2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield

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2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE
PROVIDER SCORECARD

DECEMBER 2018

Licensed by:
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  TABLE OF CONTENTS

  Executive Summary ............................................................................................................................................................................. 4
         Key Findings ............................................................................................................................................................................ 4
  Recommendations ................................................................................................................................................................................6
  Addressing Today’s Fraud Threats ................................................................................................................................................. 7
  Four Types of IDPS Subscribers .................................................................................................................................................... 10
  Key threats to the Identity Protection Market.......................................................................................................................... 12
         Core Focus — Apathy and Lack of ROI ....................................................................................................................... 12
         Consumer Credit Safeguards: Freezes, Locks, and Alerts.................................................................................... 14
         Monitoring Focus — Aggressive Free Competition ................................................................................................ 15
         Data Protection Focus ....................................................................................................................................................... 17
  Scorecard Results ................................................................................................................................................................................ 19
  Prevention ............................................................................................................................................................................................. 20
         Data Security Tools ............................................................................................................................................................. 21
         Authentication ...................................................................................................................................................................... 22
  Detection ............................................................................................................................................................................................... 24
         Child Identity Monitoring.................................................................................................................................................. 25
         Existing Account Monitoring .......................................................................................................................................... 26
  Resolution .............................................................................................................................................................................................. 27
         Digital Resolution Tracking ............................................................................................................................................. 28
  Appendix................................................................................................................................................................................................ 29
  Methodology ........................................................................................................................................................................................ 30
  Endnotes ................................................................................................................................................................................................ 30

  TABLE OF FIGURES
  Figure 1: Mean Fraud Amount and Resolution Hours, 2008-17 ............................................................................................ 7
  Figure 2: Perceived Impact of Fraud, 2008-17 ........................................................................................................................... 8
  Figure 3: IDPS Net Promoter Categories, 2015-18 ................................................................................................................... 8
  Figure 4: Reasons for Canceling Subscriptions, 2015-2018 ................................................................................................... 9
  Figure 5: IDPS Subscriber Segments ........................................................................................................................................... 10
  Figure 6. Reasons for Cancellation, by Subscriber Focus.................................................................................................... 12
  Figure 7: Reasons for Canceling Subscriptions, 2015-18 ...................................................................................................... 13
  Figure 8: Source of Most Recent Credit Score, IDPS Subscribers and Other Consumers....................................... 16
  Figure 9: Most Important IDPS Features, by Age ................................................................................................................... 17
  Figure 10: Prevention Category Rankings ................................................................................................................................. 20
  Figure 11: Data Protection Capabilities at Evaluated Providers ........................................................................................ 22
  Figure 12: Password Reset Authentication at Evaluated Providers ................................................................................ 23
  Figure 13: Detection Category Rankings ................................................................................................................................... 24
  Figure 14: Child Identity Protection Capabilities at Evaluated Providers ..................................................................... 25
  Figure 15: Alert Types Offered at Evaluated Providers........................................................................................................ 26
  Figure 16: Resolution Category Rankings ................................................................................................................................. 27
  Figure 17: Digital Resolution Tracker Availability at Evaluated Providers .................................................................... 28
  Figure 18. Percentage of Fraud Victims Affected by Each Fraud Type ........................................................................ 29
  Figure 19. Number of Financial Relationships Among Banked Consumers ................................................................. 29

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                                                                 2
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

      ABOUT JAVELIN:                 Javelin Strategy & Research, a Greenwich Associates LLC company, provides
                                     strategic insights into customer transactions, increasing sustainable profits for
                                     financial institutions, government, payments companies, merchants and technology
                                     providers.

      AUDIENCE:                      Identity protection service providers, digital security solution providers, financial
                                     institutions, credit card issuers, credit bureaus, investment firms, and government
                                     regulatory agencies

      AUTHORS:                       Kyle Marchini – Senior Analyst, Fraud Management
                                     Al Pascual – SVP, Research, Head of Fraud & Security

      CONTRIBUTORS:                  Ian Benton – Senior Analyst, Digital Banking & Payments
                                     Crystal Mendoza – Production Manager
                                     Sean Sposito – Analyst, Cybersecurity

      EDITOR:                        Mark Stevenson

      PUBLICATION DATE:              December 2018

    OVERVIEW
    In the wake of some of the most destructive data breaches and dramatic changes to the US payments
    landscape with the adoption of EMV, the intensity and diversity of fraud schemes continue to increase.
    These growing threats reinforce the relevance of identity protection services in facilitating victims’ ability to
    prevent, detect, and resolve fraud. But other headwinds are emerging. The breadth of features offered by
    leading identity protection providers means they are exposed to competitive pressure on many fronts.
    Consumers have plenty of options when it comes to free credit monitoring. Newer feature sets such as data
    protection tools bring identity service providers into competition against data security companies who have
    established reputations in the space.

    In Javelin’s eleventh Identity Protection Service Provider Scorecard, we evaluate twenty leading products
    for the features they offer to help victims Prevent, Detect, and Resolve fraud against the backdrop of the
    threats facing consumers.

    PRIMARY QUESTIONS
        How do current fraud and financial service trends impact consumers demands on and expectations for
         the IDPS industry?
        How should providers adjust product offerings to best meet the challenges posed by the changing
         nature of fraud and the competitive landscape?
        What identity protection service providers offer the widest array of capabilities suited to addressing
         current and emerging fraud threats?

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                3
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 EXECUTIVE SUMMARY
  EZShield takes Best in Class in the 2018 Identity                               recommend their subscription, there is still a long
  Protection Service Provider Scorecard. As the only                              way to go, but the industry is moving quickly in the
  provider to emerge as a leader in all three                                     right direction.
  categories, EZShield distinguished itself through its
  breadth of capabilities, providing both robust core                             Regulatory backlash is behind the industry for
  functionality around credit, black market, and                                  now. After repeatedly being pummeled by
  existing account monitoring and emerging features,                              regulatory agencies for deceptive and abusive sales
  such as mobile data protection tools and digital                                practices, the IDPS industry has had three years
  fraud resolution capabilities.                                                  clear from fines, and it’s showing. Poor industry
                                                                                  reputation as a driver for attrition has steadily
  EZShield, ID Watchdog, IdentityForce, and Norton                                declined since 2015 and this year became the least
  LifeLock distinguished themselves as leaders in                                 prevalent reason for subscribers to cancel their
  prevention. These products all offer a wide array of                            services.
  features aimed at blocking threats to subscribers’
  identities. Notably, all these providers integrate                              Intensifying fraud attacks reinforce the value of
  digital security features into either their desktop or                          identity protection services. With fraudsters
  mobile offerings, such as secure browsing tools and                             diversifying the types of organizations they target,
  anti-malware partnerships.                                                      the amount of time victims have to spend resolving
                                                                                  fraud has risen notably since hitting a low in 2015.
  EZShield, ID Watchdog, and LegalShield                                          As fraud moves to other industries, many of the
  distinguished themselves as leaders in detection,                               targeted companies have not had nearly as much
  narrowly leading a competitive field. Each of these                              experience in resolving fraud as financial
  providers offers a robust set of alerts for core                                institutions. On top of that, the proportion of fraud
  monitoring services while also integrating newer                                victims who say the incident had a severe impact
  features such as existing account and social media                              on their life jumped from 8% in 2017 to 24% in 2018,
  monitoring.                                                                     undoing a decade of declines. This establishes
                                                                                  additional value for resolution services that help
  EZShield, IdentityForce, and Norton LifeLock                                    guide victims through restoration processes that
  distinguished themselves as leaders in resolution.                              may not be well-defined.
  Not only do these providers offer accessible
  resolution services, they moved ahead of the pack                               But other headwinds are emerging. The breadth of
  by digitizing parts of the resolution process. All                              features offered by leading identity protection
  three providers enable victims to report fraud from                             providers means they are exposed to competitive
  within their mobile apps and online portals.                                    pressure on many fronts. Consumers have plenty of
                                                                                  options when it comes to free credit monitoring.
  Subscriber satisfaction is on the rise. After several                           Newer feature sets such as data protection tools
  years of lackluster user satisfaction, the IDPS                                 bring identity service providers into competition
  industry’s Net Promoter Score rose to 22.6 in 2018                              against data security companies who have
  from 6.6 in 2017. With just under half (45%) of                                 established reputations in the space.
  customers saying they would be likely to

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                4
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  Fraud and breach fatigue is setting in. In spite of                             More than half of evaluated IDPS plans rely on PII
  the increasing intensity of fraud, in terms of both                             or knowledge-based authentication to verify
  real and perceived impact, customers discontinuing                              customers’ identity during the password reset
  subscriptions because they are now less worried                                 process. Not only do these authentication methods
  about fraud jumped dramatically in 2018 to become                               provide only a nominal level of assurance given the
  the third most prevalent reason for attrition, just                             past five years of data breaches, they condition
  behind the subscription’s being too expensive and                               users to be willing to provide their sensitive data for
  expired free periods.                                                           day-to-day activities, increasing the risk associated
                                                                                  with phishing and other social engineering
  Free credit freezes chip away at the value of                                   schemes.
  identity protection services. For consumers who do
  not plan to open new financial products or apply                                 Child identity protection features tend to mirror
  for other accounts that may require a credit inquiry                            capabilities for adults, to the detriment of robust
  (e.g., opening a new mobile phone account), credit                              products. The most widely available child identity
  freezes can obviate essentially all the credit-related                          theft protection feature is the ability to monitor for
  safeguards offered by identity protection. Not only                             the sale of the minor’s personal information on
  does a credit freeze ensure there will be no new                                black markets, currently offered by 65% of
  credit activity for monitoring products to detect, it                           evaluated providers. This functions in a very similar
  means the identity protection service will also be                              manner to the same feature for adults.
  unable to access the information contained within                               Unfortunately, monitoring for the establishment of
  the credit report — effectively shutting down those                             a new credit report in the child’s name or attached
  features.                                                                       to the child’s SSN, a somewhat stronger safeguard
                                                                                  against both synthetic identity and familiar fraud, is
                                                                                  the least prevalent child identity protection feature,
                                                                                  provided by just 40% of evaluated providers.

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                5
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 RECOMMENDATIONS
  Use data security partnerships to expand fraud                                  Digitize the resolution process. Enabling victims to
  prevention capabilities. Features such as screening                             initiate fraud claims from within the online portal
  for data-stealing malware, identifying phishing                                 can facilitate more timely detection and jump-start
  pages, and boosting the security of users’ logins                               the resolution process. While these features are
  can directly counter many of the threats that lead                              unlikely to eliminate the need for direct contact
  to subscribers’ data being compromised —                                        with victims, it can reduce the amount of time spent
  stopping the attack prior to the information’s                                  gathering basic information, enabling resolution
  winding up in the criminal marketplace.                                         specialists to focus on helping victims identify the
  Consequently, data protection features can turn                                 most effective next steps.
  identity protection service providers into active
  players in mitigating fraud risk, rather than sideline                          Use online portals to track next steps and follow-
  observers that detect fraud when it occurs.                                     up needs. Integrating a digital resolution tracker
                                                                                  into the IDPS platform’s online and mobile portals
  Enable subscribers to customize existing account                                can help remind victims of the steps already taken
  monitoring alerts. Specific alert customizability                                and recommend the best steps to take next,
  enables identity protection providers to act as a                               potentially including links to key forms or contact
  supplement to card protection features at the                                   information for organizations to reach out to.
  subscriber’s financial institution. The basic                                    Unfortunately, only 20% of evaluated providers
  transaction risk assessments provided with the card                             offer this capability through their web platform, and
  are likely to render existing account monitoring                                only 15% offer it through their mobile app.
  without customizability largely redundant.
  Conversely, providing the subscriber with a more
  robustly configurable set of alerts can enable the
  identity protection service to function well in
  tandem with pre-existing card safeguards.

  Aim to make digital channels self-sufficient. While
  only peripheral to the identity protection space,
  free competitors such as Credit Karma are raising
  the bar for digital capabilities with tools such as
  being able to submit disputes on TransUnion credit
  report entries entirely within their webpage. These
  kinds of features help the service move away from
  being a “concierge-style” offering that assists but
  can take only limited action to one that actually
  puts tools into consumers’ hands that they did not
  have before.

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                6
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 ADDRESSING TODAY’S FRAUD THREATS
  In the aftermath of one of the most critical data                               that remove much of the burden from the victim —
  breaches of all time, fraud hit record highs in 2017                            in part because federal regulations and card
  as fraudsters broadened their focus to target a                                 network rules have almost entirely shielded victims
  wider array of account types and organizations. The                             from liability for fraud. However, as fraud moves to
  combined increased intensity and diversity of fraud                             other industries, many of the targeted companies
  schemes have reinforced the relevance of identity                               have not had nearly as much experience in
  protection services in facilitating victims’ ability to                         resolving fraud as financial institutions.
  prevent, detect, and resolve fraud.
                                                                                  Consequently, along with the increased complexity
  Following the formal switch to EMV chip cards in                                of fraud has come a corresponding increase in the
  late 2015, with fewer opportunities for fraud at the                            amount of time victims need to spend resolving
  point of sale due to the difficulty of counterfeiting                           each incident. In 2017, fraud victims spent an
  cards, fraudsters have instead turned their attention                           average of 8.7 hours of their own time resolving
  to fraudulent new accounts and attacks on digital                               fraud, up from the record low of 5.2 hours in 2015
  portals at financial institutions, merchants, and even                           (Figure 1). This reinforces the value of identity
  other digital accounts such as email and social                                 protection providers in helping to coordinate
  media.                                                                          victims’ efforts in restoring their identity, directing
                                                                                  them to the best parties to contact and advising on
  Because financial institutions have conventionally                               the ideal next steps for fraud resolution.
  been the “first responders” when fraud occurs, they
  have developed fairly streamlined resolution flows

                                Resolution Times Climb as Fraud Amounts Continue to Decline
                                      Figure 1: Mean Fraud Amount and Resolution Hours, 2008-17

               Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                7
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  As fraud amounts steadily decline and fewer and
                                                                                         Industry NPS Rises Notably From 2017
  fewer victims pay any amount out of pocket to
                                                                                      Figure 3: IDPS Net Promoter Categories, 2015-18
  resolve fraud, the amount of time victims have to
  invest in restoring their identity has become a good
  metric for how burdensome fraud resolution is for
  victims, and victims’ perception of the impact of
  fraud on their life bears that out.

  After a decade of slowly declining severity of fraud,
  in 2017 the proportion of fraud victims who
  reported that fraud had a severe impact on their life
  jumped back up to 24%, the same level as in 2008
  (Figure 2).

  At a high level, the identity protection market
  appears to be in good shape in 2018. Overall
  satisfaction increased notably from 2017, with the
  industry’s Net Promoter Score rising from 6.6 in
  2017 to 22.6 in 2018, with both a steep increase in
                                                                                   Source: Javelin Strategy & Research, 2019
  promoters, to 45% from 38%, and a corresponding
  decrease in detractors, to 22% in 2018 from 31% in
  2017 (Figure 3).

                                     Severity of Fraud Spikes, Undoing a Decade of Progress
                                                Figure 2: Perceived Impact of Fraud, 2008-17

            Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                8
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  Along with a rise in subscriber satisfaction came                               The lack of regulatory action since 2015 can be
  more good news for the identity protection service                              attributed to two factors. First, heavy penalties
  industry. The proportion of subscribers canceling                               have made IDPS resellers particularly averse to
  their subscription due to poor industry reputation                              regulatory risk, with many financial institutions
  continued its three-year decline to become the                                  withdrawing identity protection add-on services.
  least prevalent reason for canceled subscriptions in                            The number of identity protection subscriptions
  2018 (Figure 4).                                                                obtained through a financial institution, the main
                                                                                  target of regulatory action, declined from 28 million
  This suggests that IDPS providers have largely been                             in 2015 to 23 million in 2017.1 Those that remained in
  able to put a rash of regulatory actions behind                                 the market have prioritized compliance
  them. These penalties, largely imposed by the                                   transparency in potential partnerships.
  Consumer Financial Protection Bureau and the
  Federal Trade Commission, hit IDPS providers and                                Additionally, the Trump administration’s efforts to
  their financial institution clients for $2.4 billion in                          restrict the power of the CFPB have resulted in a
  fines between 2012 and 2016, due to unethical                                    general decline in regulatory actions. However,
  marketing and sales practices, such as charging                                 providers should be wary of a potential for
  users who had not been fully enrolled and                                       increased regulatory scrutiny in the future with the
  consequently could not access the full benefits of                               Democrats’ resurgence in the House of
  the product.                                                                    Representatives.

                        Identity Protection Industry Reputation Recovers From Regulatory Blows
                                         Figure 4: Reasons for Canceling Subscriptions, 2015-2018

       Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                9
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD - DECEMBER 2018 Licensed by: EZShield
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 FOUR TYPES OF IDPS SUBSCRIBERS
  While the intensifying fraud landscape means that                               the space. The mark of a leader in the identity
  consumers do have a need for the kinds of services                              protection market is a product that is able to
  offered by IDPS providers, that doesn’t mean the                                effectively combine these disparate features into a
  market is not facing headwinds. One of the greatest                             cohesive product that justifies customers’ going to
  challenges facing the industry is the perennial                                 them, rather than assembling their own set of tools
  criticism that these products largely function as a                             from those available in the market.
  combination of services that consumers can find
  elsewhere, and to a certain extent this is valid.                               To more clearly identify the threats to the identity
                                                                                  protection service industry, we can break
  The breadth of features offered by leading identity                             subscribers into four segments based on the types
  protection providers means they are exposed to                                  of features that matter most to them in the IDPS
  competitive pressure on many fronts. Consumers                                  subscription:
  have plenty of options when it comes to free credit
                                                                                     Core focus: Two in five (41%) subscribers care
  monitoring. Newer feature sets such data                                             most about what could be described as “core”
  protection tools bring identity protection service                                   IDPS features such as resolution assistance,
  providers into competition against data security                                     fraud insurance, dark web monitoring, and
                                                                                       credit freezes.
  companies which have established reputations in

                      Customers’ Focuses Dictate the Competitive Threats Facing IDPS Providers
                                                      Figure 5: IDPS Subscriber Segments

                  Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
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2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

      Monitoring focus: Accounting for just under a                                Other focuses: A fairly small, but not negligible,
        third (29%) of IDPS subscribers, these users                                   set of subscribers (17%) report they care most
        care most about features that monitor for                                      about features that are typically seen as
        suspicious activity on their credit report or                                  ancillary IDPS features such as educational
        existing accounts.                                                             material, breach notifications, and the service’s
      Data protection focus: A notably smaller group                                 mobile app.
        than users with a core focus, 13% of subscribers
        care most about data protection features, tools
        such as password managers, anti-malware, and
        VPNs.

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                11
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 KEY THREATS TO THE IDENTITY
 PROTECTION MARKET
  CORE FOCUS —                                                                   was too expensive, notably higher than the rate for
  APATHY AND LACK OF ROI                                                         those with a monitoring focus (24%) and twice as
                                                                                 high as for users with a data protection focus (17%)
  Since many of the features that core-oriented
                                                                                 (Figure 6).
  subscribers care about are relevant only when fraud
  occurs or is about to occur, IDPS providers can
                                                                                 The high rate of cost-related attrition should be a
  struggle to provide relevance to this set of users.
                                                                                 driver for identity protection services to implement
  After six months or a year have gone by with no
                                                                                 more active tools and emphasize the ones they
  signs of fraud and no subscriber data being picked
                                                                                 currently offer. In addition to the fraud protection
  up in the dark web, it becomes difficult to convince
                                                                                 benefits of tools such as existing account
  users that the $10 to $30 per month expense of an
                                                                                 monitoring through aggregation and data
  IDPS subscription is worth it.
                                                                                 protection tools such as anti-malware and
                                                                                 password managers, these tools offer capabilities
  This manifests in a particularly high rate of cost-
                                                                                 that are relevant to daily browsing and financial
  related attrition. More than a third (34%) of core-
                                                                                 management, minimizing “dead air” that can occur
  oriented subscribers who canceled a subscription
                                                                                 between credit report refreshes and other
  within the past year did so because the subscription
                                                                                 monitoring updates.

                                     IDPS Providers Fail to Justify Value to Core Subscribers
                                         Figure 6. Reasons for Cancellation, by Subscriber Focus

          Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                12
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  Elevated concern about cost is also exacerbated by                              Decreased concern about fraud is certainly not a
  a general decline in concern about fraud among                                  bad thing in and of itself. In fact, one would hope
  identity protection service subscribers, in spite of                            that as financial services and other industries make
  the growing intensity of fraud affecting consumers.                             progress in establishing robust identity safeguards,
  This driver broke into the three most prevalent                                 consumers will have more confidence that their
  reasons for cancellation in each of the primary                                 identities and accounts are secure. However, the
  customer categories and contributed to a quarter                                identity protection industry necessarily needs to be
  (26%) of cancellations by core feature users (Figure                            able to cope with consumer attitudes around fraud
  6).                                                                             that will ebb and flow as consumers grow inured to
                                                                                  breach headlines and most users do not personally
  This factor becomes even more significant when                                   experience fraud in any given year. This requires
  placed in context with the past few years. In 2015                              implementing features that continue to have
  and 2017, lessened concern about fraud was a                                    relevance for the user outside of directly
  comparatively minor driver for user attrition,                                  addressing fraud.
  ranking as the second least prevalent reason for
  users to cancel their subscriptions in both years. In                           This year, a new threat emerged to the credit-
  2018, this leaped to near the top of the chart as the                           oriented identity protection service providers in the
  third most prevalent reason for users to cancel their                           form of free credit freezes. As of Sept. 21,
  subscriptions, behind the service’s being too                                   consumers nationwide became able to freeze and
  expensive and expired free subscriptions.                                       unfreeze their credit report for free with each of the
                                                                                  three main credit bureaus. Previously, fees were
                                                                                  determined by each state and ranged from free to
                                                                                  around $15.

                            Lessened Fraud Concern Leaps in Prominence as an Attrition Driver
                                          Figure 7: Reasons for Canceling Subscriptions, 2015-18

            Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
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provide access to the content of this report without permission.                                                                                                13
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  For consumers who do not plan to open new                                       Even though this can chip away at the value
  financial products or apply for other accounts that                              proposition offered by many identity protection
  may require a credit inquiry (e.g., opening a new                               service providers, it may work to the advantage of
  mobile phone account), credit freezes can obviate                               plans offered by the credit bureaus. These have
  essentially all the credit-related safeguards offered                           responded to the mandate of free credit freezes by
  by identity protection. Not only does a credit freeze                           building into their identity protection products the
  ensure there will be no new credit activity for                                 ability to immediately lock a credit report, a subtly
  monitoring products to detect, it means the identity                            different feature from a credit freeze. Although
  protection service will also be unable to access the                            credit report “on/off switches” predate free credit
  information contained within the credit report —                                freezes, these new offerings give them a higher
  effectively shutting down those features.                                       profile and highlight a differentiator of the credit
                                                                                  bureaus’ products.

       CONSUMER CREDIT SAFEGUARDS: FREEZES, LOCKS, AND ALERTS
       Fraud-conscious consumers have a few options when it comes to securing their records held with the
       major credit reporting agencies (CRAs), Equifax, Experian, and TransUnion. Each of these approaches
       has its own advantages and drawbacks:

       Credit freezes are the strongest safeguard consumers can place around their credit report. With a
       freeze in place, the CRA with the freeze is legally obligated to block essentially all requests by new
       creditors to view the credit report (law enforcement, government agencies, and existing creditors can
       still gain access). This effectively prevents new credit-oriented accounts from being opened in the
       consumer’s name. However, credit freezes still need to be placed individually with each of the bureaus
       and can be inconvenient to place and lift, since they typically require contacting the bureaus by phone
       or mail whenever there is a change to the freeze.

       Credit locks function similarly to credit freezes but offer somewhat lighter protections in exchange for
       greater convenience, since they are contractual arrangements between the consumer and the CRA
       rather than the legal framework provided by credit freezes. Crucially, this means the ability to lock and
       unlock a credit report applies only as long as the consumer has an open account with the credit lock
       products offered by each bureau. Equifax and TransUnion currently offer free lock products, but
       Experian charges $5 for the first month and $25 thereafter. Notably, while freezes can take up to a day
       to place, locking and unlocking the credit report is typically done instantly from within a smartphone
       app or online portal. This potentially makes locks preferable for users who anticipate they will need to
       be regularly locking and unlocking their credit report, such as renters who may have multiple credit
       inquiries while applying for a new apartment.

       Finally, the third major credit report safeguard available to consumers is fraud alerts. Unlike credit
       freezes and locks, alerts do not restrict new creditors’ ability to pull credit information on the user.
       Instead, an alert indicates that this individual is at heightened risk for identity fraud and that the
       creditor should take additional identity verification steps prior to approving a new account.
       Unfortunately, these additional identity verification steps are not prescribed by law and consequently
       offer only moderate protection against fraudulent new accounts. Previously, basic fraud alerts lasted
       for only 90 days, though fraud victims could place extended alerts that would last for up to seven
       years. Under the same legislation establishing free credit freezes, all consumers are now able to place
       year-long fraud alerts for free.2

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                14
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  MONITORING FOCUS —                                                              records from within the Credit Karma user portal
  AGGRESSIVE FREE COMPETITION                                                     empowers users to initiate, and potentially
                                                                                  complete, the fraud resolution process entirely
  Identity protection services arguably face the most
                                                                                  within the platform’s digital portal, ideally
  competition when trying to appeal to subscribers
                                                                                  eliminating time-consuming calls to customer
  who care primarily about credit report or existing
                                                                                  service.
  account monitoring. Credit monitoring services like
  Credit Sesame and Credit Karma are widely known
                                                                                  However, Credit Karma’s credit record dispute
  among consumers, easy to sign up for, and — more
                                                                                  feature does have some limitations. Users are not
  important — free.
                                                                                  able to submit documentation, such as police
                                                                                  reports or other proof that the account is
  Of these two services, Credit Sesame has made the
                                                                                  fraudulent, from within the Credit Karma portal, so
  most aggressive moves into the identity protection
                                                                                  any complex fraud cases are likely to still require
  service space with a free identity protection
                                                                                  the user to directly interact with TransUnion. Also,
  module that offers $50,000 in identity fraud
                                                                                  this feature is not currently available for records on
  insurance coverage along with resolution
                                                                                  the subscriber’s Equifax credit report, the other
  assistance. If users are willing to upgrade to a paid
                                                                                  credit bureau from which Credit Karma provides
  plan, they have access to a broader set of
                                                                                  information.
  traditional IDPS features, such as Social Security
  number monitoring, higher insurance coverage (up
                                                                                  Additionally, Credit Karma provides free “identity
  to $1 million), and 24/7 access to resolution
                                                                                  monitoring” to see if the user’s email address and
  assistance. Since this product both brands itself as
                                                                                  other unspecified pieces of personal information
  an identity protection service and offers a feature
                                                                                  can be found in dark web marketplaces or public
  set consistent with this market, the paid version of
                                                                                  dumps of breached data. While it is nice to see this
  Credit Sesame’s product is evaluated within the
                                                                                  kind of feature paired with a free credit monitoring
  scorecard.
                                                                                  service, it lacks the depth of other dark web
                                                                                  monitoring services provided through traditional
  Even without directly offering an “identity
                                                                                  identity protection services. Users do not have any
  protection” product that is labeled as such, Credit
                                                                                  visibility into the types of data monitored through
  Karma provides some features that help it cross
                                                                                  the service and lack the ability to enroll additional
  over into fraud protection territory. In addition to
                                                                                  identifiers, such as ID card numbers or other email
  monitoring for new activity on users’ credit report,
                                                                                  addresses that are not associated with the Credit
  Credit Karma has partnered with TransUnion to
                                                                                  Karma account.
  enable users to dispute credit report records
  directly from their Credit Karma portal, rather than
                                                                                  While users who are looking for full-featured
  having to leave the site and file the dispute
                                                                                  identity protection services will inevitably be
  separately with the credit bureau.
                                                                                  disappointed if they attempt to use free credit
                                                                                  monitoring services as IDPS surrogates, IDPS
  Crucially, this feature adds an air of self-sufficiency
                                                                                  services are losing a crucial part of the battle with
  to the product that is lacking from many identity
                                                                                  credit-oriented competitors. Only 13% of
  protection platforms. Rather than simply providing
                                                                                  subscribers reported that their identity protection
  a window into the subscriber’s financial life, being
                                                                                  service was the most recent place they went to
  able to address fraudulent or erroneous credit

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                15
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  check their credit score, behind their financial                                 resolving fraud entirely outside their platform,
  institutions (29% for primary bank/credit union, 15%                            which directly undermines the value they purport to
  for card issuer), credit bureaus (15%), and online                              provide.
  credit monitoring services (16%).
                                                                                  However, here as well, IDPS providers face strong
  This indicates that not only do many identity                                   competition from free services, not the least of
  protection service subscribers hold IDPS and credit                             which originates from the users’ own financial
  monitoring accounts but also that the identity                                  institution. IDPS providers cannot directly compete
  protection service is losing “top of wallet” status                             with financial institutions’ ability to screen, approve,
  when it comes to where subscribers go first to                                   and decline transactions and consequently must
  manage their credit information.                                                focus on detecting fraud that slipped through
                                                                                  financial institutions’ nets.
  Similarly, existing account monitoring is an
  important feature since it enables identity                                     Conventionally, the unique advantage that IDPS
  protection services to extend their coverage to                                 providers bring in combating card fraud is the
  card fraud, which accounts for more than 80% of                                 ability to aggregate information on accounts at
  fraud victims (compared with 20% for new-account                                multiple institutions, offering a single portal where
  fraud) (Appendix, Figure 18). Without the ability to                            subscribers can keep tabs on all their accounts,
  provide some degree of card fraud management,                                   rather than having to regularly visit multiple banks’
  IDPS providers will frequently find themselves in                                websites or apps. With 60% of banked consumers
  the position of having customers detecting and                                  holding accounts at two or more institutions and

                       5 in 6 IDPS Subscribers Check Their Credit Score at Another Organization
                     Figure 8: Source of Most Recent Credit Score, IDPS Subscribers and Other Consumers

          Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                16
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  20% of banked consumers holding accounts at four                                DATA PROTECTION FOCUS
  or more institutions, this is not an insignificant
                                                                                  A newer area of competition for identity protection
  advantage (Appendix, Figure 19), but it is being
                                                                                  services that Javelin has tracked closely over the
  eroded as a differentiator as more organizations
                                                                                  past few years are data security products that are
  offer similar capabilities.
                                                                                  blurring the lines with the IDPS industry. The most
                                                                                  high-profile case for the blurring of these markets,
  As of Javelin’s 2018 Mobile Banking Scorecard, a
                                                                                  of course, was the Symantec acquisition of
  quarter of the top 30 FIs in the U.S. offer the ability
                                                                                  LifeLock, which was completed in early 2017. Since
  to aggregate information on accounts held at other
                                                                                  then, other data protection companies have made
  institutions within their mobile app.3 Non-bank
                                                                                  moves into the space, with McAfee offering its own
  services such as Mint also offer the ability to
                                                                                  identity protection service and Dashlane, one of the
  aggregate account information within a single
                                                                                  leading password managers, adding dark web
  portal. Although they typically lack features
                                                                                  features and a credit monitoring partnership with
  specifically aimed at mitigating fraud, some of their
                                                                                  TransUnion to its premium product.
  capabilities can provide ancillary benefits in alerting
  the victim to card fraud schemes in progress, such
                                                                                  In Javelin’s view, data protection features such as
  as large transaction alerts.
                                                                                  anti-malware services, password managers, and
                                                                                  secure browsing tools have a crucial place in

                                      Data Security Tools Grow in Value to IDPS Subscribers
                                               Figure 9: Most Important IDPS Features, by Age

            Source: Javelin Strategy & Research, 2019

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                17
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  identity protection services’ product offerings.                                rather than sideline observers that detect fraud
  Actual fraud prevention tools have always been one                              when it occurs.
  of the weakest aspects of an industry that was
  largely focused on detecting suspicious activity and                            Data protection features have a growing appeal
  guiding users through the resolution process.                                   among subscribers, especially users 25-54. While
  Conventionally, assistance with setting up credit                               they still rank below some major identity protection
  freezes and security alerts was as far as identity                              features such as credit report and existing account
  protection providers went, and for most companies,                              monitoring, data security tools do rank above black
  that really meant directing customers to the credit                             market PII monitoring.
  bureaus.
                                                                                  Unfortunately, many of the IDPS implementations
  By screening for data-stealing malware, identifying                             of these features are still nascent and in need of
  phishing pages, and boosting the security of users’                             further development. Among users who care most
  logins, these kinds of features can directly counter                            about data protection tools in their identity
  many of the threats that lead to subscribers’ data                              protection subscriptions, the second most frequent
  being compromised — stopping the attack prior to                                reason for attrition was that the product did not
  the information’s winding up in the criminal                                    provide all the features they desired, accounting for
  marketplace. Consequently, data protection                                      29% of canceled subscriptions, a much higher rate
  features can turn identity protection service                                   than for users who focus on core features (18%) or
  providers into active players in mitigating fraud risk,                         monitoring (15%) (Figure 6).

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                18
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 SCORECARD RESULTS

                  2018 IDENTITY PROTECTION
                  SERVICE PROVIDER AWARD

                                BEST IN CLASS

                  EZShield Platinum Protection

  EZShield returned to the top of the pack in Javelin’s                           capabilities, providing both robust core
  2018 Identity Protection Service Provider                                       functionality around credit, black market, and
  Scorecard. As the only provider to emerge as a                                  existing account monitoring and emerging features,
  leader in all three categories, EZShield                                        such as mobile data protection tools and digital
  distinguished itself through its breadth of                                     fraud resolution capabilities.

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                19
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

 PREVENTION
  As has been a recurring theme in Javelin’s Identity                             EZShield, ID Watchdog, and Norton LifeLock
  Protection Service Provider Scorecard, prevention                               distinguished themselves as leaders in prevention,
  continues to be one of the most challenging tasks                               offering a variety of features aimed at blocking
  for IDPS providers but fortunately one that is                                  threats to subscribers’ identities. Notably, all these
  moving in the right direction. The growing adoption                             providers integrate digital security features into
  of data protection tools and emergence of digital                               either their desktop or mobile offerings, such as
  on/off switches for credit reports help to answer                               secure browsing tools and anti-malware
  one of the key criticisms of the industry — that                                partnerships.
  these services help victims address fraud when it
  occurs but offer few tools that can actually stop
  fraud before it happens.

                              EZShield, ID Watchdog, and Norton LifeLock Lead in Prevention
                                                           Figure 10: Prevention Category Rankings

                                                                       PREVENTION

                                                EZShield Inc.          Platinum Protection
                                    Leaders

                                                ID Watchdog            Platinum
                                                Norton LifeLock        Norton 360 with LifeLock Ultimate Plus
                                                Affinion Group         PrivacyGuard - Total Protection
                                                Experian               IdentityWorks
                                   Contenders

                                                Finastra               MyIdentityAssist
                                                ID Experts             MyIDCare
                                                IdentityForce          UltraSecure packages
                                                LegalShield            IDShield
                                                TransUnion             True Identity Premium
                                                Credit Sesame          Platinum Protection
                                                Equifax                Equifax Complete Family Plan
                                   Followers

                                                Intelius               IdentityProtect
                                                Intersections          Identity Guard
                                                Lookout                Personal
                                                ReliaShield            ReliaShield Elite
                                                True ID Pro            Platinum Membership
                                    Laggards

                                                FICO                   FICO Ultimate 3B
                                                McAfee                 Identity Theft Protection
                                                ScoreSense             ScoreSense
                                  * Providers in each category are listed alphabetically
                                    Source: Javelin Strategy & Research, 2018

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                20
2018 IDENTITY PROTECTION SERVICE PROVIDER SCORECARD

  DATA SECURITY TOOLS                                                                  Addressed by: password managers. With the
                                                                                       ability to generate and autofill strong
  One of the perennial problems facing the identity
                                                                                       passwords, users are relieved of much of the
  protection service industry is that, for an industry
                                                                                       burden of managing unique passwords across a
  that purports to protect customers from identity
                                                                                       plethora of online accounts.
  fraud, there are a comparatively small number of
  features that actually serve to reduce subscribers’
                                                                                     Phishing: Lookalike sites harboring malware or
  risk of identity fraud. Conventionally, this has been
                                                                                       attempting to steal passwords, card data, or
  limited to assisting subscribers in placing credit
                                                                                       other PII have grown more sophisticated, with
  safeguards such as freezes and fraud alerts.
                                                                                       many leveraging SSL certificates to provide
                                                                                       HTTPS and the padlock security icon next to
  Fortunately, the blurring of lines between the
                                                                                       their domain name to provide a patina of
  identity protection and consumer data security
                                                                                       legitimacy.
  markets is making strides in addressing this
  criticism. There are four main types of capabilities                                 Addressed by: secure browsers, anti-phishing
  that can help address several of the main methods                                    apps, and browsing extensions. Automated
  that fraudsters use to compromise consumers’ data.                                   tools are frequently much more effective than
                                                                                       human eyes at detecting that a purportedly
      Malware: While ransomware and cryptominers                                     legitimate site is actually missing a character
        are the strains du jour, keyloggers and Trojans                                from its URL or harboring malicious code.
        continue to be a threat to consumers as
        fraudsters demand data for card-not-present                                  Data interception in transit: Through
        fraud and account takeover, with counterfeit                                   compromised Wi-Fi or lookalike networks set
        card fraud steeply declining in the wake of the                                up in public locations, fraudsters can intercept
        EMV shift.                                                                     key pieces of consumer data such as passwords
                                                                                       and card numbers that are transmitted though
       Addressed by: desktop and mobile anti-
                                                                                       unencrypted connections.
       malware services and man-in-the-browser
       protection products.
                                                                                       Addressed by: VPN services. By automatically
                                                                                       encrypting traffic and routing activity through
      Password reuse: One of the more pernicious
                                                                                       the provider’s network, VPN services can
        threats posed by password breaches is that
                                                                                       provide a layer of protection against malicious
        they open up vulnerabilities at any organization
                                                                                       networks and routers that attempt to snatch up
        where victims used the same login information.
                                                                                       sensitive information.
        If consumers reused their login information for
        core accounts such as their email, that single
                                                                                  As valuable as these features are, there is one
        compromised account can provide a window
                                                                                  caveat that should be mentioned with regard to
        for fraudsters to intercept password reset
                                                                                  their value in identity protection services. Most of
        emails and gain access to otherwise secure
                                                                                  these features are aimed at protecting data on or in
        accounts.
                                                                                  transit from consumers’ personal devices but do

© 2018 GA Javelin LLC, a Greenwich Associates LLC company. All rights reserved. This report is licensed for use by Javelin EZShield only. No portion of
these materials may be copied, reproduced, distributed or transmitted, electronically or otherwise, to external parties or publicly without the permission of
GA Javelin LLC. Licensors may display or print the content for their internal use only, and may not sell, publish, distribute, re-transmit or otherwise
provide access to the content of this report without permission.                                                                                                21
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