Retail Payments Risk Forum
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.
Federal Reserve Web Sites
Other Bank Regulatory Sites
Take On Payments
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.
August 15, 2016
The Personal Cost of Fraud
Last week's post by my colleague Doug King described the check fraud that took place after someone burglarized his wife's car and stole her wallet, including her driver's license and credit and debit cards. The frequency and magnitude of data breaches and constantly reading and researching payments fraud as part of my job have probably numbed me to the personal impact of fraud. When discussing the likelihood of becoming victims of some sort of identity theft fraud, we jokingly paraphrase the slogan in the South about termite infestations: "It's not a matter of if, it's a matter of when." Given the data breaches and information available through public records, we operate under the assumption that the criminal element has all the information they need to perpetrate fraud against us and, for those of us who haven't already been victimized, it is likely to happen in the near future. A pessimistic outlook for sure, but one I fear is realistic.
I still get frustrated when I see the many studies that show that, despite consumers' concern about the security and privacy of their transaction and personal information, the vast majority do not adopt strong security practices. They use easy-to-guess passwords or PINs and often use the same user ID and password for their various online accounts, from social media to online banking access. I believe that many financial institutions (FI) and ecommerce providers have passively supported this environment in that they often do not require customers to use stronger practices because they don't want to incur the customer service cost associated with password resets or customer abandonment. The lack of consistent password formatting structures adds to the confusion (some require special characters and others don't allow them).
I certainly don't hold myself out as the poster child for strong security, but our family has adopted a number of the recommended stronger security practices. These include using a simple compound password structure that creates a separate password for each application, creating a more complex password structure for financial applications, establishing filter rules designed to spot spam and phishing emails, and conducting a frequent review of financial accounts to spot unauthorized transactions.
While liability protection laws and regulations generally hold a consumer financially harmless, there clearly is a social and individual cost associated with fraud from the time spent dealing with law enforcement and FI representatives to the issue of not being able to access the funds fraudulently taken until reimbursement is made. Perhaps Doug's wife's requirement for her FI to provide a stronger level of authentication reflects a changing sense of the need by the general public for stronger security practices. I certainly hope so.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
April 25, 2016
Be Careful, Be Very Careful
Less than halfway through the spring season of banking and payments conferences, the dominant theme of cybercrime is ringing loud and clear. In the 2015 conferences, it was virtual currency, but this year, it is the threat of cyberattacks against individuals and business in both widespread and singular manners. At a payments conference last week, a representative of the Internet Crime Complaint Center (IC3) told the session audience about her center's work. The IC3 has served since 2000 as a conduit for the public to provide information to the FBI regarding suspected Internet-facilitated criminal activity. IC3 tracks and investigates hacking, money laundering, identity theft, advanced fee, and ransomware schemes. It also tracks and investigates efforts to steal intellectual property and trade secrets.
In its latest annual report, IC3 provides detailed statistics on Internet-related complaints and trends. In 2014, the center received almost 270,000 complaints, accounting for more than $800 million in losses. Average monthly complaints received were 22,452. Complaint volume peaked in July at 24,521; the month with the fewest was February, with 20,888.
I asked the IC3 representative about the top complaints the unit was currently seeing. She indicated that email compromise of targeted businesses was the primary complaint and the one that generally resulted in the highest financial loss per complaint. It is common for employees in accounting areas to be targeted. They receive spoofed emails instructing them to initiate wire transfers or to change invoice remittance payments to fraudulent parties and locations, often accounts at financial institutions located in eastern Europe or the Asian-Pacific region. Although representing less than 1 percent of the total complaints filed in 2014, the losses from business email compromise accounted for 28 percent of the total losses reported, and from January 2015 to January 2016 the loss rate increased 270 percent.
Advanced fee schemes involving home rentals or sales, automobile sales, dating services, and lottery/prize winnings are also common. As the name implies, the criminals gain the confidence of victims and demand upfront payment as a sign of good faith. Once they receive the first payment, they will often try for additional payments before disappearing.
Finally, intimidation or extortion schemes are becoming more prevalent. The criminal generally contacts the victims by phone, accuses them of being past due on tax payments or utility bills, and says if immediate payment is not made, their property will be confiscated or they will be arrested. Often the criminal has used social engineering or public records to obtain legitimate data to make their representation of the agency seem more legitimate.
The size and frequency of data breaches of financial institutions, retailers, health care and insurance companies, and government agencies have led some people to conclude that just about everyone's personal identification information has been compromised to some level. I believe it is sensible to be a bit distrustful and apprehensive about the legitimacy of offers or information you might receive through emails or websites, especially those with which you are unfamiliar. Many of the attempts are easy to spot but many others involve highly sophisticated techniques, so one should be extremely careful when on the Internet.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
March 21, 2016
The Insider on the Outside
Having had a few days to digest my RSA Conference 2016 experience (and let my feet recover), I'm not sure whether to be more concerned about cybersecurity challenges or more at ease due to the sheer number of solutions on display that are available to mitigate these challenges. In reality, my emotions are mixed.
On the one hand, the cybersecurity threat is real and spreading across all types and sizes of businesses and government agencies. On the other hand, information sharing is taking place across, and within, industries like never before, and technology is being harnessed in an effort to strengthen defenses against the latest cybersecurity threats. But my biggest takeaway from the week might be different from that of the many technology evangelists and cyber risk experts that I encountered: the human element might be the most important element in mitigating data loss risks.
The risk of data loss due to the human element is quite substantial and probably merits a paper on its own or perhaps a dedicated Take on Payments series. Today, I'm going to focus on a single aspect of the human element: the expanding nature of the insider threat. In a Take On Payments post from the summer of 2013, I discussed some access and security management principles to thwart malicious behavior from an insider.
Traditionally, an insider has been thought of as an employee. That definition has broadened as organizations outsource more internal-support functions to third-party providers. Much has been written and discussed concerning regulatory and compliance issues related to third-party providers, and this notion of the "outside insider" is a logical extension of a company's risk management practice. The insider threat is real and costly. According to data from the Ponemon Institute, malicious insider attacks cost companies an average of about $144,000 annually.
Ensuring that any third-party provider has the necessary policies and procedures in place to secure your data from outsiders is paramount, but what about the sufficiency of their controls to protect your data from potential bad actors within these third parties? Have you given much thought to this notion of the "outside insider"? If you have, what recommendations or best practices do you have to avoid becoming a victim of a malicious insider on the outside?
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
February 22, 2016
2016 Payment Predictions
In our 2015 year-end review, we promised we would provide some predictions and expectations for payments in the United States during 2016. Predictions are usually pretty…unpredictable, so by waiting a couple of months to release ours, we're hoping they will end up being more accurate than usual. Disclaimer: These predictions are through the collective wisdom of the Retail Payments Risk Forum staff and do not reflect the opinions of the Federal Reserve System or the Board of Governors. So here we go in no particular order or probability of happening.
- Cyberattacks will be the top threat to payments security: Cyberattacks and data breaches will be as robust as ever and will be the number one threat in the payments ecosystem. As retailers and financial service companies strengthen their defenses, the Risk Forum predicts that hackers will widen their focus.
- This will be the year for mobile point-of-service (POS) payments…not!: Like the broken analog clock face that is correct twice a day, we believe that those forecasting 2016 as the "year of mobile payments" (as they did in 2013, 2014, and 2015) will be a little bit right, but will still be waiting for this optimistic prediction to be fully true. While the adoption pace of mobile payments is growing because of the increasing influence of millennials, the issues of limited merchant acceptance points, fragmentation, and consumer concerns over security and privacy will remain as substantial hurdles. Major educational efforts will be launched stressing the increased security provided by mobile payments through tokenization and biometrics.
- EMV (chip card) POS migration will pick up the pace from 2015: The liability shift for POS took place October 1, 2015, and projections for both card and terminal capability missed their optimistic marks for a variety of reasons. Credit and debit card reissuance will continue during 2016 and should reach significant conversion levels by the end of the year. The Risk Forum expects the pace of merchant terminal conversions to pick up as certifications are completed and merchants targeted by counterfeit card fraudsters feel the sting of losses. However, we also think some merchant categories, such as restaurants, will continue to proceed at a tepid pace.
- ACH same-day service will not be a huge hit: The Risk Forum forecasts that the roll-out of NACHA's mandated same-day ACH service in September will, at least initially, have modest adoption because corporate originators will have to update internal systems to support faster payments, the dollar cap of $25,000 per payment, and the imposition of the interbank fee. Consumer payment applications will have modest uptake due to competing payment alternatives.
- EMV ATM liability shift will cause the number of ATMs to shrink: The implementation of chip card readers in ATMs will follow the same pattern as POS terminals did in 2015—the large ATM owners and operators will meet the October 2016 deadline but many of the small and mid-sized operators, especially those owned by nonfinancial institutions, will not and will be faced with absorbing the loss of transactions made with counterfeit cards—a fraud loss they haven't experienced in the past. Overall, the Risk Forum looks for the ATM base in the U.S. to contract by 10 to 15 percent because of financial institution mergers and the cost of EMV upgrades.
- Mobile wallet space will continue to see turbulence: 2015 saw the launch or announcement of more mobile wallets by payment stakeholders such as Samsung, Google, Chase, Capital One, Walmart, and Target. Then add the retailer and credit union consortiums (MCX CurrentC and CU Wallet) that are struggling to emerge from uncertainty. How many wallets will the consumer be willing to load on a phone and which providers do they trust to keep their payments and banking credentials safe? We believe we'll see continued turbulence in this space during 2016, with some settling of the dust by next year.
- Blockchain technology interest will accelerate: Cryptocurrencies will continue to exist in the "novelty" space, but we think large payments players will direct efforts to leveraging the distributed ledger technology for various uses and will proceed at an accelerated pace.
- Biometric technology improves, but passwords remain supreme: Despite continued cries for intervention, the user ID and password will remain the primary authentication method that consumers use to access their various applications. Biometrics technology for payment and customer authentication applications will continue to improve while decreasing in price. Fingerprint, facial recognition, and eye/iris recognition will dominate as the most-used biometrics although voice recognition will serve as a key method in certain environments such as call centers. The Risk Forum believes that the technology will continue to face critical adoption challenges due to concerns about privacy, security, and safety, but educational programs will lower this resistance.