,
reducing bad debt through better customer management and facilitating
risk based pricing.
The first question that the amendments raise is perhaps one of “over and
mis- regulation” in the name of consumer protection. There is an underlying
clash between the objective of the National Consumer Credit Protection
Act 2009 and the changes to the Privacy Act. Under the former, lenders are
obliged to make enquiries regarding a borrower’s financial position and to
verify that position. This information allows lenders to assess if the product
is appropriate for the borrower. However the amendments introduced
by the Privacy Act still prohibit the use of the most powerful tool for that
assessment, the account balance. Thus legislators have entrusted the
lenders with the responsibility but denied them the most relevant tools
to fulfil their job. Experian research has demonstrated that by including
“account balance” in the assessment process nearly 14% more bad debt
is highlighted within the population with derogatory data and more than
18% of bad debt is highlighted within the credit active segment, with an
associated dollar value in the millions. If “account balance” was included
this would provide a more accurate estimation of credit indebtedness
and thus affordability.
Further still the amendments made within the definition of “default
information” and in particular the increase of an amount that is overdue
from $100 to $150 will impact roughly 1% of the default accounts that sit
in that range. For how many people is not making a credit card or phone
bill payment an early indicator of subsequent default on a larger mortgage
or personal loan product? This simple change in the definition will have
an adverse impact on the collections process, with the largest proportion
of these occurring within the telecommunications industry and credit
card portfolios.
The industry knew they were never going to achieve all that they wanted
through this reform. However, once comprehensive reporting kicks in,
the ball will be in their court. Regardless of whether it is a Tier 1 bank
or a smaller lender, every part of the application process will be affected.
Every organisation and agency within the industry will need their
capabilities evaluated and the gaps highlighted. This process will range
from simply up-dating application forms and training staff, to up-dating
infrastructure (i.e. establishing connection to the bureaux), modifying
current application processing systems and decision agents, training
underwriters and modelers and lastly informing existing customers.
One of the main reasons for a provider to use a multi-bureau strategy is
to access the broad set of data available for making decisions. For the best
decisions it is prudent to have an extensive understanding of an individual
and this can be achieved by accessing the most appropriate bureau for
each case (or multiple bureaux where practical and cost effective).
The development of customer profiles based on multi-bureau decisioning
strategies can optimise “value-for-money” product offerings across all
data providers. The benefits of multi-bureau include:
Data Coverage: It is common for data suppliers to not supply to all
bureaux in the market and as such different bureaux will have different
data. Examples of this may include industry preference for a particular
bureau or pricing based preferences. As such, it may be prudent to use
the multi-bureau strategy for niche populations, or invoking a secondary
bureau call where, for example a consumer has a ‘thin file’ to determine
if there is more data available
Niche Populations: As mentioned above a credit provider may
implement a strategy that orders a specific bureau choice for niche
populations (e.g. ‘youth’ segments may go to Bureau A, ‘mature’
segments may go to Bureau B etc)
Additional Data Sources: Where a bureau has unique data sources
preference may be given to that bureau where their data is useful in the
decision process for particular product or customer segments
Service Availability: The level of resilience, up-time and disaster recovery
is important and where a provider has concerns about a bureau, the
availability of multiple bureaux allows timely decisioning in the event of an
individual bureau experiencing problems
Regulatory Protection: Some providers see multiple bureau strategies
as a way of protecting themselves in the increasingly complex regulatory
environment by demonstrating that their systems use multiple credit
bureaux making the best decisions for their business and their customers
Value-Add Services: Each bureau will have its own set of products
(e.g. scores, triggers, segments) which will add value to the provider.
The additional value-add from these products may influence the choice
of a primary bureau and/or the use of a secondary bureau
Data Quality and Matching: Having ‘clean’ data is of the utmost importance
and optimum value will be gained from having the cleanest data. Each
bureau has its own matching and cleansing routines so a choice of bureau
may be made on the ‘match-rate’ along with the cleanliness of the data. There
are occasions when a second bureau may be used to find the ‘harder’
addresses as these have simply not been matched at the first bureau
The prioritisation of each of these steps will depend on the organisation’s
size, structure and business objectives, however it must be assumed in
the next 15 months building and updating the infrastructure as well as
addressing the legal requirements will be at the top of the list for all.
We should be mindful that while the cost of development or updating
of software is somewhat well understood within the industry, the cost
of enforcing and implementing all the legal requirements is not. An
understanding of the impact of these costs will be needed to manage
profitability and customer impact.
Connectivity: Making it simple to connect and ‘shake hands’ with a
bureau from a data perspective may lead to switching to another bureau
So far larger lenders have been investing more time and resources into
the appropriate infrastructure compared to the smaller lenders. However
the sheer size and complexity of these institutions makes it more difficult
to grasp the whole picture and manage the transition process. On the other
hand smaller lenders have not made as much progress and many are only
just waking up to the impending changes. The need for connectivity and
change into their origination systems will soon be top of their agenda.
It is a combination of all of the above points that will lead to decisions on
primary and secondary bureau calls, along with creating optimal strategies
to gain the most out of the bureau data available and making the best
decisions possible.
CCR Adoption
There is still a lot of change that will need to flow through, the Australian
privacy and industry codes are still being developed and once completed
will have a great impact on the way all new amendments by the Act are
to be implemented. The speed at which Comprehensive Credit Reporting (CCR) is adopted will
vary depending on the appetite of individual lenders, and as a result, so will
the benefits. To summarise and compare the advantages and disadvantages
of different approaches, the following classifications have been used;
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Experian Decision Analytics Global Market Update No. 6
Price: There are occasions where the decision to use a bureau may be
made with price in mind. Different bureaux may offer varying price models
which may be attractive to different businesses in certain scenarios
Customer Service: Easy connection to the bureau is a given, however the
approach to customer service will often lead to a provider choosing which
bureau will be the primary supplier
Abstainer: An “abstainer” chooses not to adopt CCR beyond the base
principles of the legislation.
Follower: Adopting a follower approach will mitigate some of the risks
of being an early adopter but removes the opportunity to realise some
early benefits.
Early Adopter: An early adopter would be looking to use their appetite
and ability to leverage positive data to maximise value immediately and
therefore gain competitive advantage over those who don’t.
Abstainer
Lender chooses not to provide or receive positive data
Pros:
+ No additional development costs
+ No risk, no mistake
Cons:
– Likely to be considered irresponsible lender*
– Customer confusion if other lenders/government/consumer groups
communicate changes publicly
– Adverse selection, means application profiles will deteriorate,
inheriting high risk accounts rejected by early adopters
– Missed opportunities from good, risk marginal declines
– Customer service likely to fall behind adopters
– Process efficiency gains not realised
– Going against the new political direction
Follower
Lender is fully ready for the major opportunities at – or shortly after – day 1 but
‘plays safe’ by not introducing anything which might be considered controversial
until it has been embedded in the market for some time
Pros:
+ Potentially learn from others mistakes in the market
+ Allow others to “take the heat” should there be any adverse reactions
from customers
+ Potentially slows down the general introduction of CCR
(assuming market follows)
Cons:
– A
dverse selection means application profile could deteriorate inheriting
high risk accounts rejected by early adopters
– May inadvertently fall behind due to speed of implementation
– Potential for some bad publicity in branding as others leverage ‘best practice’
– Lost opportunities from marginal declines
– Lost opportunities from improved customer service
– Process efficiency gains not realised immediately
– Increased risk of being considered irresponsible lenders*
Early Adopter
Lender views the introduction of positive credit bureau data as a major opportunity
and focuses all reasonable efforts to ensure processes, tools, systems, analytics
etc. are fully ready to exploit positive data as soon as it becomes possible
Pros:
+ Take full advantage of benefits in accept rate or bad rate reduction and gain
a competitive edge in customer service (verification, authorisations etc.)
+ Take full advantage of improved internal processes
(process efficiency, fraud prevention etc.)
+ Potential to leverage as leading brand – customer service, retention,
technology, innovation
+ Shape the market, ‘forcing’ others to follow
(verification, fraud prevention, customer communication, hardship policies)
Cons:
– Need to direct significant resources towards project in the short-term
– Risk of “getting it wrong” – additional IT cost, bad publicity
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Experian Decision Analytics Global Market Update No. 6
Credit licensees must comply with the NCCP (National Consumer Credit
Protection Act 2009) including responsible lending conduct obligations.
The key concept is that credit licensees must not enter into a credit
contract with a consumer, suggest a credit contract to a consumer or assist
a consumer to apply for a credit contract if the credit contract is unsuitable
for the consumer. There is an obligation to make reasonable inquiries about
a consumer’s financial situation including fixed expenses such as repayment
of existing debts. There is also an obligation to verify such information.
CCR may well become the new standard by which compliance with
NCCP is measured.
CCR has been proven to be advantageous to both lenders and customers
in every market in which it has been adopted. Lenders who fail to embrace
the opportunities of CCR may find themselves left with the negatives –
adverse selection and difficulties in retaining good customers with more
options than they have ever had to get the best deal. By being an early
adopter a credit provider can enhance their market share as they will be
better placed to offer products and services to good customers, with late
adopters/followers suffering adverse selection.
Risk Mitigation:
How will the new data help?
It is the application of new data together with your existing internal
information and the actions that are taken, not the data that makes
the difference – which is nothing new. However the availability of new
information about how your customers are using credit and with whom,
will add value and put your business in a more powerful position to
understand a) the total risk of your customer and b) develop the correct
action plan to optimise the situation. This process (risk mitigation) is
traditionally for the management of high risk customers – to reduce the
value of realised losses. On first thought it may seem this relates only
to collection actions, but that would miss the large opportunities across
credit cycle management. On the flip side – the same process is one way
to optimize profitability for all customers e.g. increasing or decreasing
card limits, allowing current accounts to overdraw in addition to the
direct collection action.
The global economic crisis and associated higher unemployment has
resulted in previously good customers struggling to meet their commitments.
Forward thinking lenders are aware that ‘prevention is better than cure’
so have begun incorporating pre collections activity into their credit cycle
management, with the aim of reducing the flow of cases into the
collection system.
Ultimately, it may not be possible to stop an account defaulting, however
the earlier that the customer’s position is understood, the earlier actions
can be taken to manage the risk and lower the loss. In this situation
information is indeed power – knowing more about the way your customer
is using credit, makes it easier to identify those customers that, while not
in arrears, are displaying signs of distress.
Identification of changing behaviour patterns indicative of financial distress
are vital if a lender is to make an early proactive intervention. Additional
information available through the introduction of comprehensive credit
reporting together with existing internal information held will add significant
value to this strategy – the availability of ongoing payment patterns with
other lenders will be extremely powerful when assessing customer risk.
Additionally external bureau data will add to the success of the contact
strategy by ensuring that you have the most accurate contact details.
Luckily you do not have to wait for another 14 months for CCR – some of
the lift can be achieved by leveraging Current Credit Provider (CCP) data
to better understand the risk profiles of your customers. There is a proven
relationship between the number of credit providers and the riskiness
of the customer.
Internal data alone will not ensure success. Even if you are the customer’s
primary lender, it is likely your customer will have other data rich accounts,
such as credit cards, phone contracts etc with other lenders. It is also likely
a customer in the early stages of financial distress will maintain their
relationship with the primary lender at the expense of a secondary lender
for as long as possible. If the primary lender does not leverage the external
data, internal data alone will not highlight the problem and it may be too
late when the primary account also starts to deteriorate.
Current
Future Australia
Using MOSAIC
Full Comprehensive
+4.8
+9.9
+5.5
+3
+10.2
Derogatory Data
+15.2
+6.6
+7.6
+2.5
Credit Active
New to Banking
Figure 2: Example Experian Credit Bureau based Benchmarking Report
The power of combining geo-demographic
and bureau data
Mosaic is a geo-demographic profiling tool that uses aggregated customer
data to provide highly predictive insight into the Australian population.
MOSAIC categorises the population into 11 groups that are further split
to form a total of 47 types. This tool provides a deeper understanding of
any customer base: who, what, where, when, how and why.
Understanding a customers’ demographic and lifestyle when combined
with bureau data is a powerful tool to acquire, manage and develop
profitable relationships and help achieve business KPI’s.
The first place where the power of these two elements can be harnessed
is for the purpose of building propensity models or strategies. Supplementing
customers’ payment history patterns (bureau data) with their sociodemographic information enables better estimation of their future needs
and follow-up behaviour.
Further to modelling or building strategies, geo-demographic and bureau
data can be used for segmenting pools of customers. Geo-demographic
data can slice and dice the population to expose the difference in
performance within different segments. Ignoring these differences
can create unstable and unreliable forecasts.
With the recent changes to the privacy legislation and introduction of
comprehensive credit data to Australia, lenders will learn more about their
customers’ payment performance. One vital piece of information that will
be missing with the implementation of this change is account balance.
In order to make up for the lost predictive power that balance provides,
one can either set up and develop a proxy or use additional data sources,
such as geo-demographic data, which provides insight into the borrower
and their behaviour. The uplift in the performance provided by the
geo-demographic data when developing models is demonstrated
in Figure 2 (above) for different population segments:
Current: Only negative data used.
Future Australia: Only data allowed as per the recent changes
in the privacy act.
than ever for lending institutions to be as diligent as possible when
assessing an application and ensure any offered credit is affordable.
Whilst the exclusion of balance is not ideal, there are many ways,
with varying degrees of complexity that comprehensive credit reporting
information can be used in the assessment of affordability. If used correctly,
these methods can not only help comply with responsible lending
requirements, but can potentially enhance the application decisioning
process to assist in driving growth, reducing bad debt, decreasing credit
losses and minimising operating costs.
The following are some commonly used methods to assess affordability
and some of the benefits that can come from using these methods:
Common methods limit can be used to enhance affordability assessment:
Derive affordability using limit:
– Assume balance = limit. If the customer can afford this, approve the
affordability component of the application (conservative)
– Estimate balance/repayment based on the date the repayment facility started;
the credit limit (proxy for initial balance) and a standard repayment curve
(low risk)
– Create an estimated balance model using limit, number of facilities,
time since account opened etc (high risk)
Calculate affordability using a combination of limit and the customers
provided information (e.g. balance)
Use geographical estimation models to enhance any limit models
Benefits that can arise through accurate income estimation:
Direct evidence of responsible lending in line with regulatory guidelines
Ensure appropriate and affordable products are offered
Improved decision making to:
– Reduce bad debt
– Decrease credit losses
Using MOSAIC: Using allowed data as per the recent changes
in the privacy act as well as MOSIAC.
– Target specific sub-populations, e.g. customers with higher capacity
Full comprehensive: No limitations on the data used.
Confirm declared liabilities/limits with bureau data, reducing
verification requirements
The combination of geo-demographic and comprehensive bureau data
enhances the decision making process in multiple areas during challenging
market conditions. The insights that it can provide can lead to an increase
in customer awareness and support and additionally drive higher sales.
Affordability, does CCR
give any assistance?
With the passing of the privacy legislation, lending institutions will soon
have access to a wider range of information about a customer’s financial
status. When you combine this with the ever increasing stringency around
NCCP and responsible lending requirements, it is now more important
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Experian Decision Analytics Global Market Update No. 6
Increased ability to segment the data
In short, existing affordability assessments may not need to change to
accommodate the new CCR information if they are fully compliant with
NCCP requirements. However with increasing competition in the lending
market and strict government regulations around responsible lending
it is inevitable that using this data during will be considered best practice.
Given this, the question should not be “Will this new information provide
assistance when assessing affordability?”, instead we should be asking
“How can we best use this new data to exploit the opportunities and
advantages that come with access to new information?”
CCR Questions and Implications
Consumer Credit Reporting FAQs
Did you know that…
If you are delinquent in making your payments, it may affect your ability
to access new credit?
You are entitled to free access to your credit report
Credit Reporting Agencies (CRAs) and credit providers need to
ensure that your information is accurate, up to date and complete
If you dispute an item on your credit report, the CRAs must review and if an
amendment is required, notify you and any other delegates immediately
Effective March 2014, credit providers will begin reporting and using (under
the reciprocity rules) information on all of your outstanding obligations
If you are not satisfied with the resolution of a reported problem,
you may lodge a complaint with the Privacy Commissioner
If you make consistent payments on your outstanding obligations,
you may be able to negotiate better loan terms on new obligations
These are just some of the implications for consumers of the recently
amended Privacy. When a consumer applies for credit, a credit provider
is able to obtain information from any of the credit reporting agencies
about their credit worthiness. That has not changed. However, the type
of information that will now be available to the credit provider has grown
multi-fold. Credit providers will be able to obtain access on all reported
obligations (under reciprocity principles) for an individual. This includes
whether the individual has had any difficulties making repayments to other
credit providers. Provisions have been made to limit the type of information
that may be held by the credit reporting agencies so, for example, medical
records, criminal records, political beliefs and so on are protected. The law
also requires that credit providers and credit reporting agencies take
reasonable steps to protect an individual’s personal information against
unauthorised use or disclosure.
In consideration of the enormity of the impact to a consumer, it is essential
that consumers are educated and informed about the consequences of the
new reporting to their ability to access credit going forward. Such education
should be government led in order to present the most objective and
unbiased view to the consumer. However, the government has made their
position clear on this matter. While they acknowledge that consumers do
need to be educated, they have refused to commit any funds to do so.
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In fact, they have placed the financial responsibility squarely on the
shoulders of private sector stakeholders. So who will ultimately be
responsible for informing and educating the consumer?
Like most pieces of legislation, the Act is complex and in order to ensure
a thorough understanding by individuals, a systematic and comprehensive
education program needs to be put in place to raise awareness of privacy
rights and obligations. This is an opportunity for institutions to partner
together to inform and educate consumers. For some, this will be an
opportunity to build their brand awareness and shape customer behavior.
In addition to the Privacy Act, NCCP also imposes a set of responsible
lending conduct requirements on credit providers. Compliance with the
responsible lending laws will require an assessment and verification of
a consumer’s credit needs and financial circumstances, including that
the consumer has the capacity to repay the new financial obligation.
In the US and UK, an individual’s financial reputation is represented
via their credit score. Most consumers are aware of their credit scores and
therefore their ability to access certain types of credit products. Customers
with “blemishes” in their credit history suffer the consequences through
higher pricing, i.e. sub-prime loans. Similarly, the new legislation in Australia
will enable consumers to take charge of their financial reputation. However,
this will require changing the existing mindset. Credit granting institutions
need to help train individuals to use credit consciously and responsibly,
to make them aware of the consequences of over-indebtedness.
Various studies have shown that comprehensive reporting reduces
the rates of delinquency and default and results in an improvement
in economic growth. Even some of the more vocal opponents of positive
reporting now recognise the potential for lending decisions to improve.
Ultimately this is a win-win proposition for all!
To summarise the implications of positive reporting for consumers:
Extension of credit to a wider consumer base in a safe and responsible
manner including customers who may have been declined in a negative
only environment
Consumers incentivised to manage their finances to ensure good
repayment history, empowering them to shop around for a good deal
Lender’s wider view of consumer liabilities reduces the possibility
of over-indebtedness, consistent with responsible lending compliance
Opportunity for institutions to build brand awareness and shape
consumer behavior through targeted education campaign
Global Market Update Contributors
Jean Abraham
Paula Bray
Nikolay Dimitrov
Nathan Bock
Michael Sheppard
Kalpana Rumburg
Denise Tipping
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please contact your Experian Account Director or email
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Disclaimer
This material has been prepared by Experian and is general information about Experian’s activities. The content is intended for general information and only represents
the view and understanding of Experian Asia Pacific Pty Ltd. This information does not constitute legal advice or professional advice of any kind. Before acting on any
information you should consider the appropriateness of the information having regard to these matters and you should seek independent advice.
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