3/25/2024

Chase Sues Trans Union Argus over Privacy










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I can't summarize the specific risks of JPMorgan Chase with Argus, Verisk, and consumer privacy, but I can provide some general information that might be helpful.

JPMorgan Chase is a large financial institution that collects a lot of data on its customers. This data could include things like your name, address, Social Security number, income, and spending habits. This data is valuable to JPMorgan Chase, but it could also be valuable to criminals or other unauthorized people.

Argus and Verisk are data analytics companies that provide information to businesses, including financial institutions. It is possible that JPMorgan Chase could share customer data with Argus or Verisk. If this data is not properly secured, it could be accessed by unauthorized people.

Consumer privacy is a growing concern, and there are laws and regulations in place to protect consumer data. JPMorgan Chase is required to comply with these laws and regulations. However, there is always a risk that a data breach could occur.

Here are some steps that JPMorgan Chase could take to mitigate these risks:

  • Implement strong security measures to protect customer data
  • Only share customer data with authorized third parties
  • Be transparent with customers about how their data is collected and used
  • Comply with all applicable laws and regulations

If you are concerned about your privacy, you can contact JPMorgan Chase to ask about their data security practices. You may also want to consider reviewing your privacy settings with the bank. I asked Chase ten times to not record my voice for recognition, to never share my social security number, date of birth or address but they continue to give away the bank. Argus, Trans Union, and Verisk (the prior parent company) all sell my information to the devil.

PMorgan Chase's lawsuit against Trans Union hinges on the alleged misuse of anonymized credit card data by Argus, which Trans Union later acquired. Here's the breakdown:

  • The OCC Mandate (2009): The Office of the Comptroller of the Currency (OCC) required banks like JPMorgan Chase to submit anonymized (no Personally Identifiable Information - PII) credit card data.
  • Argus as Data Aggregator: The OCC contracted with Argus to collect and process this anonymized data from banks. This presumably involved compiling and analyzing the data for the OCC.
  • Confidentiality Expectations: JPMorgan Chase likely assumed the anonymized data would be kept confidential by Argus, considering the OCC's purpose and trade secret laws.
  • Federal Reserve & CFPB Contracts: The Federal Reserve and Consumer Financial Protection Bureau (CFPB) followed suit, trusting Argus with similar anonymized data collection.
  • Trans Union Acquires Argus: Later, Trans Union acquired Argus, inheriting the contracts and the anonymized data.
  • JPMorgan Chase Sues Trans Union: JPMorgan Chase suspects Trans Union misused the anonymized data, potentially by:
    • De-anonymizing it (which could be a challenge)
    • Combining it with other datasets to identify individuals
    • Selling the data (even if anonymized) in a way that wasn't aligned with the original agreements.

JPMorgan Chase believes Trans Union violated the trust and potentially even the law regarding how anonymized data should be handled. Chase is responsible as well, this is a method to appear compliant, not actually be within privacy laws.

There are several key privacy laws in the United States that protect consumers' banking and credit habits. Here's a breakdown of some of the most important ones:

  • The Gramm-Leach-Bliley Act (GLBA): This 1999 law requires financial institutions to protect the privacy of their customers' nonpublic personal financial information (NPPI). NPPI includes things like your name, address, Social Security number, income, and account balances. The GLBA also gives consumers the right to know what information a financial institution collects about them and how it is shared.
  • The Fair Credit Reporting Act (FCRA): This 1970 law regulates credit reporting agencies (CRAs) like Experian, Equifax, and TransUnion. The FCRA gives consumers the right to see their credit reports and dispute any errors. It also limits how often your credit report can be checked without your permission.
  • The Right to Financial Privacy Act (RFPA): This 1978 law restricts the government's ability to access your financial records without a warrant or your consent. It also requires financial institutions to notify you before they disclose your nonpublic personal information to third parties.

These are just a few of the key laws that protect consumer privacy in the context of banking and credit. It's important to note that these laws are complex and there may be exceptions.

  • Consumer Financial Protection Bureau (CFPB): https://www.consumerfinance.gov/ The CFPB is a government agency that enforces many of the consumer financial protection laws, including the GLBA and the FCRA.

 

 

 


3/24/2024

Commercial Real Estate Apps



Commercial information applications for real estate


Here's a comparison of Tex-X, CoStar, Moody's Analytics (Economy.com), and Economy.com for analyzing commercial real estate:

Tex-X

  • Focus: Primarily provides data on property characteristics, valuations, and transactions.
  • Strengths:
    • Deep property-level data, including tenant leases, operating expenses, and cap rates.
    • Granular market coverage, especially for major metros.
    • Well-suited for detailed property valuation and underwriting.
  • Weaknesses:
    • Limited analytics and reporting tools compared to competitors.
    • Subscription can be expensive, particularly for smaller firms.
    • User interface can be dated and less intuitive than some competitors.

CoStar

  • Focus: Comprehensive data provider with a mix of property characteristics, market research, and analytics tools.
  • Strengths:
    • Extensive data coverage across all property types and geographies.
    • Powerful mapping and charting tools for market analysis.
    • Offers a variety of subscription tiers to fit different budget needs.
  • Weaknesses:
    • Data quality can be inconsistent, especially for smaller markets.
    • Advanced features can have a steep learning curve.
    • Can be overkill for users who only need basic property data.

Moody's Analytics (Economy.com)

  • Focus: Macroeconomic and real estate market data and analysis.
  • Strengths:
    • Strong reputation for economic forecasting and market trends.
    • Provides national and regional market reports in addition to property data.
    • Useful for understanding the broader economic context of commercial real estate markets.
  • Weaknesses:
    • Limited property-level data compared to Tex-X and CoStar.
    • Less granular market coverage, particularly for smaller local markets.
    • May not be as suitable for detailed property-specific analysis.

Economy.com (Not to be confused with Moody's Analytics (Economy.com))

  • Focus: Limited information available online. It appears to be a general economic data and research provider, but it's unclear how in-depth their commercial real estate coverage is.

Here's a summary table to help you decide:

Feature

Tex-X

CoStar

Moody's Analytics (Economy.com)

Economy.com

Data Coverage (Property-level)

Deep

Extensive

Limited

Unclear

Data Coverage (Market)

Granular (major metros)

Extensive

National/Regional

Unclear

Analytics & Reporting

Limited

Powerful

Strong (macroeconomic)

Unclear

Subscription Cost

High

Varied

Moderate

Unclear

Ease of Use

Less intuitive

Steeper learning curve

User-friendly

Unclear

Best For

Detailed property valuation & underwriting

Comprehensive market analysis

Macroeconomic & market trend analysis

pen_spark

Unclear

 

RMBS Private Label Packaging

Diving into Non-Agency RMBS: The Wild West of Mortgage Investing

For those interested in the nitty-gritty of the mortgage world, non-agency RMBS, also known as private label RMBS, offer a high-risk, high-reward investment opportunity. But before you jump in, it's crucial to understand what you're getting into.

Breaking it Down: Non-Agency vs. Agency RMBS

Most people are familiar with agency RMBS, those backed by government-sponsored enterprises (GSEs) like Fannie Mae and Freddie Mac. These offer stability with a government guarantee in case borrowers default.

Non-agency RMBS, on the other hand, are the rebels of the mortgage world. Issued by private institutions like banks and investment firms, they hold mortgages that don't meet the GSEs' strict criteria. This could be due to loan size, borrower creditworthiness, or property type.

The Allure of Non-Agency RMBS

So, why invest in something riskier? The potential payoff:

  • Higher Returns: Since they carry more risk, non-agency RMBS can offer significantly higher yields compared to agency counterparts.
  • Greater Diversification: Non-agency RMBS can add diversification to your portfolio, as their performance isn't tied to the government.

Understanding the Risks

But with great reward comes great risk. Here's what to watch out for:

  • Increased Default Rates: The very reason these mortgages aren't agency-approved is that they carry a higher chance of default.
  • Lower Liquidity: The non-agency market is smaller and less transparent, making it harder to buy and sell these securities.
  • Complex Analysis: Analyzing non-agency RMBS requires deep dives into the underlying loans, making them unsuitable for casual investors.

Non-Agency RMBS: Not for the Faint of Heart

Investing in non-agency RMBS requires a strong understanding of the mortgage market, risk tolerance for potential defaults, and the ability to analyze complex financial instruments.

Loan types may use Debt Service Ratios, alternative documentation for income, and only want prime locations. If you're a seasoned investor seeking high returns and portfolio diversification, non-agency RMBS could be an option. But for everyone else, proceed with caution and do your research before diving into this wild west of mortgage investing.

It's important to understand that private label non-agency RMBS aren't issued by lenders themselves, but rather by investment banks and financial institutions who pool together mortgages that don't meet agency standards and then issue them as securities.

Here's why lenders aren't directly involved:

  • Origination vs. Securitization: Lenders originate mortgages, meaning they connect borrowers with loans. Securitization, on the other hand, is the process of pooling those mortgages and turning them into tradable securities like non-agency RMBS.
  • Risk Distribution: By securitizing non-agency mortgages, lenders spread the risk of defaults across investors who purchase the RMBS.

However, if you're interested in which institutions might be originating the underlying mortgages for non-agency RMBS, here are some examples:

  • Regional Banks: Many regional banks originate non-jumbo mortgages (loans exceeding conforming loan limits set by Fannie Mae and Freddie Mac) that could end up in non-agency RMBS.
  • Mortgage REITs (Real Estate Investment Trusts): These firms invest in real estate-related assets, and non-agency mortgages can be a part of their portfolio.
  • Non-Bank Lenders: Specialty lenders who cater to borrowers with lower credit scores or those seeking alternative financing options might originate mortgages that get packaged into non-agency RMBS.

·        Hard Money Loans: Hard money loans, which are short-term, asset-based loans secured by real estate. Typically, eighteen months terms. These loans are for borrowers who might not qualify for traditional bank financing.

·        Non-Agency RMBS: Non-agency RMBS, on the other hand, are securities created by pooling together mortgages that don't meet the standards of government-backed institutions like Fannie Mae and Freddie Mac. These are then sold to investors.

The Difference:

·        Lending vs. Securitization: A hard money company acts as a lender, providing financing directly to borrowers. Non-agency RMBS deal with securitization, which is the process of transforming numerous loans into tradable securities.

·        Loan Focus: Hard money loans are not usually securitized and packaged into non-agency RMBS but sometimes they are bundled together with similar mortgages. Since they do not fit with GSE criteria it is difficult to determine the ability for these loans to perform or rate them.


3/21/2024

State Farm Cancelling More Hazard Insurance Policies in CA

 

March 20, 2024

 

 

Subject:

Update on California

 

 

To:

Agents Licensed in California

 

 

From:

Denise Hardin, Senior Vice President

 

Thank you for all that you do to serve State Farm® customers in California. As we’ve discussed in our California Update calls, State Farm General Insurance Company’s (SF General) financial picture is concerning.

Despite ceasing writing new Fire business last May and implementing rate increases in several product lines this year, the financial strength of SF General continues to deteriorate.

Although there haven’t been significant California wildfire losses for several years, large underwriting losses and growing risk exposure has resulted in surplus of less than 50 cents for every dollar of risk we face today. SF General’s financial strength is less than a quarter of what it was in 2016. Even factoring in the May 2023 action and the approved rate increase, the financial picture for SF General is projected to get worse in 2024.

As a result, we must take some difficult but necessary underwriting actions that will unfortunately impact some of our existing customers.

As shared during today’s call, State Farm General will take the following actions to further reduce our exposure in California:

  • Non-renew approximately 30,000 homeowners, rental dwelling and other property insurance policies (residential community association and business owners) beginning July 3, 2024.
  • Withdraw from offering commercial apartment policies, which will result in the non-renewal of all those policies (approximately 42,000) beginning Aug. 20, 2024.

Additionally, State Farm General will also:

  • Remove commercial earthquake coverage for all remaining Business Lines Fire policies with the endorsement, excluding farm/ranch.
  • Non-renew business owners policies for tobacco product stores and telephone/cell phone stores & installation.

Combined, these actions represent just over 2% of Fire policies in the state.

We realize this will impact many of you and the relationships you have built. This decision was not made lightly and is necessary to improve the affiliate’s financial strength to ensure we can help more people in more ways, forever. We’ll continually evaluate our approach based on changing market conditions.

 

Action requested

Please review the following resources in preparation for customer questions:

·      Update on California on statefarm.com®

·      3/20/2024 letter from State Farm General to the California Department of Insurance

·      State Farm General underwriting actions on Agency Hub News

·      *Key Messages and Customer FAQ on the Western Market Area site’s California page. The Key Messages include details about the agent policy listings that will be available in the Campaigns tab of ECRM beginning March 20.

Your market area leadership is also available as a resource. As always, please redirect any media inquiries to Sevag Sarkissian.

Message points
The following are approved messages agents can share verbally with customers:

  • State Farm General Insurance Company is taking necessary actions to improve its financial strength related to California:
    • State Farm General will non-renew approximately 30,000 homeowners, rental dwelling and other property insurance policies (residential community association and business owners) beginning July 3, 2024.
    • Additionally, the company will withdraw from offering commercial apartment policies with the non-renewal of all of those approximately 42,000 policies beginning Aug. 20, 2024. (This is insurance for apartment owners, not renters insurance.)
  • The non-renewal process will take over a year to complete. (through July 2, 2025, for impacted homeowners, rental dwelling, residential community association and business owners policies and until Aug. 19, 2025, for apartment policies)
  • State Farm independent contractor agents licensed and authorized in California will continue to service impacted policies up until their last date of coverage.
  • State Farm agents will also continue to service policies not impacted by these decisions.
  • We’re mindful of the impact to customers and will continue to work constructively with the California Department of Insurance, Governor’s Office and policymakers to address needed market reforms and help build market capacity in California.
  • This decision is unique to California and the challenges there.

 

Thank you again for your ongoing commitment as we continue to address our challenges in California. 

For more information

  • For questions about the philosophy of these underwriting actions and agent impacts, contact your sales leader.

 

C:

Senior Executive Council; Sales Executive Office; Western Market Area Executive Team; P&C Underwriting/Billing Strategy, Actuarial & Modeling Executive; Angela Martin; Adam Swope; Jeff Clinch; Ken Doss; Sales Leaders of agents licensed in California; WMA Agency Administration Leaders and AFS Function Manager/Managers; ECC PLCC/BLRC and Billing Directors; Greg Reynolds; Nathan Miller; Tisha Strand; Debra Billings; Sheri Kurkowski; Laura Campbell; Marty Wietfeldt; Melinda Clark; Laura Triplett; Anne Bennett; Lynn Whitlow; Chris Stucky; WMA Executive Assistants

 

FOR INTERNAL STATE FARM USE ONLY

Contains information that may not be disclosed outside State Farm without authorization

 

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