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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.

Take On Payments

June 26, 2017


Responsible Innovation, Part 2: Do Community Financial Institutions Need Faster Payments?

In my last post, I introduced themes from a summit that the Retail Payments Risk Forum cohosted with the United Kingdom's Department for International Trade. The summit gathered payments industry participants to discuss faster payments and their effects on community financial institutions (FIs). This post, the second of three in a series, tackles the question of whether community FIs and their customers actually have an appetite for increasing the speed of payments.

A summit attendee from WesPay, a membership-based payments association in the United States, presented the findings of a survey of 430 U.S. FIs about current payments initiatives. An important discovery was that awareness and adoption of faster payments solutions remains low, as the responses to two survey questions indicate:

  • For same-day ACH, a majority (57 percent) indicated that the first phase—faster credits—"has had no measurable impact on our customers'/members' transactions."
  • When asked about the Federal Reserve Faster Payment Task Force, 34 percent of respondents indicated they were unaware of the initiative, and 46 percent indicated they had only high-level knowledge.

Responses to another of WesPay's survey questions suggest that, although there may be low awareness of many current initiatives, many financial institutions are recognizing that faster payments are inevitable. A majority (60 percent) agreed that faster payments initiatives are "an important development in the industry. However, our institution will be watching to see which platform becomes the standard."

NACHA's representative presented statistics from phase one of same-day ACH, with reminders about the phases to come.

  • Same-day ACH reached a total of 13 million transactions in the first three months (launched September 23, 2016).
  • Phase 2 will allow for direct debits to clear on the same day (to launch September 15, 2017).
  • Phase 3 will mandate funds availability for same-day items by 5 p.m. local time (to launch March 16, 2018).
  • The current transaction limit is $25,000, and international ACH is not eligible.

Results of a study by ACI Worldwide, a global payments processor, look a little different from WesPay's survey results. The study looked at small to medium-size enterprises to gauge real-time payments demand. For the U.S. respondents, the research revealed that:

  • Fifty-one percent are frustrated by delays in receiving payments.
  • Forty-two percent are frustrated by outgoing payments-delivery timeframes.
  • Sixty-five percent would consider switching banks for real-time payments.

We don't know yet what U.S. adoption rates will be, but Faster Payments Scheme Ltd. (FPS) in the United Kingdom already has a story to tell. U.K. panelists attending the summit at the Atlanta Fed stated that FPS has had constant adoption growth due to cultural change and customer expectations.

  • FPS reached a total of 19 million transactions in the first three months (launched May 27, 2008).
  • The FPS transaction limit increased in 2010 from £10k to £100k, and then to £250k in 2015.
  • On April 2014, Paym, a mobile payments service provider, launched, using FPS. Paym handles person-to-person and small business payments, similar to Zelle in the United States, which started up in June 2017, using ACH.
  • FPS had a total volume of 1.4 billion items in 2016.

For payment networks offering new solutions, community FIs are the critical mass that ensures adoption. Their participation will require practical benefits with a lot of support before they are willing to commit. Some community FIs might be forced to adopt new systems because everyone else has. Will new networks in the United States contest same-day ACH, which already has the advantage of ubiquity? Likely, as options develop, so will customer culture and expectations.

In the final installment of this "Responsible Innovation" series, I will look at future impacts of faster payments.

Photo of Jessica Washington  By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

June 26, 2017 in ACH, banks and banking, financial services | Permalink

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June 5, 2017


Responsible Innovation Part 1: Can Community Banks Remain Competitive?

The Atlanta Fed's Retail Payments Risk Forum recently co-hosted a summit with the United Kingdom's Department for International Trade to discuss faster payments and their effects on community financial institutions (FIs). In a series of three posts, I will share summaries of the lessons and implications that payments industry stakeholders discussed at the summit. A major theme of these discussions was whether community FIs can remain competitive independent of how they access a faster payments network. This post tackles this theme.

What networks were discussed at the summit?
United States United Kingdom
ACH (NACHA) ACH (Bacs)
Real-Time Payments (The Clearing House) Faster Payments (Faster Payments Scheme Ltd.)

The Faster Payments Scheme, or FPS, opened in the United Kingdom in 2008. The summit was a good opportunity to hear first-hand from one community banker's experience with the still-new system. A panelist from the first retail community bank to join the FPS discussed how access options played a role in the bank's ability to compete with large FIs.

  • In the beginning, the only way a community bank could access the FPS was through a sponsoring bank.
  • This option was expensive, hindering, and much like a newborn baby who needed attention all day and night (even on weekends), according to the panelist.
  • The FPS sends messages 24/7, in near-real time, but her bank's access model often caused a delay of 15 to 30 minutes, making the bank less than competitive.
  • Last year, the bank was able to join as a "Direct Participant" under the New Access Model,, an experience that the panelist compared to parenting a toddler who allows her to sleep through the night, even as it runs 24/7/365. The new model was also much more affordable and provided her community bank the near-real time model larger banks received. (The New Access Model that gives payment service providers and community FIs direct connection began in 2014, six years after the FPS began.)
  • The panelist did note a serious obstacle to this access model for the smaller banks: the onerous 12-month certification process to become a Direct Participant is tailored to large banks. The process required significant resources and strained other areas of her bank. She suggested that the certification take a risk-based approach.

Two developments on the way may affect future access options: (1) plans are set to consolidate Bacs, FPS, and Cheque; and (2) the Bank of England plans to grant settlement services to nonbank payment service providers.

The United States is facing a similar challenge: community FIs will have to choose how to access faster payment systems. Some community FIs have begun to offer same-day ACH and will likely consider real-time payments later this year.

Representatives from the Clearing House's Real-Time Payments initiative shared some details on their access model:

  • FIs of all sizes will be able to connect directly or through third-party service providers.
  • Regional payments associations will play an important role as they collectively represent all U.S. financial institutions plus third-party processors.
  • The speed will be the same for all participants.
  • Indirect participation will not be available.
  • Payments can be made 24/7/365.

While direct access is available for both same-day ACH and Real-Time Payments, some FIs may choose to use a sponsor or correspondent access model. To remain competitive, community FIs will have to understand the advantages and limitations that each access model provides.

The next installment in this series will discuss the U.S. market appetite for faster payments; the one after that will look at the impacts of adoption.

Photo of Jessica Washington  By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

June 5, 2017 in banks and banking, financial services, innovation | Permalink

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September 19, 2016


Mobile Banking and Payments—What's Changed?

This week, the Federal Reserve Banks of Atlanta, Boston, Cleveland, Dallas, Kansas City, Minneapolis, and Richmond are launching an online mobile banking and payments survey to financial institutions based in their respective districts. The purpose of the survey is to achieve better understanding of the status of mobile banking and payments initiatives, products, and services that financial institutions offer in the various regions of the country. The results of the survey at the individual district level should be available to participants by mid-December; a consolidated report for all the districts will be published in early 2017.

The last survey, which had 625 participants, was conducted in the fall of 2014. That was before the launch of the various major mobile wallets operating today, so it will be interesting to see what level of impact these wallets have had on the mobile payments activity of financial institutions. You can find the results of the 2014 Sixth District survey on our website. This survey effort complements the 2016 Consumer and Mobile Financial Services survey conducted by the Federal Reserve Board's Division of Consumer and Community Affairs.

First designed by the Federal Reserve Bank of Boston in 2008, the survey has been updated over the years to reflect the many changes that have taken place in the mobile landscape in the United States. Similar to past surveys, the 2016 survey looks to capture:

  • Number of banks and credit unions offering mobile banking and payment services
  • Types of mobile services offered or planned
  • Mobile technology platforms supported
  • Features of mobile services offered or planned
  • Benefits and business drivers associated with mobile services
  • Consumer and business adoption/usage of mobile services
  • Barriers to providing mobile services
  • Future plans related to mobile payment services

If your financial institution is based in one of the participating districts and has not received an invitation to participate in this year's survey, please contact your district's Federal Reserve Bank. For the Sixth District, you can contact me via email or at 404-498-7529. You can also contact me if you need assistance in locating your district's lead survey coordinator.

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

September 19, 2016 in banks and banking, financial services, mobile banking, payments | Permalink

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August 1, 2016


FFIEC Weighs In On Mobile Channel Risks

In late April, the Federal Financial Institutions Examination Council (FFIEC) released new guidance regarding mobile banking and mobile payments risk management strategies. Titled "Appendix E: Mobile Financial Services," the document becomes part of the FFIEC's Information Technology Examination Handbook. While the handbook is for examiners to use to "determine the inherent risk and adequacy of controls at an institution or third party providing MFS" (for mobile financial services), it can also be a useful tool for financial institutions to better understand the expectations that examiners will have when conducting an exam of an institution's MFS offering.

Consistent with examiners' focus on third-party relationships for the last several years, the document points out that MFS often involves engagement with third parties and that the responsibilities of the parties in those relationships must be clearly documented and their compliance closely managed. Other key areas the document reviews include:

  • Mobile application development, maintenance, security, and attack threats
  • Enrollment controls to authenticate the customer's identity and the payment credentials they are adding to a mobile wallet
  • Authentication and authorization, emphasizing that financial institutions should not use mobile payment applications that rely on single-factor methods of authentication.
  • Customer education efforts to support the adoption of strong security practices in the usage of their mobile devices

The document also identifies and reviews strategic, operational, compliance, and reputation risk issues for the various elements of a financial institution's MFS offering. The final section of the document outlines an examiner's work plan for reviewing an MFS program with seven key objectives. I believe that it would be time well spent for the institution's MFS team to assume the role of examiner and use the work plan as a checklist to help effectively identify and manage the risks associated with an MFS program.

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

August 1, 2016 in bank supervision, banks and banking, financial services, mobile banking, mobile payments, regulations, regulators, third-party service provider | Permalink

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Looking forward to welcoming David Lott to our upcoming Next Money Tampa Bay meetup.

David will be our keynote on Wednesday, Sept 21, 2016 6:00 ~ 8:00 PM

Tampa Bay Wave Venture Center
500 East Kennedy Boulevard 3rd FL
Tampa Florida 33602

All are welcome to attend RSVP at

https://www.meetup.com/NextMoneyTPA/events/233171815/

Posted by: Bruce Burke | August 6, 2016 at 05:22 PM

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July 11, 2016


Surviving the Emerging Payments Providers

Predictions abound that emerging companies will dominate the remittance and person-to-person (P2P) payments space and financial institutions will be relegated to being a bystander. While I am not sold on their eventual dominance, I do think that emerging companies are creating positive changes. These changes have included new business models for financial institutions and traditional remittance providers who are able to offer their existing and prospective customers new, efficient payment choices. And as recently released financial and transaction figures show, some traditional players embracing change are poised to remain in their leadership positions.

I recently saw a speaker who said that one particular emerging digital remittance provider is the largest digital remittance business in the United States. However, I think the honor of the largest digital remittance transfer provider goes to a long-term remittance incumbent, Western Union. Though payments volume data are not available, revenue data do provide us with some insight into the size of these providers. According to Western Union's 2015 annual report, its digital money transfer services generated $274 million in revenues in 2015. As a point of comparison, three emerging companies (Xoom, Worldremit, and TransferWise) had combined revenues of $230 million. Though Western Union's online service represents only 6.3 percent of its consumer-to-consumer revenues, the segment grew by 26 percent in 2015.

In June, Chase announced changes to its digital P2P solution that will allow Chase customers to send and receive money in real time through ClearXchange with customers of Bank of America, U.S. Bank, and several other financial institutions. Chase's digital P2P solution has been a feature on the Chase mobile application and online banking website for several years now and was used in 2015 to send $20 billion in P2P payments. As a point of reference, the wildly popular emerging mobile and online P2P provider, Venmo, reported $1 billion in transfers during the month of January, up 250 percent from the prior January. With the additional reach of ClearXchange participants, Chase customers will now be able to digitally send and receive payments to 65 percent of the digital banking population in the United States, placing it in a position to experience significant growth to its digital solution.

With both remittances and P2P payments, online and mobile channels are seizing share from traditional channels. Even though the in-person agent model in remittances and P2P payments via cash and checks will remain a viable solution for many consumers, today's growth is being driven by digital models.

No doubt emerging players are threatening traditional companies for remittance and P2P dollars. However, financial institutions and established money transmitters are evolving, and based on the numbers, remain valuable payments providers. Given this environment, financial institutions and traditional remittance providers that don't evolve to embrace the digital remittance and P2P economy are at serious risk of losing share. And the threat isn't just coming from emerging companies. In fact, you can call me a traditionalist, but I think evolving traditional financial institutions and remittance providers are positioning themselves to remain the dominant providers of P2P and remittance payments.

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

July 11, 2016 in banks and banking, emerging payments, financial services | Permalink

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June 27, 2016


Between a Rock and a Hard Place?

Customer education encouraging safe payments practices has always been viewed by staff at the Retail Payments Risk Forum as a vital element in mitigating payments-related fraud. We have stressed this need time and time again in our posts as well as our numerous speaking engagements at payments-related conferences and events.

Financial institutions (FIs) have generally been identified as the group that should bear this responsibility as they own the account relationship, but with more intermediaries in the payments process, I think that others should also be involved. The advent of mobile banking and payments has introduced even more challenges since the financial institution doesn't get involved in the acquisition of the mobile device as that is normally handled by the mobile network sales representatives. My personal experience with these sales representatives is that once the device sale is done, they are more interested in selling me accessories or upgrading my data plan than they are teaching me about selecting and setting strong passwords or preventing malware and viruses from finding their way into my phone.

When I raise this issue with others, all too often I hear a pessimistic chorus that getting consumers to adopt strong security practices will always be a losing battle for FIs. They say that consumers will always choose convenience over security—that is, until they fall victim to fraud. And forget about any other player in the ecosystem taking on the education responsibility because if they have no liability for fraud losses, why direct funds to education when they could be deployed elsewhere?

The impact of fraud on a consumer's relationship with his or her financial institution has never been greater. We read every day about the increasing economic importance of the Gen Y or millennial segment. With an estimated 80 million people, they represent the largest segment of our country's bankable population. A late 2015 study by FICO on millennial banking habits revealed that 29 percent of respondents indicated that they would close all their accounts with a financial institution if one of those accounts experienced fraud. To make matters worse, one quarter of the survey participants indicated they would write a negative post on social media about their financial institution if they experienced a fraud incident.

So are financial institutions in a no-win situation? A ray of hope emerges from the same FICO study, which states that 41 percent of the millennials surveyed indicated that they recommended their FI to friends, colleagues, or family members after a positively handled fraud incident. Studies have consistently shown that payment security is a key concern of all customers, not just millennials. So although it may not seem fair that financial institutions have to shoulder most of the security education effort, the impact of not doing so could be significant. Perhaps it is time for a coordinated payments industry campaign to encourage consumers to adopt safer and more secure banking practices.

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

June 27, 2016 in banks and banking, financial services, payments, risk | Permalink

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October 27, 2014


ISO 20022 in the United States: What, When, Why, and How?

At the October 2014 Sibos conference in Boston, there was considerable discussion about the International Organization for Standardization (ISO) 20022 standard, which many major non-U.S. financial markets began moving toward a few years ago. ISO 20022 is a public international standard for financial sector global business messaging that facilitates the processing and exchange of financial information worldwide.

In Canada, adoption drivers include the use of domestic messaging standards in proprietary ways that created inefficiencies and the need for enhanced remittance data to add straight-through processing and automated reconciliation, according to a Canadian speaker at the conference. A speaker from Australia explained how the new real-time payment system that country is building will use ISO 20022, and one of the drivers is the desire for rich data to enable automation.

The United States is behind in the adoption curve, which raises the question, why? Several Sibos sessions included discussion of a study commissioned by an industry stakeholder group and conducted by the advisory firm KPMG. (The stakeholder group—which consists of representatives from the New York Fed, the Clearing House Payments Company, NACHA–The Electronic Payments Association, and the Accredited Standards Committee X9—formed to evaluate the business case of U.S. adoption of the ISO 20022 standard.)

KPMG interviewed participants of markets already moving toward adoption and found that adoption was largely driven by both infrastructure change, as in the Australian example, and regulatory requirements. In addition, many U.S. firms, beyond the large financial institutions and corporations, lack in-depth knowledge about ISO 20022. Two additional barriers in the United States are (1) the exact costs of ISO 20022 implementation are difficult to pinpoint, in part because they vary by participant, and (2) the country has no industry mandate for adopting the standard.

In one conference session, a speaker categorized some of the strategic reasons the United States should move forward, framing them in terms of the risks of nonadoption. These reasons include:

  • Commercial reasons: The U.S. industry will have to bear the incremental costs of maintaining a payments system that does not integrate seamlessly with an emerging global standard.
  • Competitive reasons: Many countries are experiencing such benefits of the ISO standard as increased efficiencies and rich data content, but U.S. corporations and financial institutions will fall farther behind.
  • Policy reasons: The U.S. market will become increasingly idiosyncratic, with more payment transactions conducted in currencies other than the U.S. dollar.

Recommendations from the KPMG study include initiating adoption of the ISO 20022 standard in this country first for cross-border activity, starting with wires, and then ACH. The U.S. industry should then reassess domestic implementation.

Because communication is keenly important to overcoming the lack of knowledge of ISO 20022 in the U.S. market, the stakeholder group is currently focusing on educating affected groups about the key observations and findings of the KPMG study.

No particular timetable or course of action has been determined for U.S. adoption, which makes it the ideal time for industry input. What's your institution's perspective on the adoption of the ISO 20022 standard in the U.S. market?

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

October 27, 2014 in financial services, payments, regulations | Permalink

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October 6, 2014


Starting Off on the Right Note with Mobile Enrollment

In Rogers and Hammerstein’s Sound of Music, the classic song “Do-Re-Mi” begins “Let's start at the very beginning / A very good place to start...” Such a suggestion is essential in ensuring that the person enrolling in a payments system is, in fact, who he or she claims to be. The USA Patriot Act requires financial institutions (FIs) to develop a formal customer identification program that validates the customer when the account is opened. This program must specify the documentation that is used for authentication.

However, once the account is open, FIs have greater latitude in their procedures for identifying customers when the FIs handle account access requests, such as when a customer requests a change of address or enrolls in a third-party program that uses a card that the FI has issued to the customer. At that stage, it’s up to an FI’s own risk-management policies as to what documentation to require.

This situation can be risky. For example, let’s look at what happens when a customer wants to add a payment card to a mobile wallet that a third party operates. When the customer adds the card—enrolls with the third party—how can the FI that issued the card know that not only the payment card being added but also the mobile phone itself belongs to the right individual? How can the issuer efficiently and effectively ensure that the payment card information being loaded on a phone hasn’t been stolen? Adding any sort of verification process increases the friction of the experience and can result in the legitimate user abandoning the process.

Most mobile wallet operators use several techniques to validate that both the mobile phone with the wallet and the payment card belong to the rightful customer. (These operators send a request to the issuing FI as part of their enrollment process.) Some FIs require the operator to have customers submit their payment card information along with their cards’ security code and additional data, such as the last four digits of the social security number. Others may require just the payment card number, expiration date, and card security code, although such a minimal requirement offers little protection against a stolen card being added to a criminal’s phone. Still others require the customer to submit a photo of the payment card taken with their phone to verify possession of the card. If the issuer can obtain some of the phone’s device information, it can increase the level of confidence that the authorized cardholder is using their phone.

Regardless of what process is used, having strong identification controls during the initial enrollment step is essential to a sound risk management program.

Photo of Douglas A. King

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

October 6, 2014 in authentication, financial services, mobile banking, mobile payments, payments systems | Permalink

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March 24, 2014


The Fraudsters Are Omni-Channel--and Omnipresent

"Omni-channel banking" is an in-vogue term for what bankers have known for quite some time: customers can access multiple channels to conduct their banking, have a preference for one over the others, and that preference to a large degree reflects their ages. Despite their primary preference, these consumers are likely to use multiple delivery channels, and when they do, they want a seamless experience when moving from one to another. The banking industry has struggled to successfully implement such an experience. Achieving this seamlessness is difficult because the industry has historically had a vertical organizational structure, in which each distribution channel has its own strategic plan and sometimes even an independent technology, which leads to differences among the channels. For example, if a customer were to check his or her account balance from an ATM or automated call center, the balance can be different from the balance they would get from a teller inside a branch.

Unfortunately, criminals have also adopted omni-channel usage, and at an even faster pace—they are not concerned with having a transparent or seamless experience. In fact, they seem to be more successful when there are disparate systems because that makes the detection of fraudulent activity more difficult. For example, we have seen criminal attacks move from in-branch armed robberies to ATM cash-out cyberheists. Why risk a physical confrontation and mandatory jail sentence when you can work anonymously and actually get a greater haul? We are also aware of cross-channel fraud activity within the electronic channels. In one case, e-mail phishing attacks led to a customer unwittingly disclosing online banking credentials (user ID and password) and then fraudulent payments or wires being initiated through the online channel. In a recent post, we talked about how criminals often target call centers. They use social engineering techniques to gain sufficient account information to fraudulently access accounts through a variety of channels.

A lesson from these incidents is that financial institutions must take a holistic view of fraudulent activity and not just a channel-specific view. For major losses, they have to perform forensics to determine the channel where the fraudulent effort began not just the channel where the actual fraudulent transaction occurred. Only after such investigative work can the financial institution identify the weak points in its system and processes and take the necessary steps to fortify them to provide a higher level of protection against future attacks.

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

March 24, 2014 in banks and banking, crime, cybercrime, financial services | Permalink

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July 1, 2013


The Cost of "Free"

Many retail-centric banks have found themselves in a fee-revenue dilemma as the impact of regulations regarding overdraft fees and debit card interchange revenue begins to be felt. After decades of providing "free" services to consumers, these banks are under significant customer pressure to continue this practice even as they roll out new products and services. But this pricing model poses financial risk. The operating expenses of the bank are increasing at the same time that the banks are receiving minimal—if any—incremental revenue.

I recently participated in a conference that had a session comprised of a panel of four MBA students. The goal of the session was for the audience of bankers to better understand the driving forces for financial service decisions by the Gen Y, or millennial, customer. (I wrote a bit about this panel in a previous post.) One eye-opening statement universally shared by the panel was the expectation that mobile banking and mobile banking services be provided free of charge. When asked for a justification, they believe that by using the mobile channel they "saved" the bank money over writing a check or going into a branch office. When further questioned as to how the bank was going to pay for the development and operating expenses of such new products and services, their response was essentially that they believe the bank earns sufficient revenue from its lending operations, including credit cards and installment and mortgage loans. I am sure that many other consumer segment groups have this attitude as well.

After Regulation II capped debit card interchange fees for banks with assets exceeding $10 billion, some banks announced they would begin charging a monthly debit card fee. Consumer and media response was so negative that banks withdrew the proposed fee changes. Subsequently, many banks changed their checking account service fee waiver conditions by raising minimum balance requirements, requiring other account relationships (to provide additional revenue support), or eliminating some previously bundled services. The Bankrate 2012 Checking Survey found that only 39 percent of banks were offering free checking without a minimum balance requirement or maintenance fee. This percentage is down from 45 percent in 2011 and 76 percent in 2009. Credit unions have not followed suit—the number of them offering free checking is holding fairly steady at around 72 percent.

Is there anything banks can do to shift consumers' expectations and ease some of the financial risk associated with controlling operating expense levels? We would like to hear from you.

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

July 1, 2013 in financial services, mobile banking, regulations | Permalink

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