February 11, 2013
Is Growing Fraud Really a Catalyst for EMV?
My payments news feed has been filled with a heavy dose of EMV-related news these last few days. Take the January 2013 article from the American Banker that looks at the incidence of increasing fraud losses as the United States continues to lag on the implementation of EMV chip cards. This one especially caught my attention given that I had written a paper on this topic early in 2012.
In recent SEC filings, both Discover Financial Services and Capital One reported significant increases in fraud losses. Based on calculations using figures from Discover's latest annual report, its fraud rate on sales volume increased from 4.8 basis points in 2010 to 7.2 basis points in 2011, and reached 8.8 basis points in 2012. Because of our nation's continued reliance on magnetic-stripe cards, "we are the weakest link around the world," according to one analyst. According to another, "the fraud comes here." Given this trend of rising fraud losses, is fraud finally becoming a bigger part of the business case for EMV with card networks' liability shifts for counterfeit fraudulent transactions a little more than two years out?
I don't think that it is. While the American Banker article, and even my paper, paints a somewhat discouraging picture of the fraud situation, the fact remains that fraud is but a small, albeit growing, expense on an issuers' income statement. For example, Discover reported $93 million in fraud losses for 2012, or roughly $8 million more than it spent on postage. By comparison, net charge-offs from credit card debt cost them over $1.2 billion in 2012 and as much as $3.7 billion in 2010. Fraud risk as measured by fraud losses is just "another expense" to issuers while credit risk, measured by credit losses, has one of the largest, if not the largest, negative impact on an issuers' bottom line. Is it possible that fraud losses will have a larger negative impact further down the road? Absolutely, and I think they will. I also recognize there are other "soft costs" associated with card fraud in terms of cardholder inconvenience and overall payment safety perception.
Further, EMV does not address the entire fraud loss problem. It's no secret by now that while EMV has been excellent at reducing face-to-face fraud, card-not-present (CNP) fraud continues to rise because EMV does not effectively prevent it in today's online environment. For example, since the rollout of chip-and-PIN in 2008 in Canada, CNP fraud increased from C$128 million to C$259.5 million in 2011. This is another example of fraud moving to the weakest link in the payments chain. Ultimately, EMV as it exists today only solves part of the fraud equation. Until a cost-effective and consumer-friendly CNP fraud reduction solution gains traction, I believe a business case for EMV built around fraud losses will remain difficult to build. For some, the costs to implement EMV may be viewed as an insurance policy against a widespread compromise of the mag-stripe technology.
It has been more than 17 months since Visa announced its EMV U.S. migration plan and a year since MasterCard announced its EMV "Roadmap." Still, issuance and acceptance of EMV cards remains tepid, if that, here in the United States. With a little over two years until the first liability shifts for the U.S. are scheduled to take place in April 2015, issuers will need to make EMV migration decisions soon if they intend to take advantage. But is the business case there currently?
By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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