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.
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January 30, 2017
Pssst…Have You Heard about PSD2?
No, I'm not talking about the latest next-generation video gaming console. I am referring to the revised Directive on Payment Services (PSD2) that the European Parliament adopted in October 2015 and that will serve as the legal foundation for a single market for European Union (EU) payments. The original PSD was adopted in 2007 but, according to official statements, the Parliament found that an update was necessary to incorporate new types of payment services, improve consumer protection, strengthen payment transaction security, and increase competitiveness with an expected result of lower consumer fees in the payments processing market. PSD2 applies only to digital payments and must be in force in all EU countries by January 13, 2018.
The directive and subsequent implementation rules that the European Banking Authority* is developing make a number of major changes in the European banking landscape, including:
- Opens up the regulated financial services system to merchants and processors who might initiate payments on their consumer customer's behalf as well as data aggregator firms. In particular, PSD2 will apply to any financial institutions already operating within the scope of the PSD but will also apply to third parties such as operators of e-commerce marketplaces, gift card and loyalty plans, bill payment service providers, public communication networks, account access services, mobile wallets, and those who receive payment by direct debit.
- Requires financial institutions, upon the request of their customers, to allow these approved nonbank, third parties significant, but not unlimited, access to the customer's account and transaction data through APIs (application program interfaces). Many financial institutions see having to turn over customer data to potential competitors as a significant threat to the retention of their customer's business as well as concerns with data security.
- Sets out two-factor customer authentication as an absolute minimum, with additional security such as one-time passwords required for higher-value transactions. The card issuer must actively authenticate all transactions above 10 euros. Critics of these provisions point out that the criminals will have fixed transaction amounts and authentication methodology information to modify their attacks.
- Supplementing card interchange limits imposed in December 2015, prevents merchants from adding surcharges to payment card transactions. Under the original directive, each country established rules regarding surcharging on card payments. It has been a common practice of European merchants to levy a surcharge on payment card transactions to offset the interchange fee paid to issuers.
While such a comprehensive single package of regulations is unlikely to occur in the United States, various flavors of these items have been and continue to be discussed. Do you favor such types of regulation here in the United States? I suspect the answer depends on your role in the payments ecosystem. I am interested in hearing from you.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
* Final rules are expected to be published in January 2017.
January 23, 2017
Mobile Banking and Payments Survey Results
In the fall of 2016, the Atlanta Fed and six other Federal Reserve Banks asked financial institutions (FI) in their districts to participate in a survey to determine the level and type of mobile financial services they were currently offering or planning to offer. The Atlanta Fed conducted a similar survey in the district in 2014.
Financial institutions completed 117 surveys; they represent FIs of all sizes and types operating in the district (see chart below). The response rate of 8 percent should provide financial institutions with good directional information when comparing their own mobile banking and payments strategy. You can find the full report here. The Federal Reserve Bank of Boston will be preparing a consolidated report for all seven districts later this year.
Key learnings from the responses to this survey include:
- Mobile banking has become a standard service of financial institutions, with 98 percent indicating they currently or plan to offer mobile banking.
- Competitive pressure and the retention of existing customers are the primary reasons for offering mobile banking.
- Consistent with the 2014 survey and numerous other mobile research reports, FIs cite security concerns by consumers as the greatest barrier to mobile banking adoption.
- FIs identify biometric methodologies as the security tool most likely to be used in their program.
- Over half (59 percent) currently or plan to support at least one mobile wallet. Their primary reason for offering the service was competitive pressure as mobile payments appear to be gaining traction among some consumers.
- Most of the survey respondents have a long-term outlook (three years or more) for mobile payments to reach a customer participation level of 50 percent.
Supplemental results breaking the data into the six asset-size segments will be made available in early February. If you have any questions about the survey results, please let us know.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
January 17, 2017
Payments people start biting their nails when they hear "share more with more." They have been conditioned to keep payments information from ever being shared. But that is in the context of protecting legitimate payments system users from losing money while a fraudulent party benefits. At 7,000 members, the Financial Services Information Sharing and Analysis Center (FS-ISAC) is currently the largest financial services trade association in the world. I attended their Fall Summit last October, a month fittingly designated National Cybersecurity Awareness Month, and heard plenty about sharing. The mission of FS-ISAC is always strength in sharing; this year's summit focused on expanding the trust.
Payments people are used to looking for fraud by way of chargebacks and returns, one payment-channel silo at a time. Shhh. Don't let ACH people share information with wire people, and vice versa—the risk department will let us know if there is an issue. Of course, payments fraud is an ever-increasing battle, and we must remain vigilant. However, who is prepared to recognize payment events that from a bird's-eye view may look legitimate but, when analyzed, point to a threat of mass destruction?
Recent distributed denial-of-service (DDoSs) attacks highlight the scale of network bandwidth that can be unleashed on connected systems. Payments are just that, a network of systems that connect every aspect of our economy. There are countless examples of services or goods not being rendered when payments aren't received. Liquidity failures do tend to cause a state of panic. Even attacking one specific sector such as payroll processing on the first of the month could lead to disaster. As my colleague pointed out in a July 2016 blog, cash is alive and well, but payments systems today rely totally on telecommunications, which rely on our power grid.
Admiral James Stavridis, the keynote speaker at the FS-ISAC Summit, echoed the importance of expanding trust, along with the need to increase the resiliency of the nation in the event of a cyber-incident. Stavridis provided many encouraging solutions, one being that it is time for a cyber-force branch of the military. The United States Air Force was formed as a separate branch of the military in September 1947 under the National Security Act of 1947 as aerial warfare advanced. Stavridis proposed that now is the time for us to consider that cyber-incidents could be used as weapons of mass destruction. He applauded the current combat against cybercrime, yet encouraged new thought on what could be in store and how quickly it could arrive.
How do payments people continue down the path of protecting individual players while simultaneously protecting the nation from a crippling cyber-incident? It could be just a matter of whom you invite to the table. As I saw with attendance at the FS-ISAC Summit, the cybersecurity conversation needs to include diverse skill sets. There has been a trend in moving information security departments away from their information technology partners and under the risk and compliance umbrella so they can remain unbiased when scrutinizing payment transaction red flags and other systems. Additionally, legal barriers are being reevaluated to ensure that law enforcement can access information, most notably by FinCEN expanding Suspicious Activity Report requirements to include cyber events.
And, more deeply about whom we are trusting at the table, are we actually expanding the information shared? Could we make correlations by looking at payment volumes together with cyber activity and reports of fraud?
There is a growing sense that payment security equates to cybersecurity and national security. With Stavridis and others promoting the movement for "expanding the trust," new ideas continue to emerge. Hopefully, the technologies and strategies that are made to wow us (for example, the internet-of-things, machine learning, and the distributed ledger) can also serve to unite and protect us.
By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
January 9, 2017
The Year in Review
As we move into 2017, the Take on Payments team would like to share its perspectives of major payment-related events and issues that took place in the United States in 2016, in no particular order of importance.
Cybersecurity Moves to Forefront—While cyber protection is certainly not new, the increased frequency and sophistication of cyber threats in 2016 accelerated the need for financial services enterprises, businesses, and governmental agencies to step up their external and internal defenses with more staff and better protection and detection tools. The federal government released a Cybersecurity National Action Plan and established the Federal Chief Information Security Office position to oversee governmental agencies' management of cybersecurity and protection of critical infrastructure.
Same-Day ACH—Last September, NACHA's three-phase rules change took effect, mandating initially a credit-only same-day ACH service. It is uncertain this early whether NACHA will meet its expectations of same-day ACH garnering 1 percent of total ACH payment volume by October 2017. Anecdotally, we are hearing that some payments processors have been slow in supporting the service. Further clarity on the significance of same-day service will become evident with the addition of debit items in phase two, which takes effect this September.
Faster Payments—Maybe we're the only ones who see it this way, but in this country, "faster payments" looks like the Wild West—at least if you remember to say, "Howdy, pardner!" Word counts won't let us name or fully describe all of the various wagon trains racing for a faster payments land grab, but it seemed to start in October 2015 when The Clearing House announced it was teaming with FIS to deliver a real-time payment system for the United States. By March 2016, Jack Henry and Associates Inc. had joined the effort. Meanwhile, Early Warning completed its acquisition of clearXchange and announced a real-time offering in February. By August, this solution had been added to Fiserv's offerings. With Mastercard and Visa hovering around their own solutions and also attaching to any number of others, it seems like everybody is trying to make sure they don't get left behind.
Prepaid Card Account Rules—When it comes to compliance, "prepaid card" is now a misnomer based on the release of the Consumer Financial Protection Bureau's 2016 final ruling. The rule is access-device-agnostic, so the same requirements are applied to stored funds on a card, fob, or mobile phone app, to name a few. Prepaid accounts that are transactional and ready to use at a variety of merchants or ATMS, or for person-to-person, are now covered by Reg. E-Lite, and possibly Reg. Z, when overdraft or credit features apply. In industry speak, the rule applies to payroll cards, government benefit cards, PayPal-like accounts, and general-purpose reloadable cards—but not to gift cards, health or flexible savings accounts, corporate reimbursement cards, or disaster-relief-type accounts, for example.
Mobile Payments Move at Evolutionary, Not Revolutionary, Pace—While the Apple, Google, and Samsung Pay wallets continued to move forward with increasing financial institution and merchant participation, consumer usage remained anemic. With the retailer consortium wallet venture MCX going into hibernation, a number of major retailers announced or introduced closed-loop mobile wallet programs hoping to emulate the success of retailers such as Starbucks and Dunkin' Brands. The magic formula of payments, loyalty, and couponing interwoven into a single application remains elusive.
EMV Migration—The migration to chip cards and terminals in the United States continued with chip cards now representing approximately 70 percent of credit/debit cards in the United States. Merchant adoption of chip-enabled terminals stands just below 40 percent of the market. The ATM liability shift for Mastercard payment cards took effect October 21, with only an estimated 30 percent of non-FI-owned ATMs being EMV operational. Recognizing some of the unique challenges to the gasoline retailers, the brands pushed back the liability shift timetable for automated fuel dispensers three years, to October 2020. Chip card migration has clearly reduced counterfeit card fraud, but card-not-present (CNP) fraud has ballooned. Data for 2015 from the 2016 Federal Reserve Payments Study show card fraud by channel in the United States at 54 percent for in person and 46 percent for remote (or CNP). This is in contrast to comparable fraud data in other countries further along in EMV implementation, where remote fraud accounts for the majority of card fraud.
Distributed Ledger—Although venture capital funding in blockchain and distributed ledger startups significantly decreased in 2016 from 2015, interest remains high. Rather than investing in startups, financial institutions and established technology companies, such as IBM, shifted their funding focus to developing internal solutions and their technology focus from consumer-facing use cases such as Bitcoin to back-end clearing and settlement solutions and the execution of smart contracts.
Same Song, Same Verse—Some things just don't seem to change from year to year. Notifications of data breaches of financial institutions, businesses, and governmental agencies appear to have been as numerous as in previous years. The Fed's Consumer Payment Choices study continued to show that cash remains the most frequent payment method, especially for transactions under 10 dollars.
All of us at the Retail Payments Risk Forum wish all our Take On Payments readers a prosperous 2017.
- The Year(s) of Ransomware
- What Canada Knows That We Don't
- Calculating Fraud: Part 1
- Additional Authentication: Is the Protection Worth the Hassle?
- Would Consumers Ever Give Up Their Passwords?
- Will the Password Ever Die? Part 1
- Catch Me If You Can
- Governance Down Under
- Don't Forget the Check
- Fraud Reduction at the IRS: Some Happy Returns
- May 2017
- April 2017
- March 2017
- February 2017
- January 2017
- December 2016
- November 2016
- October 2016
- September 2016
- August 2016
- account takeovers
- ATM fraud
- bank supervision
- banks and banking
- card networks
- check fraud
- consumer fraud
- consumer protection
- cross-border wires
- data security
- debit cards
- emerging payments
- financial services
- identity theft
- law enforcement
- mobile banking
- mobile money transfer
- mobile network operator (MNO)
- mobile payments
- money laundering
- money services business (MSB)
- online banking fraud
- payments risk
- payments study
- payments systems
- phone fraud
- remotely created checks
- risk management
- Section 1073
- social networks
- third-party service provider
- trusted service manager
- Unfair and Deceptive Acts and Practices (UDAP)
- wire transfer fraud
- workplace fraud