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Portals and Rails

June 30, 2014

A Call to Action on Data Breaches?

I recently moved, so I had to go online to change my address with retailers, banks, and everyone else with whom I do business. It also seemed like an ideal opportunity to follow up on the recommendations that came out after the Heartbleed bug and diligently change all my passwords. Like many people, I had a habit of using similar passwords that I could recall relatively easily. Now, I am creating complex and different passwords for each site that would be more difficult for a fraudster to crack (and at the same time more difficult for me to remember) in an attack against my devices.

I have found myself worrying about a breach of my personal information more frequently since news of the Heartbleed bug. Before, if I heard about a breach of a certain retailer, I felt secure if I did not frequent that store or have their card. Occasionally, I would receive notification that my data "may" have been breached, and the threat seemed amorphous. But the frequency and breadth of data breaches are increasing, further evidenced by the recent breach of a major online retailer's customer records. This breach affects about 145 million people.

As a consumer, I find the balance between protecting my own data and my personal bandwidth daunting to maintain. I need to monitor any place that has my personal data, change passwords and security questions, and be constantly aware of the latest threat. Because I work in payments risk, this awareness comes more naturally for me than for most people. But what about consumers who have little time to focus on cybersecurity and need to rely on being notified and told specifically what to do when there's been a breach of their data? And are the action steps usually being suggested comprehensive enough to provide the maximum protection to the affected consumers?

Almost all states have data breach notification laws, and with recent breaches, a number of them are considering strengthening those laws. Congress has held hearings, federal bills have been proposed, and there has been much debate about whether there should be a consistent national data breach notification standard, but no direct action to create such a standard has taken place. Is it time now to do so, or does there need to be more major breaches before the momentum to create such a standard makes it happen?

Photo of Deborah Shaw

June 30, 2014 in consumer protection, cybercrime, data security, privacy | Permalink

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June 23, 2014

Do Consumers REALLY Care about Payments Privacy and Security?

Consumer research studies have consistently shown that a top obstacle to adopting new payment technologies such as mobile payments is consumers' concern over the privacy and security protections of the technology. Could it be that consumers are indeed concerned but believe that the responsibility for ensuring their privacy and security falls to others? A May 2014 research study by idRADAR revealed the conundrum that risk managers often face: they know that consumers are concerned with security, but they also know they are not active in protecting themselves by adopting strong practices to safeguard their online privacy and security.

The survey asked respondents if they had taken any actions after hearing of the Target breach to protect their privacy or to prevent credit/debit card fraudulent activity. A surprising 79 percent admitted they had done nothing. Despite the scope of the Target data breach, only 4 percent of the respondents indicated that they had signed up for the credit and identity monitoring service that retailers who had been affected offered at no charge (see the chart).

Consumers Post Breach Actions

In response to another question, this one asking about the frequency at which they changed their passwords, more than half (58 percent) admitted that they changed their personal e-mail or online passwords only when forced or prompted to do so. Fewer than 10 percent changed it monthly.

When we compare the results of this study with other consumer attitudinal studies, it becomes clear that the ability to get consumers to actually adopt strong security practices remains a major challenge. At "Portals and Rails, we will continue to stress the importance of efforts to educate consumers, and we ask that you join us in this effort.

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June 23, 2014 in consumer fraud, consumer protection, data security, identity theft, privacy | Permalink

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Consumers have been hearing "the horror stories around the campfire" for so long, they have come to believe that if the "boogieman" is going to get you, there is nothing you can do about it. However, this is just not true. The FSO industry needs to promote consumer education efforts to update the public: we are each provided options every day that can serve to reduce our exposure to the fraud/ID theft boogieman - at FraudAvengers.org we call it "anti-fraud activism". Once aware, consumers will find themselves liberated to make choices based on their own risk tolerance about: how they make and receive payments; how they use their communication devices; the places in which they voluntarily place their personal information; ways and frequency of monitoring their financial, medical and other personal records; who and how they do business with people they have never met and/or do not know; etc. By ensuring we always include the "lessons learned" after we tell our horror stories, we serve to educate the public and inform them of protective actions they can take in their own defense. Crime collar criminals are always looking for victims: by reducing one's visibility to them and by proactively knowing what to watch-out for, consumers can greatly reduce the likelihood of becoming victims.

Posted by: Jodi Pratt | June 23, 2014 at 03:19 PM

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April 28, 2014

Is Personal Data Privacy Going, Going, Gone?

Since last December, it seems that not a week has gone by without a headline about another breach of consumers' payment or personal data. These articles—which are no longer limited to banking or IT industry publications—have created both weariness and concern among consumers. The market research firm GfK conducted a national survey of U.S. consumers in March 2014 to measure the impact of these breaches and better understand how consumers view and manage their personal data. They surveyed 1,000 individuals over the age of 18 and sorted the results by generation. Some of the findings I found most interesting were:

  • All generations are concerned about the protection of their personal data and, overall, 59 percent indicated that their concern has risen over the last 12 months.
    Question: Are you concerned about the protection of your personal data?
  • One-third of the survey participants indicated that they had been the victim of the misuse of their personal data at least once over the past year.
  • Over half (54 percent) of those surveyed don't believe the U.S. government is doing enough to protect their data, with two-thirds of the pre-boomers taking that position.
  • Overall, 80 percent of the respondents believe there should be additional regulations preventing organizations from reselling their personal data to third parties.
  • There is a strong demand from consumers for all consumer-facing industries to change their data privacy and personal data usage policies, but that demand is the highest for credit card companies and social networks.
  • Banks are in the top four trusted organizations regarding the protection of personal data but trailing health care organizations, online payment systems, and online retailers. Social networks, international businesses, and marketers and advertisers are the least trusted.
  • Although more than half of the participants do not agree with the tracking or recording of communication data without their permission, younger generations are not as concerned.
    Agreement with the statement: I accept that my communications data (e.g. phone, online) can be recorded without my approval to prevent crime.

So how are consumers behaving in light of this increased concern? Almost half (48 percent) indicated that they have changed their online practices and are avoiding the use of online auctions, online banking, and online social networks to reduce the likelihood that their personal data might be compromised or misused in some way. I have seen other research indicating that as much as 40 percent of a retailer's customers that have had their personal data compromised through a breach at that retailer will avoid that retailer, at least in the immediate term.

So what is the best approach to develop and maintain safeguards for consumer's personal information and transaction data? The private sector has always championed self-regulation through standards efforts such as PCI-DSS, but we all recognize that being compliant with a common minimum standard is not the same as being totally secure. There has been no shortage of recent congressional discussion on this issue, and future major breaches will likely add to the momentum such that it will be difficult to stop. Is that where you think we are headed—a regulatory fix coming from a legislative mandate? Let us hear from you.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 28, 2014 in consumer fraud, consumer protection, data security, regulations | Permalink

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The Target breach, in which 110 million Americans lost critical personal and financial data, is just the latest problem caused by extending legacy payment networks built in the 1960s to internet originated payments.

In the classic New Yorker cartoon, one dog says to the other, "On the Internet, nobody knows you're a dog." Until we solve this problem, the legacy payment networks cannot be made secure. They were not architected with security built into them to do what we are doing today by extending them to payments generated from the internet. The security of any network is only as good as its weakest node. By moving access to the legacy payment systems to the internet, we added tens of millions of nodes to each legacy payment system and most of those nodes are not securely authenticated or truly secure.

A next generation payment system is required that is architected with security and encryption of all data "end to end", with no data ever “in the clear” and in which all users are "strongly authenticated". It is less expensive by orders of magnitude to build a new next generation payment system that can do that, than to retrofit one of the existing legacy payment systems, as I was once told by the former global CIO of VISA International. The existing legacy payment systems are all designed to have required information "in the clear" at multiple points in the transaction cycle.

The rapid rise of Bitcoin, despite its significant flaws, highlights the hunger in the marketplace for a better and more secure internet based global payment system. It would be better if that next generation payment system was also bank-centric and properly regulated, none of which Bitcoin is.

FYI, the New Yorker cartoon was first published in 1994, so this problem has been building for over 20 years.

Posted by: Stephen Lange Ranzini | April 28, 2014 at 05:31 PM

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March 10, 2014

Who Is Responsible for Consumer Security Education?

A theme that consistently appears in our Portals and Rails blogs is the continual need for consumer education when it comes to protecting account access credentials. Financial institutions have generally taken this responsibility seriously, running frequent verbal and print campaigns reminding customers to safeguard their payment cards, monitor account activity frequently, and adopt strong password and PIN access practices.

But as payment channels and access devices expand outside the bank-controlled environment, who then becomes responsible for customer education? The representatives of mobile phone carriers and handset manufacturers, for example, are often in sales mode. The last thing they want to do is scare off a potential sale by identifying the potential for fraud with their product or service.

When I recently went to purchase a new mobile phone that was equipped with a number of strong security safeguard options, the sales representative was more interested in selling me high-margin accessories than telling me how to safeguard the phone and its contents. While I understand the motivation of the sales representative, especially if he works under a sales incentive compensation plan, wouldn’t it easy for the carrier or phone manufacturer to provide a brochure promoting safe practices?

Unfortunately for the financial institutions, the stakes are high. For them, the financial impact of fraudulent activity on a customer's account is often a one-two punch. First, various regulations and rules are in place to protect consumers from liability, so the financial institutions generally write off the fraud loss. Second, and perhaps more painful, victims of fraud often move their accounts even though their financial institution is not at fault. The challenge of consumer education by the bankers is becoming more and more difficult as the opportunity for direct contact with the customer lessens with every new payment transaction product or service.

As we've seen before, in the aftermath of recent card transaction and customer data breaches, the negative reputational and financial impact from fraud is felt not just by financial institutions but also by the retailer or company that was breached. Will such events cause these other stakeholders to take a more proactive role and join financial institutions in educating their customers?

Portals and Rails is interested in hearing from you as to how the payments industry might best address customer awareness and education regarding security.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

March 10, 2014 in banks and banking, consumer fraud, consumer protection, data security, mobile payments | Permalink

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February 03, 2014

Call Center Phone Fraud: Are You Really Who You Say You Are?

"Have I reached the party to whom I am speaking?" Lily Tomlin would use this line whenever she would play her character Ernestine the telephone operator on the classic TV comedy show "Laugh-In." But to the thousands of financial institutions that operate call centers, the question of whether their customer service representatives are talking to an actual customer is no laughing matter.

In a recent report on call center phone fraud, Pindrop Security cites a number of alarming statistics based on their clients' actual experiences: one in every 2,500 calls to a call center is fraudulent; the average fraud loss per call received is $0.57; and the average potential loss to an account from phone fraud is more than $42,000. It seems that the call center has become an increasingly attractive target for fraudsters.

A call from someone not authorized to access the bank account in question may not directly result in a financial loss on that call. In fact, Pindrop's research indicates that it takes an average of five calls before the fraudster gathers enough information to strike. They use those preliminary calls to gain account or customer information that will help them subsequently to generate a fraudulent transaction, whether it's through the call center or another channel. Some of the calls are from criminals who are simply trying to get account information such as credit and debit card information that they can sell to others. Some of the calls attempts to change account settings such as statement mailing address or call-back phone numbers. With a simple address change, the criminal can gain more information about the accountholder and also keep the victim from being alerted to fraud on their account. Often, a call that results in a direct loss occurs when the fraudster obtains sufficient account credentials to generate a fraudulent wire transfer or ACH transfer from the targeted account.

While these criminals might be looked at as "low-tech hackers" compared to the sophisticated hackers who probe computer systems or worse, the evidence from law enforcement shows that these groups are just as well-organized and sophisticated. They are often based outside the United States, which makes investigations and prosecutions difficult. Sometimes they use technology to change their voice or to show a fake phone number on the bank's caller ID system. The fake phone number helps the fake caller avoid suspicion when the call is coming from outside the customer's area of residence.

To address this growing attack vector, financial institutions are adopting new technology to help them detect potentially fraudulent calls. Voice biometric technology can detect altered voices or even compare the caller's voice to a database to verify the caller's legitimacy. In addition, phone call and device "fingerprinting" gathers enough information from the caller's device to allows the call to be scored, just like a card transaction, on how likely it is to be fraudulent.

It is clear that criminals are attacking all physical and virtual channels of banks, sometimes using information obtained through one channel to carry out fraud in another channel. Portals and Rails believes it is important that you approach your fraud mitigation strategy from a cross-channel perspective. Please let us hear about your challenges and successes with such efforts.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

February 3, 2014 in authentication, banks and banking, consumer protection | Permalink

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January 21, 2014

Online Payday Lenders: An Illustration of the Importance of Bank Due Diligence

3-legged stool Because of a series of incidents involving illegal payday loans, online payday lenders have been featured in news articles of late. They've also been the focus of increasing enforcement actions to ensure that adequate consumer protection is in place. States are stepping up their enforcement actions against online payday lenders that violate state laws, and federal regulators are stepping up enforcement of federal and state laws. Meanwhile, online lenders and their third-party payment processors are defending their roles in providing this borrowing option to consumers.

The recent uptick in attention on online payday lenders is an impetus for us to stress the importance of banks conducting their due diligence process for any payment processor or business for which they provide payment services. It's useful to look at this due diligence as a three-legged stool, with regulatory compliance, know your customer (KYC), and know your customer's customer (KYCC) all working together to keep the stool upright.

In an August 2013 post, we examined the risks incurred by banks that originate payments for online payday lenders. Much debate has focused on whether online payday lenders—and those who provide services to them—are unfairly targeted by regulators and enforcement agencies. The reality is that businesses that comply with state and federal law are not the reason for increased guidance and enforcement.

When it comes to online payday lending, the law—one leg of the stool—is quite complex. At the state level, laws can significantly differ from state to state. Some states, including Georgia, do not even allow online payday lending. But many online payday lenders operate virtually, and are therefore more likely to operate nationally, which can add to the confusion about complying with all relevant state and federal laws. When conducting their due diligence processes, banks should always consider their customers' ability to operate within the law.

KYC and KYCC are also two very important components of a bank's due diligence process with any customer for which they originate transactions. The better the bank understands the business lines of its originator from the very beginning, and the better they understand it over time by way of continuous monitoring, the greater their chance to quickly identify and address any problems.

Like any business, online payday lenders can use the services of a third-party payment processor. As we explained in a September 2013 post, payment processors are a bank's direct customer in providing payment services to businesses . This adds another layer to the bank's due diligence processes. With this kind of relationship, banks now need to know their customer's customer—in this case, the online payday lender.

Banks should use the recent attention to online payday lenders as a reminder to review and improve their due diligence practices for all their customers. They should make sure that all three legs—KYC, KYCC, and compliance with the law—are in place so that the stool doesn't topple.

What lessons has your bank learned from the recent attention to payday lenders?

Photo of Deborah ShawBy Deborah Shaw, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

January 21, 2014 in banks and banking, consumer protection | Permalink

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January 13, 2014

Into the Breach: Protecting the Integrity of the Payment System

The breach of Target's point-of-sale system that compromised up to 40 million cardholders during the 2013 holiday shopping period has prompted us to step back and examine this attack—and wonder about its aftereffects. We've certainly seen the expected media attention for a crime of this magnitude, and the filing of class-action lawsuits wasn't far behind despite the lack of any verifiable fraud—as yet. We also have to wonder about its effect on consumers' confidence in the U.S. payment system.

For consumers to have confidence in the payment system, it is critical that they feel their financial information is protected during a payment transaction. And when that information has to be stored, they need to know that it is stored safely and securely. The research shows—and many consumers are well aware—that the creation of synthetic or stolen identities depends primarily on information obtained from data breaches.

All kinds of consumer advice followed the data breach. Many consumer advocates advised cardholders who had used their debit card at Target during the time their POS system was compromised to go to their financial institutions and request a card reissuance to prevent possible fraud. Others focused not on how consumers might recover from the Target breach but on how to prevent problems in the future—that is, they suggested that consumers use credit cards rather than debit cards because with credit cards, unauthorized transactions will not affect the payment of legitimate transactions. Some advocates suggested that people authenticate their debit cards at POS terminals with their signatures rather than their PINs, despite the fact that the level of PIN-based debit card fraud is almost one-third the level of signature-based debit card fraud.

Financial institutions also had varying responses. Some reissued cards when customers requested new cards, while others took a wait-and-see attitude. Still others lowered transaction limits on their customers' debit cards to minimize fraud exposure.

Of course, the Target incident has heated up the magnetic-stripe-versus-EMV conversation. As we've posted many times, the magnetic stripe was never intended to be a secure medium; the sophisticated and highly automated authorization systems were intended to carry the load of fraud detection capabilities. Some in the U.S. payment industry are calling for an acceleration of the migration to chip cards, currently scheduled for October 2015. They argue that EMV/chip cards will virtually eliminate the ability to create counterfeit cards. Some are even requesting that the government or the card networks mandate the technology, which many other countries did in their transitions to EMV. However, the reality is, we will have to keep our magnetic-stripe cards a minimum of five to 10 years, until the vast majority of merchant locations are equipped with EMV-capable terminals. And we should keep in mind that EMV is not a solution by itself—it cannot address card-not-present fraud.

As the authorities complete the forensics of the recent data breach, the industry will develop and implement additional security controls and measures. This added security will then prompt the criminals to look for other weak points. And look they will. So has this major incident shaken consumers' confidence? It is too early to know. What is clear is that the payments industry must come together to develop a cohesive strategy, and they should do so before consumer confidence in the payments system is further compromised.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

January 13, 2014 in consumer fraud, consumer protection, debit cards, EMV | Permalink

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As the number of consumers affected by the Target breach has risen to 110 million and news of the Neiman Marcus and Michaels breaches surface, much discussion about improving card security has been sparked—including the adoption of EMV technology. While EMV is not the perfect solution, it is only a matter of time before the costs of fraud in the U.S. begin to outweigh the cost of implementing EMV cards or another innovative technology that works within our existing infrastructure. The tipping point may be here for banks to take a step in a new direction to better address card security in the U.S.

Posted by: Karen Gordon | January 28, 2014 at 04:56 PM

Why is the U.S. so behind Europe and Asia in adopting EMV in place of magentic stripe?

Do you think accelerating the migration to chip cards will happen?

Posted by: Saba H | January 21, 2014 at 09:21 AM

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November 12, 2013

Is Consumer Privacy Possible?

In January 1999, Scott McNealy, then chief executive officer of Sun Microsystems, told a group of analysts, "You have zero privacy anyway. Get over it." His comment caused quite a stir—at the time, most people had not yet heard the terms "big data," "data warehousing," or "data analytics."

I recently attended two conferences that had sessions on consumer privacy and data collection. All the panelists suggested that there is little data privacy for consumers anymore. And all agreed that "privacy is dead."

Four major forces have brought us to this point: technology advances, emergence of data aggregators, lack of transparency with consumers, and consumer complacency. The first force—advances in the technology of data storage—has created the environment for the other elements. The capacity of hardware to collect and store data has grown at exponential rates at the same time that the cost of that technology has plummeted. A cost analysis from Statistic Brain shows that the cost of storage per gigabyte of memory has dropped 50 percent every 14 months since 1980. Back then, a gigabyte of data storage was priced at about $438,000. Today, the price for storing a gigabyte is a mere nickel.

With the ability to store vast amounts of data so inexpensively, companies have built data warehouses to collect all types of data, ranging from government records to of consumers' product purchases at merchant locations Proponents of the data analytics business emphasize how their work can help identify fraudulent transactions through behavior anomalies and how it can help a company market more effectively. Privacy advocates express concern over how the information is used and the adequacy of safeguards to protect the data from unauthorized access.

Privacy advocates contend that most consumers have no real understanding of the information that is collected and how it is used. Indeed, disclosures are often hidden in fine print. Consumers often must accept the terms of a transaction to receive the product. How often do you click the accept box without reading the disclosure?

With support from the Federal Trade Commission, advocacy groups are working to get companies to make their consumer disclosures clearer so consumers will know exactly what information is being collected, how long it is retained, and who it is being shared with. They also want these data collectors to disclose how consumers can verify the accuracy of the information.

Are you interested in knowing what information the largest data aggregator company in the United States has on you? If so, go to Acxiom's website and scroll to the bottom of the page. You will need to register to look at your profile.

Although consumers themselves are the major source of the data being collected, many may not understand that the information they voluntarily provide on social media sites and through online browsing and purchasing activities is being tracked and collected. And consumers have consistently demonstrated a willingness to provide personal information to secure a coupon or discount.

In addition, with the increased deployment of smartphones, merchants are looking to use the mobile channel for one-to-one marketing. The success of this effort largely depends on knowing the interests of the phone owner. Such determination is made only through data collection and analytics—and these efforts are only going to intensify. This marketing element available through the mobile phone is seen as an advantage over other payment methods, and many are studying how to monetize it.

Even if the most transparent disclosures were available, do you think consumers would dramatically change their information-sharing behavior, especially when doing so would come at the expense of incentives? Or of not expressing their personal interests and posting events on social media sites? Personally, I do not think so. I believed McNealy back then and took his advice to get over it. What about you?

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

November 12, 2013 in consumer protection, data security, privacy | Permalink

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October 28, 2013

New Portals: Established Rails

Rails Do consumers understand that the consumer protection rules that apply to a mobile payment depend on the payment source—such as a debit or credit card—and not the portal—the mobile device? Purchasing goods and services using a mobile device appears to be a brand new way to make payments. But the mobile device is merely a new portal that leads to the same underlying rails: traditional retail payment sources.

Mobile wallet applications, whereby the consumer can access payment options through a mobile device, are typically sourced to the consumer's debit or credit card. The mobile carrier's billing option allows the consumer to charge an inexpensive product directly to the mobile phone bill. The consumer then pays that bill using a traditional method, such as a check. A Federal Trade Commission study of payment funding sources for 19 mobile providers in 2012 reports payment by credit or debit cards as the most common payment type, with 15. Next are bank account debit (7), multiple funding sources (7), then billing to a mobile carrier account (4).

It is important for financial institutions to educate their consumer customers about the rules and regulations related to traditional retail payment sources that support mobile purchases. Consumers should know about the mobile wallet, for example. Consumers can "carry" many payment sources in their mobile wallets, but they should be aware that each source has different consumer protection provisions. For example, the time periods for reporting disputes and liability limits are different. Education by banks can reduce confusion about the process consumers must follow if they experience a problem with any purchases. Additionally, education can make consumers more aware that the rules that apply to card payments, for instance, apply whether they make the payment in person, on the phone, online, or with their mobile devices.

Banks are in a critical position to be able to share their expertise on traditional retail payment sources as consumers increase their usage of the mobile device to initiate payments. How is your institution educating consumers about mobile payments?

Photo of Deborah ShawBy Deborah Shaw, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

October 28, 2013 in consumer protection, mobile payments | Permalink

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September 30, 2013

Securing All the Links in the Chain: Third-Party Payment Processors

Consumers may not know when a payment transaction involves more than the merchant who they buy from and the bank that has the debited account. They have no reason to know that there are often other "links" in the payment processing "chain." One such link is the third-party payment processor (processor).

The processor works between the business and the bank, providing payments services to the business while serving as a connection point to the banking system. The processor facilitates automated clearing house, or ACH, payments; credit, debit, and prepaid card payments; and remotely created check payments.

Banks that have processors as their customers must be careful to minimize the risk associated with adding another link to the payments process. Central to this risk mitigation is for the bank to conduct due diligence, including "know your customer" (KYC)—in this case, the processor—and also "know your customer's customer" (KYCC)—in this case, the businesses on whose behalf the processor is transmitting payments. Regulators, including the Federal Deposit Insurance Corporation and the Office of Comptroller of the Currency, have published and updated guidance emphasizing the essential importance of banks' risk-based management of their processor relationships.

Bank risk mitigation includes taking steps at the time of onboarding new processors as well as on an ongoing basis to monitor for any problems related to changes in those relationships. Recommended practices during onboarding include verifying the legitimacy of the business by visiting the processor's office and reviewing marketing materials and websites. It is essential that the bank understand the business lines that the processor's customers support and be aware of any payments-related concerns. For example, processors should provide the bank information on any law enforcement actions and consumer complaints related to its customers.

A bank's ongoing monitoring should include knowing about changes with either the processor or its business customers. Requiring the processor to inform the bank of new customers or business lines is one way to identify developments that require further study. Banks should also require processors to report any changes in the nature of consumer complaints, particularly if they include claims of unfair and deceptive practices that a business customer may have used. Monitoring for warning signs of potential fraud can be aided by receiving reports from the processor on its return rates and those of its business clients. High return rates for certain reasons, such as unauthorized or insufficient funds, should be investigated for the underlying cause and then addressed with the processor.

Furthermore, banks are advised to keep their board members aware of processor relationships by providing periodic reporting on transaction volumes, return rates, and types of businesses served.

Banks that focus on securing the processor link in payments transactions will mitigate their risk, support the payment efficiencies that processors bring to their merchant clients, and protect the payments system for the benefit of consumers.

We would like to hear what processes your institution has in place to monitor processors.

Photo of Deborah ShawBy Deborah Shaw, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

September 30, 2013 in banks and banking, consumer protection, risk management | Permalink

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