Take On Payments

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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

June 01, 2015


Follow the Money

This blog is inspired by Jack Weatherford's The History of Money, and I'll open with a quote from the book's introduction, attributed to Gertrude Stein: "The thing that differentiates man from animals is money." Now I'm guessing most of us can think of a few more distinctions than that, but I will wager her item would make just about any top ten list.

In his book, Mr. Weatherford discusses three generations of money, noting that today's free market systems saw their genesis in Lydia several millennia ago with the advent of coins. He credits the invention not only with leading to our free market systems but also with destroying "the great tributary empires of history." In other words, money can build new, mighty things and fell that which was once mighty.

Mr. Weatherford describes the second generation of money as beginning in Italy with the Renaissance and moving through the Industrial Revolution. What emerged in this turning was paper money and banking and what fell was feudalism, "changing the basis of organization from heredity to money," with ownership of land supplanted by ownership of stocks, bonds, and the like. In other words, modern capitalism took hold and society evolved into something very different from what it had been.

He describes stage three as electronic money and the virtual economy. Instantly, we recognize the current age. In the way he presents the history, he makes a compelling case that noteworthy evolution and reinvention of money changes the world.

"Fascinating," you might say, "but so what?" Before suggesting an answer, I point out that Mr. Weatherford published this work in 1997. Nevertheless, presciently, he said, "A new struggle is beginning for the control of [money]... We are likely to see a prolonged era of competition during which many kinds of money will appear, proliferate, and disappear in rapidly crashing waves. In the quest to control the new money [emphasis mine], many contenders are struggling to become the primary money institution of the new era."

Indeed. So, I get to my answer. At the moment, one of the focal points for many payment wonks is making platforms "faster." A lot has gone into that already, and much more seems yet to come. A key risk if not the chief risk in this endeavor is ending up with an industry focus that is too narrow (platforms only). It could cause key payment participants to end up missing an important change—in money—not the mechanisms for moving it.

As work progresses to reach consensus on what and how to improve the extant payment mechanism, it seems good to pause and make sure the focus. Pursuit of a purely faster mechanism that envisions world monetary systems continuing to be based on the things they've been based on for centuries now could cause us to overlook or miss the next evolution of money. It would have been of little use to invest in improving the systems for speeding the exchange of cowrie shells as the turn was made toward paper money and banking. I think that to get this right, it is important to worry less about improving the system(s) for facilitating exchange, and more about what's going to be exchanged.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed

June 1, 2015 in emerging payments, innovation | Permalink | Comments (0)

May 18, 2015


A Presumption of Innocence

Presumption of innocence is a principle that goes all the way back to Roman law. This concept means that if reasonable doubt remains after the accuser presents his or her proof, then the accused must be acquitted. In the payments ecosystem, the guilty is defined as the party that the account holder or cardholder has not authorized to conduct a transaction on that account or card. According to the 2013 triennial Federal Reserve Payments Study, the estimated number of unauthorized ACH transactions in 2012 reached a total of $1.2 billion.

With dollar stakes so high, reaching a guilty verdict when fraud has been committed is important. What is the best due process to identify the guilty while ensuring the preservation of the rights of the accused?

In 2009, NACHA members passed a rule change requiring financial institutions (FI) to keep the percentage rate of unauthorized transaction returns below 1 percent per originating company. If an originating company reaches the unauthorized return threshold, NACHA will contact the originating FI to investigate and resolve any potential issues that can lead to rules violations and fines. Some of the reasons an ACH transaction can be returned unauthorized include the following: the entry amount is different than the amount that was authorized, the debit was processed earlier than authorized, the transaction was fraudulent, the transaction sender is unrecognized, the check conversion was done improperly, or a previous authorization has already been revoked. Unauthorized transactions can even be a result of the receiving party committing the fraud, by reporting the transaction as unauthorized but still in receipt of goods and services. The rule change set an expectation that FIs would monitor unauthorized returns received for each originating company name over a two-month period.

Monitoring for unauthorized activity unveils a number of payment issues, but there are more opportunities to identify the guilty. The ACH operator provides unauthorized return rate data, representing returns coded properly with NACHA’s unauthorized return reason codes (R05, R07, R10, R29 or R51). If a disputed transaction is improperly coded or returned with a different code, the transaction would not factor into current unauthorized return monitoring. Regulation E provides consumer protections that require FIs to provide error resolution beyond the NACHA return deadlines and therefore such disputed transactions will also fall outside unauthorized monitoring, unless the FI manually adjusts return counts. Additionally, unauthorized transactions are sometimes quickly returned under the codes for "insufficient funds, "invalid account" or "unable to locate an account." These codes should also be monitored in order to uncover guilty originators.

Effective September 18, 2015, a new NACHA rule will lower the unauthorized transaction return rate to half a percent. In addition two new thresholds will be introduced to monitor other return reason codes that can unveil guilty originators while improving overall network quality. Thresholds are meant to provide a red-flag approach to return monitoring. However, return rates over or near the threshold should trigger investigation and due process before a final verdict is rendered.

By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

May 18, 2015 in regulations | Permalink | Comments (0) | TrackBack (0)

May 11, 2015


The Hill Tackles Cybersecurity

In a post last month, Take on Payments highlighted recent cybersecurity-related executive orders. Cybersecurity has been a hot item inside the Beltway in 2015, and the activity hasn't been limited to the executive office. Beginning on April 22, the House passed two separate cybersecurity bills. And now all eyes are on the Senate, as it looks like a vote on its own cybersecurity bill is set to take place later in May. Today's Take On Payments post will highlight the two House bills recently passed by the House and the Senate's bill under consideration.

Protecting Cyber Networks Act (H.R. 1560)
This bill encourages the timely sharing of cyber threat information among private entities, nonfederal government agencies, and local governments. It provides businesses liability protection for sharing cyber threat indicators when taking reasonable efforts to remove personally identifiable information (PII). The bill also allows the federal government (excluding the National Security Agency and Department of Defense) to share cyber threat information with private entities, nonfederal government agencies, and local governments. To further promote and protect individual privacy, it requires that the Department of Justice (DOJ) periodically review the information shared to ensure that PII is not being received, used, or disseminated by a federal entity. Finally, this bill directs the Cyber Threat Intelligence Integration Center (CTIIC), under the direction of the Office of the Director of National Intelligence, to serve as the primary organization to analyze and integrate all intelligence shared.

National Cybersecurity Protection Advancement Act of 2015 (H.R. 1731)
The purpose of this bill is to also encourage information sharing of cyber related risks among the private sector and government. Unlike its companion bill, which directs the CTIIC as the overseer of the information-sharing program, this bill authorizes the Department of Homeland Security (DHS) to do so. In order for the DHS to serve in this capacity, the bill expands the composition and scope of the DHS national cybersecurity and communications integration center to include additional parties, namely private entities and information-sharing and analysis centers, among its non-federal representatives. As with H.R. 1560, the bill has provisions to protect individual privacy and requires that the DHS performs an annual privacy policies and procedures review. As with its companion House bill, liability protection is afforded to parties sharing information.

Cybersecurity Information Sharing Act (CISA) of 2015 (S. 754)
The Senate's version of cybersecurity legislation is a companion bill to the two recently passed House bills and combines tenets of both of them. It's viewed as an information-sharing bill, with the DHS serving as the federal entity responsible for overseeing the sharing of data between the government and private sector. The DOJ is responsible for ensuring that privacy and civil liberties are upheld within the information-sharing program. As with the House bills, liability protection is provided to all entities sharing information.

The goal of information sharing featured in these bills is the hope both government and private sector would benefit. As evidenced by the participation of a significant number of financial institutions (FIs) with the Financial Services Information Sharing and Analysis Center, many FIs are seeing value to sharing cybersecurity information within their own sectors. Additionally, the Retail Industry Leaders Association established the Retail Cyber Intelligence Sharing Center earlier this year to share cyber threat information between retailers and law enforcement. Whether or not these bills accomplish the goals of creating a private environment to safely share cybersecurity information and risks, I think the payments industry and other private industries would benefit from sharing information among themselves and with government and law enforcement agencies.

Photo of David Lott By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

May 11, 2015 in collaboration, consumer protection, cybercrime, law enforcement, regulations | Permalink | Comments (0) | TrackBack (0)

May 04, 2015


Keeping Up with the Criminals: Improving Customer Authentication

The interesting thing about authenticating customers for checks and PIN-based debit transactions is that the customer's authentication credentials are within the transaction media themselves—a signature, a PIN. But for the rest of the transaction types, authentication is more difficult. The payments industry has responded to this challenge in a few different ways, and may be turning increasingly to the use of biometrics—that is, the use of physical and behavioral characteristics to validate a person's identity.

Improving customer authentication in the payments industry has been a focal point for the Retail Payments Risk Forum since its formation. After all, authenticating the parties in a payment transaction efficiently and with a high level of confidence is critical to the ongoing safety and soundness of the U.S. payments system. We have intensified our focus over the last two years, including holding a forum on the topic in mid-2013. The Forum has also just released a working paper that explores the challenges and potential solutions of customer authentication.

The working paper examines the evolution of customer authentication methods from the early days of identifying someone visually to the present environment of using biometrics. The paper reviews each method regarding its process, advantages and disadvantages, and applicability to the payments environment.

Much of the paper looks at biometrics, an authentication method that has received increased attention over the last year—partly because smartphones keep getting smarter as folks keep adding new applications, and as manufacturers keep improving microphones, cameras, accelerometers, touch sensors, and more.

The table lays out six key characteristics that we can use to evaluate a biometric system for a particular application.

New_characteristics_table

The use of biometrics will be the subject of an upcoming forum hosted by the Retail Payments Research Forum later this fall, so stay tuned as we finalize the date and agenda. In the meantime, if you have any comments or questions about the working paper, please let us know.

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

May 4, 2015 in authentication, biometrics, emerging payments, innovation, mobile banking, mobile payments, risk management | Permalink | Comments (0) | TrackBack (0)

April 27, 2015


Not Seeing a Tree for the Forest

For this blog's title, I confess to having pineapple-upside-down-caked the common adage "missing the forest for the trees." The thing is, I want to point to a particularly nice tree in the same day ACH (automated clearinghouse) forest. By torturing the adage I hope to inspire folks to deviate from the basic, same day forest flyover and focus on one tree. It seems to me it has not gotten all the attention due.

Those advocating for same day ACH generally tout the increased functionality or the economic benefits of the latest proposal. Another oft-mentioned benefit of the proposed rule change is that it may provide a bridge from today's payments to those of the future. However, tucked into the lush same day ACH forest is a hard-to-find risk abatement species. Allow me to point out some of its features.

Settlement—By reducing the settlement window, same day ACH reduces credit risk associated with the network ecosystem—both in terms of the length of time counterparties are exposed to settlement risk and, potentially, the total amounts of settlement risk. For sure, financial institutions will have more flexibility to better manage these circumstances.

Operations—Same day ACH provides additional processing windows that result in risk reduction opportunities. Operations managers gain the means to load balance or smooth processing volumes and may also be able to ease the pressure on deadlines. The additional processing windows can be thought of as de facto contingency alternatives and seem likely to yield a corresponding increase in reliability and quality for the ACH.

Returns—Expedited settlement means expedited return handling. same day ACH would provide the opportunity for receiving banks to return same day payments on that same day. Moreover, because return requirements are tied to settlement, any same day payment that needs to be returned to an originating bank will be received one banking day earlier than would have occurred without same day settlement. NACHA points out that exceptions may be identified sooner and returned sooner, which means resolution for more problems may begin sooner. They have described this as "a 'win-win' for all parties." It's hard to argue the point.

If it passes, same day ACH will improve the risk posture of financial institutions, benefiting both ACH payers and payees. As spring continues to unfurl, perhaps some of you will get to stroll through the woods. If you come across a particularly handsome dogwood or perhaps an eastern redbud, be reminded that the same day ACH ballot will pop later this spring. I'm keeping my fingers crossed that the woodsmen don't get to clear cut the forest this time and we don't lose any of the nice trees.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed


April 27, 2015 in ACH, risk management | Permalink | Comments (0) | TrackBack (0)

April 20, 2015


Fed Survey Shows Mobile Banking on Rise in Southeast

In August 2014, the Retail Payments Risk Forum conducted a mobile banking and payments survey of financial institutions in the Sixth Federal Reserve District. (The Sixth District comprises Alabama, Florida, Georgia, and portions of Louisiana, Mississippi, and Tennessee.) The Federal Reserve's Board of Governors has annually conducted a national survey of mobile financial services for the last four years from the consumer perspective. We conducted this inaugural survey to determine the level and type of mobile financial services offered by financial institutions (FIs) in our region. (At the same time, the Federal Reserve Banks of Boston, Dallas, and Richmond conducted an identical survey of the financial institutions in their districts. (So far, only the results of the Dallas District's survey are available.)

Of the 189 validated responses, 75 percent were from banks and 25 percent from credit unions (CUs). Six of the respondents (five banks and one CU) indicated that they did not currently offer nor had any plans to provide mobile banking services. The two most important reasons given by the FIs for not offering the service were security and regulatory concerns.

The full survey report is available on the Retail Payments Risk Forum website, but some of the key findings from the survey include:

  • While mobile banking was first launched in the United States in 2007, it is a relatively new service for many FIs in the Sixth District. Almost 23 percent launched it within the last year, and an additional 15 percent are planning to offer mobile banking within the next two years.
  • The primary reason FIs selected for offering mobile banking was to retain customers. Some saw it as an opportunity to gain new customers.
  • There is very little difference in the basic mobile banking functions that banks and credit unions offer.
  • Sixth District FIs use more than 30 mobile banking application vendors, although there is a large concentration with three of these providers.
  • Despite the current headlines, the respondents expressed little to no interest in using biometrics and tokenization. (But note that the survey was conducted before the Apple Pay rolled out.)
  • Security concerns related to identity theft, data breaches, malware, and poor customer security practices remain primary concerns of FIs.
  • With the possible exception of the remote deposit capability, FIs do not expect to charge customers for mobile banking or payment services.
  • The mobile payments environment is nascent and highly fragmented in both the number of vendors and the wide range of technologies. This fragmentation has created some inertia while the FIs wait for the environment to sort itself out.

The Retail Payments Risk Forum plans to conduct this survey every two years in order to measure changing penetration and attitudes. If you have any questions concerning the survey results, please contact me via e-mail.


April 20, 2015 in mobile payments | Permalink | Comments (0) | TrackBack (0)

April 13, 2015


Leaving a Cybersecurity Legacy

On April 1, the current administration's fourth executive order related to cybersecurity was signed into action. This executive order shows an ongoing commitment to securing cyberspace. In 2009, the executive office released its Cyberspace Policy Review, which triggered a flurry of cybersecurity policy. (Relatedly, the government's "Buy Secure" initiative to increase payment security mandated the issuance of chip-and-PIN cards for all federal employees and benefits programs beginning in January 2015.) This week, Take On Payments summarizes the four cybersecurity-related executive orders that have ben signed over the last six months and what these orders could mean for the banking and payments industries.

Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities (4/1/15)
Authorizes swift and severe sanctions by the Treasury Department to those engaged in malicious cyber activities that pose a significant threat to national security, foreign policy, economic health, or the financial stability of the United States. This action occurs regardless of where the offenders are domiciled, and can include the freezing of assets and denial of entry into the United States for individuals and entities. These malicious activities include, but are not limited to, distributed denial-of-service (DDOS) attacks and misappropriation of financial information for financial gain. According to an insider, attacks on banks and the financial sector, including the unauthorized access of payment credentials, would likely qualify as significant enough to warrant these new sanctions. While critics debate the enforceability of these sanctions, the banking and payments industry should find this development promising. Law enforcement is often challenged to bring these individuals to swift justice.

Promoting Private Sector Cybersecurity Information Sharing (2/13/15)
Encourages the Secretary of Homeland Security to establish information sharing and analysis organizations (ISAOs) as well as standards and guidelines to establish a robust information-sharing network related to cybersecurity incidents and risks. ISAOs can be organized on the basis of multiple attributes, including industry sector or region. Information sharing would take place both within and across ISAOs. Although the financial services industry has had some success with information sharing within their sector through organizations such as Financial Sector-Information and Security Center, the private sector generally remains challenged to share information across sectors. We hope this order will lead to the development of standards and better coordination to allow for information sharing of cybersecurity incidents and risks between the financial services sector and other industries.

Improving the Security of Consumer Financial Transactions (10/17/14)
Although cybersecurity wasn't the main focus of this executive order, two cybersecurity components are included in it. The first relates to the remediation of identity theft. It specifies that the Attorney General will issue guidance to promote regular submissions by federal law enforcement agencies of compromised credentials to the National Cyber-Forensics and Training Alliance (NCFTA) Internet Fraud Alert System. Secondly, the order requires that all federal agencies that make personal data accessible develop a plan to implement multifactor authentication. While directed towards federal agencies, it is possible that this order will pressure financial institutions and other private industry entities within the payments industry to adopt similar compromised credential submission and multifactor authentication practices, if they have not already.

The current cybersecurity activity isn't just limited to executive orders. Several cyber-related bills have circulated the congressional floor the past several years. A future Take On Payments post will highlight several bills that have been introduced in 2015 on Capitol Hill and what they could mean for banking and payments.

Photo of Douglas KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 13, 2015 in cybercrime | Permalink | Comments (0) | TrackBack (0)

April 06, 2015


What Can Parenting Teach Us about Data Security?

My older child often asks if he can play at his friend's Mac's house. If his homework is completed, my wife and I will give him the green light, as we are comfortable with where he is heading. This level of comfort comes from our due diligence of getting to know Mac's parents and even the different sitters who watch the children when Mac's parents might be working late. Things often get more challenging when he calls to tell us that he and Mac want to go to another friend's house. And this might not be the last request as our son might end up at yet another friend's house before finding his way home for dinner. We might not be familiar with these other environments beyond Mac's house so we often have to rely on other parents' or sitters' judgment and due diligence when deciding whether or not it is okay for our son to go. Regardless of under whose supervision he falls, we, as his parents, are ultimately responsible for his well-being and want to know where he is and who he is with.

As I think about my responsibility in protecting my children in their many different environments, I realize that parenting is an excellent metaphor for vendor risk management and data security. For financial institutions (FI), it is highly likely that they are intimately familiar with their core banking service providers. For merchants, the same can probably be said for their merchant acquiring relationship.

However, what about the relationships these direct vendors have with other third parties that could access your customers' valuable data? While it probably isn't feasible for FIs and merchants to be intimately familiar with the potentially hundreds of parties that have access to their information, they should be familiar with the policies and procedures and due diligence processes of their direct vendors as it relates to their vendor management programs.

In today's ever-connected world, with literally thousands of third-party solution providers, it is necessary for FIs and merchants to be familiar with who all has access to their customers' data and with the different places this data resides. Knowing this information, it is then important to assess whether or not you are comfortable with the entity you are entrusting with your customers' data. Just as I am responsible for ensuring my children's safety no matter where or who they are with, financial institutions and merchants are ultimately responsible for protecting their customers' data. This difficult endeavor should not be taken lightly. Beyond the financial risks of fraud losses associated with stolen or lost data, businesses might also be subject to compliance-related fines. And you are highly likely to take a negative hit to your reputation. What are you doing to ensure various third-parties are protecting your sensitive data?

Photo of Douglas King By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed


April 6, 2015 in consumer protection, data security, KYC, risk management, third-party service provider | Permalink | Comments (0) | TrackBack (0)

March 30, 2015


Safely Motoring the Payments Highway

I've ridden a motorcycle for 30-plus years and, except for a slight bump from behind by a car when I was stopped at a four-way stop sign, I have a perfect safety record. Some say I'm lucky. While there is probably some element of truth to that—I've made it through a number of dangerous situations over the years—I believe my good safety record is largely because early on in my riding days, I invested in proper safety clothing and took classes in motorcycle riding skills and safety. In addition, when I've been out on the road, risk management has played an integral role in my safety: I follow the Motorcycle Safety Foundation's recommended practice of S-I-P-D-E: scan, identify, predict, decide, and execute.

I recently took advantage of an early spring day and rode the North Georgia back roads. Later that evening, when I thought back over my day, I couldn't help but think of the parallel between motorcycling risk management and payments risk management. To maintain a good safety record in both, you should practice SIPDE. Here's how SIPDE can work with payments.

Scan: Constantly examine the environment you are in. Don't focus on a particular payment method or channel or you will get target fixation and be likely to miss threats to other payment types. How often have we heard that while resources were focused on responding to a distributed denial of service attack, the criminals took advantage of the distraction and executed some unauthorized transactions? When riding, I try to always be alert and I constantly move my sight lines to spot any dangers.

Identify: As you conduct your examination, identify all potential risks. Some may be immediately apparent, and some may be hidden. Some may be major threats, and others less serious. While most of the criminal threats will come from external elements, don't forget about insider fraud.

Predict: After you have identified the risks, run through scenarios as to potential outcomes given a variety of circumstances. I sometimes change my lane position to increase my visibility and always cover the brake lever to prepare for that emergency stop. You must certainly consider the worst-case scenario, but don't forget that an accumulation of less-severe situations may result in a loss that is just as big.

Decide: After weighing all the options and the likelihood of their panning out, determine your course of action so that you're ready if one of the scenarios becomes a reality. Reaction time is critical with motorcycle riding and dealing with criminal attacks.

Execute: Put into motion that course of action to deal with the risk. This is where your training, skills, and tools come into play, helping you to properly and completely execute your plan.

Just as when I ride and the environmental factors and potential threats around me are constantly changing, such is the case in our payments environment. We must constantly use our S-I-P-D-E skills to assess and react to the environment, whether that's the road you're riding on or the payments environment you're operating in.

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


March 30, 2015 in consumer protection, risk management | Permalink | Comments (0) | TrackBack (0)

March 23, 2015


Balancing Security and Friction

Several weeks ago, my colleague, Dave Lott, wrote a post addressing the question "Does More Security Mean More Friction in Payments?" Having had several weeks to ponder this concept while attending multiple payments conferences and participating in similar discussions, I can say that I believe that securing payments does mean more friction. Friction may not be seen as good for commerce, but it can be good for security. An enormous challenge that those in the payments industry face is determining the right balance of friction and security. This challenge is heightened since consumers have a range of choices in payment types, yet do not often bear financial liability for fraudulent transactions.

It is absolutely critical to secure the enrollment or provisioning of the payment instrument on the front end. However, this introduces friction before a payment transaction is even attempted. And if consumers deem the process too onerous, they can reject that payment instrument or seek alternative providers. The recent media coverage of fraud occurring through Apple Pay highlights the challenge in the onboarding process. Consumers and pundits have raved about the ease of provisioning a card to their Apple Pay wallet through what they already have on file with iTunes. But fraudsters have taken advantage of this easy onboarding process. I should stress that this isn't just a mobile payments or Apple Pay problem—fraudsters are well-versed in opening bank accounts, credit cards, and other payment instruments using synthetic or stolen identities.

Let's assume that a person's payment credentials are in fact legitimate. Verifying that legitimacy introduces more friction into the payment process. A transaction that requires no verification obviously comes with the least friction, but it is the riskiest. Signatures and PINs bring a small amount of friction to the process, with very different results in terms of fraud losses. We don't know yet what kind of friction, if any, different biometric solutions create during both provisioning and the transaction. Issuers must enable the various forms of verification, and it is up to the merchants to implement solutions that will use various verification methods. Yet consumers, who bear less of the risk of financial loss from fraudulent transactions than the merchants, can choose which payment method, and sometimes which verification method, to use—and they often do so according to the amount of friction involved, with little to no regard for the security.

Issuers and merchants will offer the right balance of friction and security based on the risks they are willing to take and the investments they make in security processes and solutions. But it is the consumer who will ultimately decide just by accepting or rejecting the options. With limited or no financial liability, consumers are often willing to trade off security in favor of less friction—and the financial institutions and merchants have to bear the losses. So I'll ask our Take On Payments readers, how do you balance friction and security in this environment?

Photo of Douglas King By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed


March 23, 2015 in biometrics, consumer fraud, identity theft | Permalink | Comments (0) | TrackBack (0)

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