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.
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February 27, 2017
Wouldn't It Be Nice to Tap and Pay?
In the mid-2000s, after setting up a new checking account following a move, I received a debit card that, in addition to the magnetic stripe, had contactless functionality. I remember thinking how "cool" this feature would be, not having to swipe the magnetic stripe but simply tapping the card on the point-of-sale (POS) terminal. However, I quickly became disappointed, as I couldn't use the tap functionality in most places that I shopped. In the few places that did allow for taps, I don't recall the tap ever working properly. After a few months, I never attempted to tap it again and reverted to the traditional swipe.
Fast forward to 2017, and contactless card usage is surging in the United Kingdom, Australia, and Canada while remaining all but nonexistent in the United States. In November 2016, contactless cards accounted for nearly 25 percent of all card payments in the United Kingdom, up from 11 percent since November 2015. In Australia, Visa reported that 75 percent of face-to-face transactions over their network happen via their contactless solution. And in Canada, 99 percent of Mastercard's consumer credit cards are contactless-enabled. A 2016 report found that Canadian consumers were frustrated by merchants that didn't accept contactless payments. All of these countries have also gone through a migration of their payments cards to EMV chip cards. Did the United States miss a great opportunity when chip cards replaced the magnetic-stripe-only payment cards?
Interestingly, in these markets where contactless card adoption rates are surging, contactless cards are leading the contactless payment push ahead of mobile payments. In the United States, we are heading in the opposite direction, with mobile contactless attempting, and struggling, to get traction. No doubt, mobile is the more challenging environment, with a variety of form factors (iPhone, GalaxyS7, Pixel, and more), different ways that the form factor can interact with the POS terminal (such as near-field communication, magnetic source transmission, and barcode), and a variety of different wallets compatible with the different form factors. With a contactless card, you get one form factor—a card—and one method of contactless interaction. (Multiple-interface cards can still be swiped or dipped at the POS.)
I am convinced that the investments made in mobile contactless to this point are one of several factors holding up this country's transition to a contactless card environment. Consumers are confused by the experience and merchants and issuers are struggling with the wide range of options to consider, such as which wallets to enable and which technologies to support. Contactless cards have the ability to create a ubiquitous experience for both consumers and merchants. And this writer believes that a payment experience can't get any easier than a tap of the card.
It's hard for me to believe that it has been 20 years since I received my keychain Speedpass fob. I have positive memories of the simple and seamless transactions that I experienced when purchasing gas by touching the contactless fob to the gas pump reader. Unfortunately, I moved to a location with very few stations that accepted my fob. I always wished that I could have a similar experience for other purchases. Contactless cards allow for that and in a much easier and simpler fashion than my mobile phone allows. So can we get on with contactless cards? I am ready to tap and pay everywhere. Are you?
By Douglas A. King, 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.
June 13, 2016
What Is GPR Feeding On? Part 2 of 2
In part 1, I shared several studies on the appetite for general-purpose reloadable (GPR) prepaid cards. It turns out there is little public data covering the fraud portion of the industry. I look forward to results from the Federal Reserve's 2016 Payments Study, which added a number of questions related to GPR card fraud.
Last week, LexisNexis® released a fraud study titled Issuers Confront Application Fraud and Account Takeover in a Post-EMV U.S. The study reports that issuers annually lose $10.9 billion to card fraud overall, with 4 percent attributed to all types of prepaid cards (not just GPR), 25 percent to debit cards, and 71 percent to credit cards. The study examines what types of fraud schemes are responsible for losses, but the data is aggregated and not broken down by card type. We will look at these results and I will describe how fraudsters could use prepaid to perpetrate that type of fraud.
Lost/stolen cards: 28 percent of total card fraud
GPR card information can be lost or stolen in a variety of ways—as can happen with all payment card instruments. When the fraudster acquires the account numbers, he or she can then sell, clone, or counterfeit new cards to make fraudulent purchases. The most common schemes include:
- Skimming magnetic stripes via compromised ATM or POS terminals
- Cyberattacks/data breaches
- Simply lost or stolen cards
"Lost or stolen" also include information obtained from extortion by coercive measures and deceptive marketing. Fraudsters trick consumers into loading funds on a prepaid card and then handing over the account information. Some prepaid issuers have included warnings about this type of crime on their packaging. Some recent schemes include:
- Pretending to represent a creditor or utility and convincing victims they are overdue on bills and must immediately make a payment using a prepaid card
- Money-winning schemes (I always win cruises) whereby a consumer must pay taxes on the winnings with a prepaid card
Account takeover: 20 percent
These schemes typically involve business bank accounts. However, a blog by Kreb’s on Security describes a well-known case involving prepaid. Cybercriminals allegedly breached a number of payment processors over a two-year period. They acquired account information and changed account balances and daily withdrawal limits. The criminals then used the breached payment card information to clone cards to use at ATMs all over the world and withdrew nearly $55 million in cash.
Application fraud: 20 percent
Ultimately, this scheme involves the criminal opening a GPR account under a stolen or false ID, using stolen funds to open the account. Schemes that fit into this category are:
- Filing fraudulent tax returns and sending refunds to prepaid accounts. (I recently blogged on this.)
- Buying prepaid cards with stolen or counterfeit cards, a growing scheme that essentially creates free money out of stolen funds
Counterfeit cards: 16 percent
Counterfeiting usually occurs in conjunction with other fraud schemes. Counterfeit cards (and even lost or stolen cards) can be sold, often at a discount to the purchaser, potentially making their way into the hands of law-abiding citizens through wholesale websites.
Maybe fraudsters stock their pantry with prepaid cards, but are these common schemes unique to GPR cards or prepaid accounts? Although it's easier to open a prepaid account with little direct human contact, couldn't we substitute debit card or credit line accounts in any of these fraud schemes? Every type of monetary instrument experiences fraud but the prepaid industry has worked diligently to address these common areas. The vast majority of prepaid customers are legitimate users that have chosen this type of product for economic or payment preference reasons.
By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
September 22, 2014
New ACH Return Rate Threshold on the Horizon
In a December 2013 post, we asked the question, Is it the right time for lower ACH return rate thresholds? We can now say that the answer is "Yes." The voting membership of NACHA-The Electronic Payments Association recently approved a NACHA Operating Rule amendment that will reduce the unauthorized debit return rate threshold.
The process of returning payment transactions is a pain point for the receiving financial institutions that incur the costs of exception processing, which includes handling customer service inquiries and the returns. Unauthorized transactions are also a pain point for customers who have experienced such postings to their accounts. For the financial institution originating transactions on behalf of businesses and third-party customers, ongoing and proactive monitoring of return rates can help them quickly identify potential problems and determine if those problems have been addressed.
The NACHA Operating Rule amendment will reduce the threshold for returns of unauthorized debit entries from 1 percent to 0.5 percent, effective September 18, 2015. An originating depository financial institution will be subject to possible reporting and fines if they have an originator or third-party sender whose return rate for unauthorized debits exceeds the current threshold.
As NACHA states in its information on the new rule, this 0.5 percent threshold is more than 16 times higher than the average network return rate of 0.03 percent for unauthorized debit entries in 2013. This new threshold will continue to emphasize the importance of institutions focusing on high return rates and working with their customers to bring any excessive rates down. The amendment also establishes a review process for when returns for "administrative" or "overall return" reasons exceed certain levels. For administrative returns, this will be 3 percent, and for overall returns, it will be 15 percent. Administrative returns include debits returned for reasons such as closed account, invalid account number structure, or the account number not corresponding to an existing account. Overall returns for ACH debits include unauthorized and administrative reasons, as well as others such as insufficient funds and stop payments.
Unlike the unauthorized return threshold, breaching return rate levels for administrative and overall return reasons will not result in an automatic requirement to reduce the return rate or undergo a rules enforcement proceeding. Instead, exceeding these return rates will lead to a process to determine if the origination practices of a given originator or third-party sender need to be modified to achieve lower exception levels.
The timeframe for implementing this rule allows originating financial institutions to look carefully at their current return monitoring processes and determine whether customers are near these return rates and to put into place practices that would address problem areas. Will this new rule affect your due diligence processes? Does your current monitoring already show that your customers' return rates are lower than the new thresholds?
By Deborah Shaw, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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February 10, 2014
Chip-and-PIN, or Chip-and-Choice?
If the comments that legislators and industry representatives made at the recent congressional hearings on data breaches were any indication, any card issuer advocating or adopting a chip-and-signature approach to EMV smartcard implementation would appear to be incautious. Unquestionably, chip-and-PIN is more secure than chip-and-signature because it represents two forms of authentication—something you have (the card) and something you know (the PIN). However, chip-and-signature could be a reasonable first step in that it would generate less friction for the consumer, merchant, and card issuer. Let me explain why.
Most consumers don't know their credit card PINs
Although most people know their debit card PINs—you need one to use an ATM—few U.S. consumers know their credit card PINs. Various studies place consumers' knowledge of their credit card PINs in the 5 to 10 percent range. It would therefore be an educational as well as logistical effort to get consumers to begin using their credit card PINs if the industry moved to a chip-and-PIN-only environment.
Merchants would incur a big expense for the equipment
Only about 25 percent of the 8 million POS terminals operating in the United States are equipped with a PIN pad, according to data provided to the Federal Reserve. Before Regulation II, merchants had a financial incentive to encourage PIN-based debit transactions because the interchange rate was lower than for credit card transactions. However, Reg II eliminated this differential. (This despite the fact that PIN debit transactions have less than one-third of the fraud loss rate of signature debit transactions, according to the 2013 Fed Payments Study Summary.) Although a representative of the National Retail Federation endorsed a chip-and-PIN-only strategy at a congressional hearing, it's difficult to know if merchants will want to make the additional investment required to equip, program, and maintain their POS systems to support PIN transactions. Most merchants have not yet taken this step, so what has changed?
Customer experience would change
A PIN-based transaction, with its single-message authorization and settlement process, creates problems for certain merchants—like car rental and lodging companies—that must run preauthorization transactions before the final amount of the transaction is determined. The separate authorization and settlement process provided by the dual-message format of a signature-based transaction is more conducive to the business needs of these merchant segments. Are fine dining restaurants going to install the even more expensive mobile payment terminals so customers can pay at the table as they currently do? Or will they require the customer to go to a checkout and pay there? These merchants especially will have to consider the impact on their customer experience.
Backup method needed
With debit cards now, a signature authentication can be a backup method of acceptance. But in a chip-and-PIN environment, how high will the rate of incomplete transactions be when cardholders can't remember their PINs and they have no other method of payment?
As with any change, there are a number of positives and negatives to be considered. To avoid unintended consequences, we at Portals and Rails believe that issuers, merchants, and consumer groups should carefully evaluate all the issues to determine the best way to migrate to EMV payment cards. What do you think—chip-and-PIN only or chip-and-choice?
By David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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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.
By David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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September 3, 2013
EMV Is Coming to the United States--Right?
The conferences I have attended recently have all had a session where speakers or panelists opined on the state of EMV migration and its future here in the United States. Some of the panelists have been highly optimistic, admitting to the challenges the industry currently faces but confident the issues will be successfully resolved. Those on the other end of the spectrum have been downright dismissive of the effort and sometimes even the standard itself. Based on my research and some of the industry discussion I've heard, let me offer my perspective on the current and future state of EMV migration in the United States.
Terminal migration timeline
The difference in the timelines of ATMs and POS terminals for the liability shift to take effect was initially confusing to some but that confusion seems to have been resolved—although the difference of a year between MasterCard (2016) and Visa (2017) for the ATM is still a head scratcher. But it seems likely that both networks will agree on a common date before the end of 2014.
Much of what I'd been hearing indicated that there would likely be no rush for the merchant community to upgrade their terminals to meet the POS liability shift timeline, currently scheduled for October 2015. Something tells me that many will choose to ignore the liability shift date altogether. The unresolved Application Identifier (AID) battle currently being fought among Visa, MasterCard, and the debit networks is a major factor in both the debit card issuance and POS terminal decisions. Many of the major merchants and their industry associations have not been big fans of EMV, apparently because of a variety of control, financial, and technical reasons. Understandably, merchants are attempting to consolidate their terminal upgrade efforts to support both mobile payments and EMV, so they would prefer to put off major terminal purchases or upgrades until there is a final resolution of terminal requirements for both technologies.
When U.S. District Judge Leon delivered his July 31 ruling that the Fed's Regulation II debit card transaction routing requirements did not meet the legislation's intent, it seemed that there was a greater likelihood for EMV development efforts to be placed on hold until there is a final routing rule.
Card migration timeline
Based on comments I've also heard at recent industry conferences, many of the major card issuers' replacement plans seem to be focused on card replacement for international travelers and high net worth/private banking clients rather than a wholesale card replacement effort. This issuance policy appears to be more to ensure operability when traveling to an EMV-converted country than to take financial advantage of the liability shift. Again, it seems highly likely that Judge Leon's ruling will suspend any major debit card replacement efforts until there is a resolution on the routing rules and the related AID solution.
Although it's normal for any major technology change to have its starts and stops, its advocates and critics, we must not forget that delays in finding a viable business solution for counterfeit card fraud only increases our risk profile through higher fraud losses and erosion of consumer confidence. We will be back to write more on this topic in future Portals and Rails posts, but for now we'd like to hear your thoughts.
By David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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- Don't Forget the Check
- Fraud Reduction at the IRS: Some Happy Returns
- Phone Scams and Phishing
- Asset Size Matters in Survey Responses
- Wouldn't It Be Nice to Tap and Pay?
- The Social Benefits of Biometrics
- The Five-Star That Flops
- ACH: No Trace Left Behind
- Pssst…Have You Heard about PSD2?
- Mobile Banking and Payments Survey Results
- March 2017
- February 2017
- January 2017
- December 2016
- November 2016
- October 2016
- September 2016
- August 2016
- July 2016
- June 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