Take On Payments


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.

September 8, 2015

Why Is the U.S. Card-Present Fraud Breakout Not Present?

Before answering the question the title poses, let me introduce myself. I'm the newest blogger in the Risk Forum. Recently, I was the faster-payments-product guy in the Retail Payments Office (RPO) at the Atlanta Fed. While in the RPO, I was a cheerleader who pushed and cajoled the industry to get same-day ACH off the ground. Incidentally, same-day ACH is due to become available universally as early as September 2016 due to a recent rule change passed by NACHA.

Back to my question—while doing some research on expanding fraud data coverage in the Fed's upcoming triennial payments study, I came across a gap in publicly available detailed fraud data for the United States compared to other geographies. As the table shows, the gap is evident from the Fourth Report on Card Fraud published in July 2015 by the European Central Bank. You probably see the "Not available" designation in the card-present subcategory.


What gives? What could be gained if this information were made available? As the footnote shows, the high-level data is taken from the Fed's last triennial payments study published in 2014. And as a previous post notes, the United States does not have a publicly available, single, uniform repository for payments fraud data. Back in 2009, the problem was covered in detail in the briefing paper "The Benefits of Collecting and Reporting Payment Fraud Statistics for the United States" by my colleague Rick Sullivan from the Kansas City Fed. In fairness, it should be noted that information is available in the United States to varying levels of detail as a paid service or through surveys conducted by such organizations as the Association of Financial Professionals and is typically distributed only to the organization's membership.

So that you know what we are missing out on in the United States, here are capsule descriptions of each card-present fraud type:

  • Counterfeit/Skimming: Fraud is perpetrated using an altered or cloned card.
  • Lost/Stolen: Fraudulent transactions result from the use of a lost or stolen card.
  • Card not received: A newly issued card in transit to a card holder is intercepted and used to commit fraud.
  • Fraudulent application: A new card is issued based on a faked identity or using someone else's identity.
  • Other: This is a catchall category for fraud not covered above.

The card-not-present subcategory, which is fully reported on in the triennial study, generally covers fraudulent payments initiated online, or by mail or telephone. Unlike card-present fraud, this type of fraud is not usually subdivided any further.

It should be noted that the current study was the first of the triennial series to report on fraud. Unfortunately, scope limitations precluded breaking out fraud further. As it is, the current study offers a wealth of payment and fraud data for cards and all other forms of noncash payments.

Adding a level of specificity for card-present fraud in the United States will help in tracking the movement of fraud from one type to another and the migration of fraud to other countries. In the United States, fraud is likely to further shift from card present to card not present due to increased counterfeiting controls at the point of sale from the anticipated broad adoption of EMV (chips) for cards and POS terminals. The Federal Reserve, in partnership with other payment system stakeholders, hopes to track these and other developments by collecting additional fraud data for the next triennial study due to be published in 2017.

What suggestions do you have for identifying and collecting other fraud data?

By Steven Cordray, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

September 8, 2015 in EMV, fraud | Permalink | Comments (0)

August 31, 2015

A Swing and a Miss

"Keep your eyes on the ball." I'm guessing my son heard those words at least 20 times a game this past baseball season. If you can't follow the ball, then your chances of a successful plate appearance are pretty slim.

Departing from the usual risk-related prose and taking a signal from the blog's name Take On Payments, I want to offer my thoughts on mobile payments. This topic floods my payments news feeds and is the subject du jour at nearly every payments-related event. Mobile payments can mean many things to many people, but one of the hottest areas is mobile at the point of sale (POS), also known as proximity payments—that is, what Apple Pay, Starbucks, and Samsung Pay among others all offer.

And this is where I think the payments industry is taking its eyes off the ball. Why do consumers want to use mobile phones to replace cash or cards at the POS? A key barrier cited by consumers who have not adopted mobile proximity payments is their satisfaction with current payment methods. So what is the best way to get consumers to use their mobile devices to replace cash or cards at the POS?

The mobile phone has significantly changed the way people interact. It's almost comical to me that the device has retained the word phone. While there will always be people who want to hear a voice or interact directly with another person, the mobile device is turning us into a society that prefers messaging over speaking and interacting through the device rather than face to face. (My nieces text each other while sitting in the same room!) Furthermore, we have come to expect information to be readily available to us whenever and wherever we desire it. People don't like waiting, and the mobile device has intensified this impatience. To understand consumer behavior in light of this mobile revolution, we don't have to look any further than the reduction of bank branches and staffing coupled with the rise of mobile banking solutions.

Yet the proximity payment solutions don't address consumer behavior with their mobile devices. I understand merchants valuing the ability of proximity payments to provide loyalty programs and targeted offers, but do these extra services really address consumers' core needs and wants? It seems to have worked for Starbucks in a closed-loop environment but has yet to be replicated in an open-loop environment. (Closed loop means that the payment is usable only at a provider's place of business, as for the Starbucks app. Open loop means the payment, like Apple Pay, is usable anywhere that has the infrastructure to read the app.)

By keeping the focus on the consumer, it seems to me that the mobile payments industry can work on reducing the physical interaction of payments and current wait times associated with the payment process. Uber, Chipotle, and the Starbucks mobile app are evolving to address these consumer needs. These apps essentially remove the payment from the POS (some would say that they make the payment invisible) and allow for minimal personal interaction and waiting times.

Hence, I predict the growth of mobile payments will come not from the POS but rather through mobile in-app payments. That's where I'd be setting my sights on the mobile payments diamond. Perhaps this will create a healthy discussion (hopefully not a bench-clearing brawl), but I think mobile at the POS is a swing and a miss. What do you think?

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

August 31, 2015 in innovation, mobile payments | Permalink | Comments (0)

August 24, 2015

Payroll Cards at Interstate Speed

State lines happen fast in New England, which is where I call home. In this part of the country, it's not uncommon for people living in one state to commute for employment to a neighboring state. One could pay property tax enjoying the motto "Live free or die" (New Hampshire) while paying income tax to the Bay State (Massachusetts). Employees may not take much notice of state employment law, but employers almost certainly do. I'm thinking that minimum wage, tax rates, and corporation law would be key factors for an employer to consider, but do payroll card laws also fit into the evaluation?

Payroll cards are prepaid cards onto which an employer loads wages. They offer an alternative to paychecks or direct deposits, and are subject to a different sort of regulation. Outside of a federal law prohibiting an employer from mandating the exclusive use of a payroll card, states are generally free to develop their own legislation governing payroll cards. In Maine, for example, employers can offer payroll cards if they give their employees free access to full pay. Connecticut goes one step further, requiring employers to provide certain disclosures and prohibiting overdrafts and certain fees. Massachusetts does not have any law for or against payroll cards. Somewhere in the middle is Vermont, which allows payroll cards with certain disclosures as long as employees receive three free transactions monthly. Proposed New York legislation would go so far as to require employees to sign a written consent form—printed with a large, 12-point font—to be retained for six years following the cessation of the employment relationship.

And that's only in my home of New England. Out of 50 possibilities, I've mentioned only fragments of only five state laws. Outside of this area, payroll-card-related legislation is being introduced or pending in 12 states.

Regulation E has covered payroll cards since 2006. Regulation E includes (i) protection to employees so they do not have to receive wages via electronic funds transfers with a particular institution; (ii) access to statements, balances, and transaction histories; (iii) clear and conspicuous disclosures; and (iv) error resolution and limited liability. In January 2016, we expect the final version of the Consumer Financial Protection Bureau's Rule on Prepaid to be published.

Because payroll cards are already covered under Regulation E, only two significant issues are applicable in the pending rule. First, credit and overdraft services, while not prohibited, will be subject to compulsory use provisions and Regulation Z's definitions of credit and periodic statement requirements. Second, disclosures will carry a bold print warning, "You do not have to accept this payroll card. Ask your employer about other ways to get your wages."

What federal regulation doesn't touch is the type and amount of fees assessed on payroll cards. Regulation E provides only that fees are disclosed. Certain industry stakeholders such as National Branded Prepaid Card Association, Consumer Action, MasterCard, and the Center for Financial Services Innovation have worked to develop industry standards. Simply speaking, most agree that cardholders should have access to full wages each pay period without cost and that they should be able to perform basic functions without incurring unreasonable fees.

Best practices give the industry the ability to fill gaps and stay nimble to changing technology, fraud schemes, and consumer needs. The CFPB even says in their proposed rules, "Employees may not always be aware of the ways in which they may receive their wages, because States may have differing and evolving requirements." Does state-by-state regulation ultimately fill the gaps needed, especially in a system that crosses state lines so often?

And in case you didn't know it, National Payroll Card Week starts September 7, a day that also happens to be Labor Day.

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

August 24, 2015 in prepaid, regulations, regulators | Permalink | Comments (1)

August 17, 2015

Pigskin and Payments

For those who know me well, they know that I find August to be the slowest-moving month of the year. It's not because of the oppressive southern heat and humidity, but rather it's my anticipation for football season. To help speed along the "dog days of summer," I generally read my fair share of prognostication publications. Alongside the predictions, improving player safety has become a key discussion topic as the season approaches.

Armed with data showing an increase in injuries as well as long-term negative effects from playing the sport, football's governing bodies on both the collegiate and professional levels are instituting rule changes to make the game safer. Equipment manufacturers are introducing new gear to improve safety and individual teams are adding new experts to their medical staffs all in the name of player safety.

Ironically, while there is a focus on improving player safety, football players continue to get stronger and faster aided by advancements in nutrition and workout regimes. As player strength and speed improves, this contact sport becomes more vicious and dangerous. And as a fan, I'll admit that I find watching a game featuring stronger and faster players more exciting. I do not want to see players injured, but at the same time I enjoy the excitement that comes with hard tackles and big hits.

Does this state of football sound at all like the current state of the U.S. payments industry? To make payments safer, public and private entities are leading literally hundreds of initiatives across various payments rails. Network rule changes are taking place and new technologies are being harnessed all in an effort to better secure payments. At the same time, start-ups, established payment companies, payment associations, and the Federal Reserve are collaborating to improve the speed of payments.

It's hard not to get excited about the possibilities of faster payments, from important just-in-time supplier payments to simple repayments for borrowing money from a friend or family member. However, can securing payments better derail the speed of payments? By way of example and personal experience, my more secure EMV (chip) credit card has clearly reduced the speed at the point-of-sale for my card payment transactions.

But just as player strength and speed has evolved alongside safety through rule-making and technology (think about leather football helmets here), I think we have seen the same progression within the payments industry. I think football remains as exciting as ever, and the payments expert in me is clearly excited about the future of payments.

Speed and safety are not to be viewed as mutually exclusive, and I am confident that the payments industry supports this view. In both football and payments, elements of risk will exist, regardless of safety measures in place. Finding the right balance between speed and safety should be the goal in order to maintain an exciting football game or efficient payments system. I can't wait to see what lies ahead on the gridiron and within the payments industry.

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

August 17, 2015 in emerging payments, EMV, fraud, innovation, risk management | Permalink | Comments (0)

August 10, 2015

Payments at the Speed of Electricity--What Could Go Wrong?

From mobile phones to the Internet—it's hard to think of many of today's great inventions that aren't beholden to the wonder of electricity and the pace at which it can facilitate the management and movement of data. Electricity has underpinned numerous payment advances already. Now, harnessed current promises to help us build a payments scheme that will make it possible to pay (and be paid) almost as fast as one can conceive of the need. That happy thought might cause us to forget this otherwise widely known truth: electricity is just as efficient in yielding a bad outcome as it is in bringing about a good one.

Those who have begun work to design a faster payment scheme will obviously be thoughtful about everything, from functional design and basic operation to ongoing management of the new system. Giving due consideration to what could go wrong may not be the most glamorous task, but it's necessary.

One way to identify potential problems is to reflect on lessons from the past. Look at the photograph below and see if you know what's depicted.

Source: Wikimedia Commons

If you guessed the photo shows a bank run, congratulations. As most of us know, rapid, heavy cash withdrawals constitute a bank run and can be caused by a variety of things, including diminished confidence in a bank, in the banking system broadly, or the local economy, among other things.

Back to faster payments. A faster payment platform offers many upsides, but for all its promise, it could also offer the unexpected, the unintended. Circa 1929, when the picture was taken, making a run on a bank meant standing in line and waiting for a teller to retrieve your money. Circa 2015, even with ATMs and other improvements, bank runs still have some natural choke points, including weekends, when customers know with certainty that their bank is closed for at least one day, and limits on ATM withdrawal amounts in a 24-hour period. A fast, 24/7, universally accessible system could offer depositors a way to drain cash reserves like never before.

What to do? Setting aside broader systemic actions, it seems reasonable that individual banks consider measures to guard against this possibility. To deal with runs in the "old days," withdrawals were limited or even fully suspended for a time. These mitigations could be efficiently, readily mimicked and become part of the new system's basic construct. Automated tools capping withdrawal amounts might be in order. Logic in the core platform that considers the full range of activity across institutions and accounts and that allows for automated or manual controls (or a combination of these) may also make sense. Tailored rules could prove worthwhile.

The considerations should be fulsome—across not just this, but a range of issues—among those who may design, build, and operate the system and also those who may use it. Meanwhile, here's to anticipating a new system that moves money as fast as electricity allows, insulated from shocks.

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

August 10, 2015 in innovation | Permalink | Comments (0)

August 3, 2015

Friendly Fraud: Nothing to Smile About (Part 2)

Last week's post discussed the increasing frequency of friendly fraud and the problems it presents for e-commerce merchants. A transaction that could be classified as friendly fraud might actually be one the customer just forget about, or one involving a family member using the customer's card without permission, or one with the customer actually not receiving the goods. So the merchant really can't just assume the customer is out to commit fraud and take an aggressive approach in dealing with the customer. The merchant would probably then have lost the customer's business altogether. But with the burden of proof on the merchant, the merchant must adopt a number of best practices to help minimize losses.

A company that works with merchants to both prevent chargeback disputes and respond to them has published a detailed guide (the site requires e-mail registration for access to the guide) to help merchants deal with friendly fraud. The following list includes some of the guide's best practices:

  • Promote a clear and fair refund policy that encourages customers to contact the merchant directly instead of the card issuer.
  • Make sure that the name of the business is on all billing statements—clearly, to avoid confusion.
  • Ensure that the customer communication channels—such as a call center or e-mail—are accessible.
  • Be responsive to customer inquiries.
  • Clearly communicate shipping charges and delivery timeframes to avoid misunderstandings about the total cost or delivery date of orders.
  • Always obtain the card security code and use address validation services. For larger-value purchases, consider the use of delivery confirmation and other validation services.
  • With digital goods or services, consider using a secondary verification tool—an activation code or purchase confirmation page—to ascertain that the customer received the goods.
  • When there is a chargeback, make every effort to contact the customer directly to attempt to resolve the matter. While the contact may not resolve this particular situation, it may offer a lesson that might help prevent future chargebacks from other customers.
  • Keep a database of customers who initiate chargebacks that appear fraudulent. Research shows that customers who deliberately defraud merchants and succeed at it are very likely to do it again.

As with all efforts to fight payments fraud, merchants must study their own customer base. They should identify their particular risks and then employ the practices that will help them best mitigate their fraud losses.

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

August 3, 2015 in cards, fraud | Permalink | Comments (0)

July 27, 2015

Friendly Fraud: Nothing to Smile About (Part 1)

Friendly fraud (also referred to as chargeback fraud or first-party fraud) occurs when someone makes an online purchase then later requests a chargeback from the bank. The person has received the goods or services, but claims they were defective or the transaction never authorized. Sometimes this happens because of buyer's remorse—the customer just doesn't want to have to explain his or her regret to the merchant, preferring to initiate a chargeback and let the bank resolve it with the merchant. Sometimes the buyer's remorse comes from a child making purchases, particularly digital goods, using the parent's card, or when a merchant's refund time limit has passed but the cardholder still wants to be reimbursed.

While there certainly can be legitimate disputes, friendly fraud is becoming a growing problem for e-commerce merchants. Not only are the merchants out the cost of the goods or services, but they also incur administrative costs and fees from the card-issuing bank. Companies selling digital goods, office supplies, or electronics—as well as auction sites—seem to be the most frequent targets of friendly fraud, but other types of businesses can also be affected.

One of the main difficulties merchants experience in combating this fraud is predicting or recognizing when it first occurs, since it often occurs on the account of a "good" customer. And with these remote purchases, the merchant is at a disadvantage in determining if a legitimate cardholder made the purchase or the goods were actually received by the cardholder.

Because the burden of proof is on the merchant, the merchant community has started to implement a number of tactics to help reduce this increasing problem. In our next installment on this topic, we will discuss some of those tactics.

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

July 27, 2015 in cards, fraud | Permalink | Comments (0)

July 20, 2015

Unsafe at Any Speed?

If you're a Corvair enthusiast, you likely get the title's reference to Ralph Nader's book that polemically accused manufacturers of resistance to the advancement of automotive safety. Shift your thoughts from automobiles, axles, and bumpers to payments, cyberattacks and data breaches. Then consider this question—if we successfully speed up payments, is payment safety more likely to advance or retreat?

I hear the question often. Since I first blogged about this topic in January, I've attended several conferences set in the context of building a better, faster, more efficient payments system. If the conversation hasn't gone straight to "safety," the topic has surely been broached before closing. The answers that presenters offer, in terms of how we make payments more secure, remain unchanged from earlier this year. The updated summary follows.

  • Innovate. Make full use of such things as biometrics and tokenization. Do not fear but rather make use of the best things coming from the cryptocurrency world.
  • Collaborate and coordinate. Share everything, taking full advantage of groups of all types to facilitate deployment and spread of best practices, among other things.
  • Prevent and plan. In a continuous and ever-improving activity, make use of such things as enhanced threat detection and continue to layer security measures. Also, educate fully, across the spectrum of both providers and users.
  • Track and report. We must do more of this in a frank, transparent way and it must be timelier.

Emphasizing and pursuing all these goals is still right in my view, yet something seems missing. I believe what's missing is a more expansive, easily accessible law enforcement regime—something that more closely parallels what's available for conventional crime fighting.

There has been good news, of late, in that various law enforcement agencies have both apprehended and successfully prosecuted cybercriminals of all sorts. What's important about this is, as law enforcement has more success, there is hope that miscreants will have an increasing expectation of getting caught. Let's assume a drop in crime rates is highly correlated to the likelihood or certainty of being caught. Self-test the theory by thinking of it this way. How often do you exceed the speed limit (answer silently to yourself). Now consider—how often do you speed when a patrol car is in the lane right next to you? It's imperative that law enforcement continue to evolve and improve such that the criminals who contemplate cybercrime increasingly anticipate they'll be caught.

The cliché that faster payments will mean faster fraud if we don't have faster security is somewhat beside the point. The fact is cybercrime has been and remains a material and looming threat. The world is all but fully a digital one and that means our police have to be able to put more—and more effective—digital patrol cars on the digital highway. Until then, to varying extents, payments are likely to be unsafe—at any speed.

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

July 20, 2015 in crime, cybercrime, innovation, law enforcement, payments risk | Permalink | Comments (0)

July 13, 2015

Biometrics and Privacy, or Locking Down the Super-Secret Control Room

Consumer privacy has been a topic of concern for many years now, and Take on Payments has contributed its share to the discussions. Rewinding to a post from November 2013, you'll see the focus then was on how robust data collection could affect a consumer's privacy. While biometrics technology—such as fingerprint, voice, and facial recognition for authenticating consumers—is still in a nascent stage, its emergence has begun to take more and more of the spotlight in these consumer privacy conversations. We have all seen the movie and television crime shows that depict one person's fingerprints being planted at the crime scene or severed fingers or lifelike masks being used to fool an access-control system into granting an imposter access to the super-secret control room.

Setting aside the Hollywood dramatics, there certainly are valid privacy concerns about the capture and use of someone's biometric features. The banking industry has a responsibility to educate consumers about how the technology works and how it will be used in providing an enhanced security environment for their financial transaction activities. Understanding how their personal information will be protected will help consumers be likelier to accept it.

As I outlined in a recent working paper, "Improving Customer Authentication," a financial institution should provide the following information about the biometric technology they are looking to employ for their various applications:

  • Template versus image. A system collecting the biometric data elements and processing it through a complex mathematical algorithm creates a mathematical score called a template. The use of a template-based system provides greater privacy than a process that captures an image of the biometric feature and overlays it to the original image captured at enrollment. Image-based systems provide the potential that the biometric elements could be reproduced and used in an unauthorized manner.
  • Open versus closed. In a closed system, the biometric template will not be used for any other purpose than what is stated and will not be shared with any other party without the consumer's prior permission. An open system is one that allows the template to be shared among other groups (including law enforcement) and provides less privacy.
  • User versus institutional ownership. Currently, systems that give the user control and ownership of the biometric data are rare. Without user ownership, it is important to have a complete disclosure and agreement as to how the data can be used and whether the user can request that the template and other information be removed.
  • Retention. Will a user's biometric data be retained indefinitely, or will it be deleted after a certain amount of time or upon a certain event, such as when the user closes the account? Providing this information may soften a consumer's concerns about the data being kept by the financial institution long after the consumer sees no purpose for it.
  • Device versus central database storage. Storing biometric data securely on a device such as a mobile phone provides greater privacy than cloud-based storage system. Of course, the user should use strong security, including setting strong passwords and making sure the phone locks after a period of inactivity.

The more the consumer understands the whys and hows of biometrics authentication technology, I believe the greater their willingness to adopt such technology. Do you agree?

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

July 13, 2015 in biometrics, consumer protection, data security, privacy | Permalink | Comments (0)

July 6, 2015

Growing, Growing, Gone!

As we've blogged before, check writing has been steadily declining as electronic payments have grown. For example, the number of checks written in 2012 was 21 billion, down from 27.8 billion in 2009, according to the 2013 Federal Reserve Payments Study. We may be writing fewer checks than ever, but more than anything, we want the convenience of depositing our checks with mobile devices. A 2013 survey by ath Power Consulting found that mobile remote deposit capture (mRDC) is the "most sought-after mobile banking feature" among consumers. And financial institutions are answering this demand. According to 2014 surveys from Federal Reserve Banks (the Dallas Fed's, for example), about 48 percent of responding institutions are currently offering mobile capture and another 41 percent are planning to offer it within the next two years.

With mRDC in such demand, solutions providers and financial institutions should be investing in risk management strategies. But if check writing is a declining business, will mRDC risk management investments end up on the disabled list? Financial institutions must look at the potential losses and how they occur, evaluate the means to minimize these, and carefully weigh these factors against the dwindling check industry.

The mRDC channel faces two primary loss challenges: fraudulent items and duplicate check presentment. A fraudulent item might be an altered, forged, or counterfeit check; it can also be an intentional duplicate presentment. The other challenge occurs when a customer unintentionally presents a deposited item a second time. Research and anecdotal evidence suggest many duplicate presentments result from customer errors. These represent a growing customer education need. Financial institutions must find room in the allocated lineup and spending cap for fraud and duplicate detection enhancements.

Handling duplicate check presentments landed an all-star position on the agenda at most payments operation conferences this past year. Duplicate check presentments mean returns and adjustments, which in turn mean time and money for the financial institutions. When duplicate presentment involves more than one bank of first deposit, losses are often sustained from misunderstanding holder-in-due-course rights and return-versus-adjustment processes. Financial institutions often need to reconstruct what happened, analyze the facts, and possibly consult legal counsel.

But rather than handling these risks with expensive roster moves, considering the declining use of checks, financial institutions can meet the threat at the origin, through customer education and enforcement policies. Financial institutions that offer mRDC can make disclosed stipulations. For example, they can require that the original check be destroyed after confirmation, or that checks have a specific restrictive endorsement that includes "for mobile deposit only." Ultimately, if a consumer deposits a check twice, financial institutions can charge a fee or suspend service. In general, customers want to avoid fines, so they tend to play within the rules when fines are looming. If training customers is a home run in mitigation, then the grand slam is having detection systems that support the stipulations and rules put into place.

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

July 6, 2015 in checks, consumer protection, mobile banking, mobile payments | Permalink | Comments (0)

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