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.

November 16, 2015

Is It Bigger Than a Bread Box?

The answer is yes and no. A payment card in physical form clearly is not bigger than a bread box, but it certainly is a symbol of something bigger. The card is an access device to an account. It could be a birthday gift to my favorite Italian restaurant, a debit card issued by my bank, a general purpose reloadable prepaid card purchased at my local pharmacy, or a card accessing a credit line, and the list goes on. You can't just say, “I used a plastic card to pay for my Italian dinner” and have someone know exactly which card type was used.

Let's play the classic 20-questions game, Take On Payments-style. I'll be thinking of a type of financial account, and you guess the type of account based on the 20 features below. Good luck!

  1. Allows you to earn interest on your account balance.
  2. Offers a loyalty program at selected merchants.
  3. Has no annual or monthly fee.
  4. Can be used at any domestic ATM.
  5. Can be used to pay bills.
  6. Allows person-to-person money transfers.
  7. Offers customer service 24/7.
  8. Offers cash-back rewards.
  9. Is usable for purchases in-person (POS) or online.
  10. Protects against unauthorized purchases and fraud.
  11. Allows access to account information via online or mobile application.
  12. Has budgeting features.
  13. Connects you to more than one account and allows you to manage multiple accounts under one main account.
  14. Issues mobile alerts.
  15. Has optional plastic card; can be all-virtual management.
  16. Offers mobile check deposit.
  17. Allows stop payments on previously scheduled transactions.
  18. Offers the ability to cover some purchase transactions over the account balance.
  19. Accepts direct deposit via ACH for payroll or other deposits.
  20. Allows you to order checks on the account and pay bills with a check.

Which account type did you guess? If I were to tell you that what I had thought of was a prepaid account, would you be surprised? I was thinking of prepaid as bigger than a bread box. It's not a card, or payment channel; it is an account type. Payment transactions are sent to and from a prepaid account just like a checking account. The financial institution and program manager determine the account name and features, and where accounts can be opened.

However, the payments industry needs to be careful that marketing differences don't lead to the misperception that these accounts are fundamentally different from checking accounts. If we let perceptions cloud the true purpose these accounts serve—it is essentially a transaction account, just sold differently—then regulations and risk controls may not address the actual risks. It is inconsistent to regulate transaction accounts offering the same services based on how the account was opened and the type of organization servicing the account, unless the regulation is addressing the actual risk injected at those points. In order for consumer protections and compliance to be achieved consistently, risk controls and regulations should address the operational aspects of these transaction accounts, rather than the marketing name assigned to it.

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

November 16, 2015 in banks and banking, prepaid | Permalink


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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


Studies by the Federal Reserve and others show the least expensive and most convenient method for a LMI employee to receive their pay is a payroll card. As noted in this article it is also the most regulated. Why so much attention is given to payroll cards when 80% of employees are direct deposit and faced with exorbitant bank fees for overdrafts and minimum balance is mind boggling. The premise that if it is offered by the employer it must be bad for the worker is painting an entire population with the same prejudicial brush

Posted by: Carl Morris | August 25, 2015 at 11:45 AM

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December 22, 2014

Top 10 Payments Events in 2014

As the year draws to a close, the Portals and Rails team would like to share its own "Top 10" list of major payments-related events and issues that took place in the United States this year.

#10: Proposed prepaid rule. After a long wait, the Consumer Financial Protection Bureau issued its proposed rules on general reloadable prepaid cards in November. While the major players in the prepaid card industry had already adopted most of the practices included in the proposed rule, the proposal allowing overdrafts and credit extensions is likely to generate differing perspectives during the comment period before a final rule is adopted in 2015.

#9: Regulation II. The U.S. Circuit Court of Appeals for the District of Columbia upheld the Federal Reserve Bank's rules regarding interchange fees and network routing rules, reversing a 2013 decision. Notice of appeal on the interchange fee portion of the ruling has been given, but resolution of the network routing rules has cleared the way for the development of applications supporting routing on chip cards.

#8: Payment trends. The detailed Federal Reserve Bank's triennial payments study results were released in July 2014, continuing the Fed's 15-year history of conducting this comprehensive payments research. Cash usage continued to decline but remained the most-used form of payment in terms of transaction volume.

#7: Card-not-present (CNP) fraud. With the growing issuance of chip cards and the experience of other countries post-EMV migration—with substantial amounts of fraud moving to the online commerce environment—the payments industry continues to search for improved security solutions for CNP fraud that minimize customer friction and abandonment.

#6: Faster payments. Continuing a process it began in the fall of 2013 at the release of a consultative white paper, the Federal Reserve Bank held town halls and stakeholder meetings throughout the year in preparation of the release of its proposed roadmap towards improving the payment system.

#5: Virtual currencies. Every conference we attended had sessions or tracks focused on virtual currencies like Bitcoin. While there was some advancement in the acceptance of Bitcoin by major retailers, the number of consumers using the currency did not rise significantly.

#4: Mobile payments. The entry of Apple with its powerful brand identity into the mobile payments arena with Apple Pay has energized the mobile payments industry and brought improved payment security through tokenization and biometrics closer to the mainstream. (Apple Pay's impact on mobile payment transaction volume will likely be negligible for a couple of years.) Additionally, the use of host card emulation, or HCE, as an alternative contactless communications technology provides another option for mobile wallet development.

#3: EMV migration. The frequency and magnitude of the data breaches this year have spurred financial institutions and merchants alike into speeding up their support of EMV chip cards in advance of the October 2015 liability shift.

#2: Third-party processors. Regulators and law enforcement escalated the attention they were giving to the relationships of financial institutions with third-party processors because of increased concerns about deceitful business practices as well as money laundering.

And…drum roll, please!

#1: Data breaches. The waves of data breaches that started in late 2013 continued to grow throughout 2014 as more and more retailers revealed that their transaction and customer data had been compromised. The size and frequency of the data breaches provided renewed impetus to improve the security of our payments system through chip card migration and the implementation of tokenization.

How does this list compare to your Top 10?

All of us at the Retail Payments Risk Forum wish our Portals and Rails readers Happy Holidays and a prosperous and fraud-free 2015!

Photo of Mary Kepler Photo of Doug King Photo of David Lott Photo of Julius Weyman

Mary Kepler, vice president; Doug King, payments risk specialist; Dave Lott, payments risk expert; and Julius Weyman, vice president—all of the Atlanta Fed's Retail Payments Risk Forum.

December 22, 2014 in chip-and-pin, cybercrime, data security, EMV, innovation, mobile payments, prepaid, regulations, third-party service provider | Permalink


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November 17, 2014

Consumer Prepaid Protections May Be Catching Up with Prepaid Use

On November 13, the Consumer Financial Protection Bureau (CFPB) issued its much-anticipated notice of proposed rulemaking of consumer protections for the prepaid market. This proposed rule covers multiple facets related to the prepaid industry, including disclosure requirements, fraud protection, access to account information, and the provisioning of credit via overdraft. Today's blog will provide a brief, high-level summary of this rule.

What is and isn't covered under this rule?
This rule redefines a "prepaid account" under Regulation E (Reg E). Prepaid products include cards, codes, and other devices capable of being loaded with funds that are not currently covered by Reg E and are usable at multiple, unaffiliated merchants and ATMs, and for person-to-person transfers. Gift cards, and certain related cards, are excluded.

Disclosure requirements
The rule requires that card issuers use two forms to disclose fees. The short form discloses four types of fees: monthly account fees, cash reload fees, ATM transaction fees, and purchase transaction fees. The rule proposes the use of a model form that establishes a safe harbor for compliance to the short-form requirement. The long form describes all of the potential account fees and the conditions under which these fees are assessed, as well as the fees that short form includes. Both disclosures must be made available to the consumer before the opening of an account.

Fraud protection
The rule modifies Reg E to require that issuers adopt error resolution procedures and limited liability for prepaid accounts. Reg E coverage limits a prepaid consumer's liability for unauthorized transfers to $50, assuming that the consumer gives timely notice to the financial institution and the card has been registered. Further, financial institutions would be required to resolve certain errors to prepaid consumer accounts.

Access to account information
The rule also modifies Reg E to require that financial institutions provide prepaid account holders with free access to periodic statements or that they make available to the consumer the account balance and at least 18 months of account transaction history. These periodic statements and transaction histories must include a summary of monthly and annual fees in addition to a listing of all deposits and debits.

Overdraft protection
The rule allows for issuers of prepaid accounts to offer overdraft services and other credit features. However, issuers that offer these services or features for a fee are subject to Regulation Z (Reg Z) credit card rules and disclosure requirements which, among other things, requires them to evaluate whether consumers can repay their debt. The issuer is required to obtain a consumer's consent before adding these services to accounts and must provide consumers with a periodic statement of the credit and provide at least 21 days to repay the debt. Should a product offer overdraft or other credit features, it must be disclosed in the disclosures of the short and long forms.

The CFPB is seeking public comment for a 90-day period, beginning with its publication in the Federal Register.

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

November 17, 2014 in consumer protection, prepaid, regulations | Permalink


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January 28, 2013

Do GPR Prepaid Cards Pose Significant Money Laundering Threats?

When it comes to laundering proceeds from illicit activities, criminals have historically had a number of financial instruments and methodologies at their disposal. These choices have ranged from payment products tied to demand deposit accounts such as checks, wires, and debit/ATM card transactions to money transfers via money transmitters. The birth of general purpose reloadable (GPR) prepaid cards in the early 1990s created yet another payment instrument that could potentially be used to clean dirty money.

Although no payment instrument—GPR prepaid cards included—is completely immune to money laundering, the payments industry can adopt risk measures to mitigate the attractiveness of these cards to criminals. But what makes a payment choice attractive to money launderers? Criminals generally seek the fastest method to move their ill-gotten proceeds the furthest away from their illegal activities. Ultimately, they want to distance themselves and their financial gain from the crime in the quickest way possible. Anonymity, accessibility, immediate liquidity, and transportability of funds are all payment characteristics that a money launderer finds attractive.

The Retail Payments Risk Forum dove into the regulatory environment and risk management practice of the GPR prepaid card industry, and wrote up findings in a paper available on the Atlanta Fed's website. Among the paper's findings is that, as GPR prepaid cards have grown in popularity and come under increased scrutiny by regulators, significant regulatory measures and industry-wide adopted practices have greatly reduced, but not eliminated, their money laundering risks. And while U.S. regulators and the card industry have made great strides with anti-money laundering measures, GPR prepaid cards issued internationally do not necessarily face the same stringent risk environment, so they pose significant money laundering risks.


For more details on the money laundering risk environment for GPR prepaid cards, read the paper.

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

January 28, 2013 in fraud, money laundering, prepaid | Permalink


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Interesting paper. The DoJ paper and rebuttal go into greater depth on the actual risks of GPR's in money laundering.

GPR's are not really like any other financial tool. Most are tied to a bank DDA with explicit account opening procedures.

What would be interesting is an analysis of recent GPR innovations which allow individuals "deposit-only" capability. Basically these are simple pieces of plastic that allow ground level drug dealers to deposit cash sales into a master account any where in the country.

Of course, it could be a parent funding a child.

Posted by: CMS | January 28, 2013 at 09:31 AM

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November 13, 2012

The Rule of 3, or Desperately Seeking Payment Products

Generally speaking, I have always believed in the "Rule of 3." When you're looking for something new—with your home, for example, or with your clothing style—try out three, and the obvious will likely emerge as a winner. When I had my design business and helped people pick products out for their homes, I never presented them with more than three options for any one product. If I did, sure enough they would get frustrated and become unlikely to make a confident decision.

When I changed career paths here at the Fed and entered the world of retail payments, I decided to look into some new payment products and services for my children. I am the mother of teenagers who are always asking for money, so my first goal was to provide them with a safe, easy, and secure way to have and spend money.

I began to research some products, and narrowed my choices down to three options to explore: gift cards, prepaid debit cards, and bank-issued debit cards. Immediately, I eliminated gift cards, which once depleted are usually not reloadable. I wanted this to be a lifestyle change, something that could be extended; therefore, I focused my research on option number 2, reloadable cards. I started at a local grocery store, where I stood looking in awe at the tower of choices I had before me. Most cards here cost $4.95 before you load money on them. A store clerk told me that a big-box retailer had the same products for $3, so off I went.

prepaid card display The first purchase was for my son. At the checkout, I asked the clerk to load $40 on the card. The clerk informed me that I could not use my credit card to fund a prepaid card—I needed cash, or a preprinted payroll or government check, or direct deposit from my paycheck, or a standard transfer from my bank that could take up to 13 days—and then I would be charged a fee.

This did not seem very user-friendly, especially since I do not carry an ATM card, nor do I frequent this big-box retailer often. But I was determined to try this new payment method, so I returned the next day and paid $3 to buy a $40 card. (I now know that this $3 fee is waived if you get your card online and that there is a reload fee of $3 and a monthly maintenance fee of $3.) This still seemed like a better option than a bank debit card. I registered the card online for my son (required for activation) and entered personal information like name, address, and social security number. I was not thrilled with that level of privacy loss—however, as the small print explained, "Federal law requires us to obtain, verify, and record information that identifies you when you open up this account." In addition, this is the only way I could get a refund if the card were lost or stolen, and that was one of my three preliminary requirements.

So I started looking for the actual custom card in the mail with my son's name on it. I waited two weeks—and no card. I reviewed the fine print included inside the package to discover that you must be over the age of 16 to buy and use this kind of card. This information was printed nowhere on the outside of the packaging. My son is 15, not even 16 yet. So, there will not be a custom card coming in the mail, and this temporary card I have will become useless once the balance falls to zero. Have I mentioned that there is a $3 monthly maintenance fee that applies after the tenth day you have the card? So far, I have paid $6 to lend him $40 on a card that is not reloadable.

This led me to option number 3, my bank, where I learned about student accounts that don't charge for bank-issued debit cards. And, for convenience, I can transfer funds from my checking account into the student account, which funds the debit card. Honestly, this was not my first choice, but it emerged as the safest, cheapest, and most convenient. I decided to use this opportunity to teach my kids about online banking, overdraft fees (because I am not linking the student account to my account), the importance of passwords, and balancing their (virtual) checkbooks.

This account has proven to be a wonderful tool, and my kids now look forward to logging in and checking their balances and confirming that their "payday" has been deposited upon completion of their agreed-upon chores. I can't wait to discover more opportunities of my new job here in the Forum!

Michelle CastellBy Michelle Castell, senior payments risk analyst in the Retail Payments Risk Forum at the Atlanta Fed

November 13, 2012 in cards, prepaid | Permalink


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I am surprised that you did not come across the prepaid "teen" card offerings such as Visa Buxx, which is a prepaid card specifically designed for parents with teenagers who would like to provide their child with a bank account type of relationship. The beauty of the teen card is that there are 2 account holders and one card holder. The parent has total visibility on the account and can load funds (without a fee from a checking account) from any source, even limit where the card is used and look at the account activity. The teen, can use the card anytime any place and also monitor statements on line. This product has become very popular with high school and college students and it has all the safety and security of a DDA account without having to keep a minimum balance or having the risk of over drafting the account. It is definitely worth looking into.

Posted by: Madeline K. Aufseeser | November 14, 2012 at 09:40 AM

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October 29, 2012

Crossing the Border: More Reason to Check Your Pockets

It's no secret that cross-border travel has involved a lot more restrictions since 9-11. Declaration of assets and physical inspection of luggage and other items are expected, as well as tedious and unpleasant, aspects of a vacation or business trip. That could change soon and not for the better, under a new rule proposed October 2011 by the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The new rule would require travelers to add the balances of prepaid cards to declaration reports.

While issuing such a rule sounds reasonable in theory, enforcement is likely to be another matter. Unlike checking the content of physical items, digital value stored in or accessed by a plastic card or a mobile phone is difficult to measure. How can you tell how much money is loaded on the prepaid card to validate the declared value? In fact, how will enforcement officials even distinguish prepaid cards from credit and debit?

FinCEN's proposed rulemaking expected to be final soon
FinCEN's Notice of Proposed Rule Making (NPRM), expanding the scope of its cross-border reporting requirements to include "tangible prepaid access devices," is poised to assume its final form, some expect as soon as the end of the year. Currently, travelers have to report aggregated cash and other monetary instruments exceeding $10,000. The premise behind this requirement is that it prevents money laundering and criminal-terrorist financing by enabling the traceability of currency and its equivalents, and hopefully eliminating anonymous flows of money into and out of the United States.

Previously, FinCEN issued a rule recognizing the advanced innovations in prepaid payment methods and the subsequent need to expand the definition to include all form factors backed by prepaid value, in addition to cards. That rule also changed the payment method definition from "stored value"—implying value stored digitally within the form factor—to "prepaid access," a term that more accurately describes the process for electronic retrieval of prepaid funds maintained by the payment provider.

Handheld readers at borders and airports?
According to comments published in response to the NPRM, the Department of Homeland Security is working on a "handheld reader with features that will, among other things, allow law enforcement to quickly and accurately differentiate between a traveler's debit, credit, and prepaid products…in a manner which imposes minimal to no inconvenience to individuals and complies with U.S. laws, regulations, and procedures." Furthermore, according to the comments, the enforcement challenge is not new, nor is the concept of a device or document that can be used to access value. The current challenges are similar to those presented in the past with other monetary instruments such as checks, money orders, and traveler checks.

Still keeping an eye on bulk cash
A recent study conducted by U.S. and Mexican officials reported that stored-value and prepaid cards are "potentially powerful means for both transporting and laundering money," but still found that the majority of illicit funds movement across the U.S. and Mexican border takes place in the form of bulk cash. In fact, most of the criminal movement of funds does not involve laundering, which is typically accomplished by first depositing illicit funds into a bank or business before moving it. This is particularly important in addressing criminal terrorist financing that may only involve transport. It will be important for regulators to strike a balance between proactive enforcement in addressing crime in electronic channels and effective management of more basic schemes involving the transport of cash across borders.

Many questions still remain
Many commenters to the NPRM have expressed opposition to the premise that prepaid access devices should be classified as monetary instruments since they merely access funds held at a bank or financial institution. When law enforcement takes possession of a cash or monetary instrument at the border, they are effectively holding the funds, but not so with a prepaid card or other device. Holding the card does not provide access to the underlying funds. Furthermore, the legislation is easy to evade. According to a comment from the Network Branded Prepaid Card Association, "a card can truthfully be reported as having just $1,000 on it; and then two hours later, the card can be loaded with funds from another location and have $15,000 on it."

Commenters also suggested alternatives that would focus the final-rule decision making on more effective measures, such as carrying a large number of cards, particularly if the cards are not embossed with the cardholder's name. For example, a person carrying more than 20 nonpersonalized cards would have to declare the aggregated value and be prepared to address questions by border patrol agents. Such a measure could avoid the need for high-cost readers and the potential privacy issues that may ensue if the final rule is issued as proposed.

Cynthia MerrittBy Cynthia Merritt, assistant director of the Retail Payments Risk Forum

October 29, 2012 in prepaid | Permalink


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August 13, 2012

Tourism Traffic Boosts Prepaid Cards

Prepaid cards, at least until 2010, were the fastest growing payment method in the United States, according to the Fed's latest payments study. Their use is also growing in other markets, including Latin America in general and Brazil in particular, especially for funding tourism activities. Brazilian tourists are increasingly choosing rechargeable prepaid travel cards loaded with U.S. currency over cash. Interestingly, U.S. banks are also realizing economic benefits from tourists' move from cash to prepaid cards.

Growing South Florida tourism drives Brazilians to spend more
Brazilians make up the second largest tourist group to Florida, next to Canadians (3.3 million of whom visited the United States in 2011). Last year, approximately 1.5 million Brazilians visited Florida. They spent more than a billion dollars total, with a per-visit amount typically exceeding $5,000. Altogether, the Fed Atlanta's Miami Branch paid out $1.7 billion U.S. dollars to Brazil.

A number of factors are contributing to the rise in Brazilian tourists to Florida, including the high number of available flights, expedited processing for travel visas, significantly lower prices for many designer brands coupled with the absence of Brazilian import tax, and relatively cheaper real estate prices.

Brazilian tax rule, other factors influence credit card spending abroad But why are these tourists increasing choosing to use prepaid cards? In 2011, the Brazilian government imposed a new financial operations tax of 6.38 percent on foreign transactions made with Brazilian-issued credit cards. The tax, called the IOF—short for Imposto sobre Operações Financeiras—makes using credit cards abroad very unattractive for Brazilians.

Prepaid travel cards also offer more favorable exchange rates, and they insulate consumers against rate fluctuations by offering a fixed exchange rate on all purchases.

Banks in Brazil also benefit from prepaid cards used abroad. Transportation and custody expenses make it costly for Brazil's commercial banks to obtain and hold U.S. dollars. As a result, these banks are actively promoting prepaid cards. U.S. commercial banks quickly seized the opportunity to compete with their Brazilian counterparts by rolling out marketing campaigns in Brazil promoting the benefits of prepaid travel cards for U.S. travel.

All these conditions and incentives have combined to create a 50 percent rise in travel card applications by Brazilians shortly after the tax regulation was introduced.

Brazil offers an interesting case study of the growth in the use of prepaid payment cards. Just as U.S. consumers beyond the unbanked are recognizing the ease and convenience of this payment device, so are international consumers.

Paul GrahamBy Paul Graham, assistant vice president and branch operations officer, Miami Branch of the Federal Reserve Bank of Atlanta

August 13, 2012 in banks and banking, cards, payments, prepaid | Permalink


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June 4, 2012

The new consumer protection agency looks at prepaid cards

The prepaid card industry has grown faster than many expected it to in recent years. The industry has a wide range of customers today, including not only the underbanked market but also many other market segments. In fact, in a public hearing on May 23, 2012, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray noted that while many consumers "actually have a bank account, they often use nonbank products to meet their financial needs," including the relatively new prepaid card. As this product has grown in acceptance, consumer advocacy groups have voiced concerns about the potential lack of consumer protections and the need for regulatory clarity for prepaid product providers. In response to these concerns, the CFPB announced its plan to launch a rulemaking initiative to promote safety and transparency in the prepaid market.

Why legal protections differ
While payment law critics cite the fragmented legal landscape for retail payment methods, the differences lie in the underlying mechanics. In the simplest of terms, retail payments can be segmented into three basic genres: "paying now" through a deduction in your account balance at a financial institution through either a check or debit card; "paying later" by using a credit card, which involves a loan from the payment service provider to cover the cost of the purchase in the transaction; and "paying before," by prefunding an account by the consumer for use at a later time.

These inherent funding differences lend themselves to different laws, regulations, and rule sets, since the timing and liability for maintaining the safety of the funds in each case differs. Consumer lending protection laws, for example, have relevance only for credit payment products. The emergence of new prepaid products and nonbanks participating in new business models, along with the sometimes questionable pricing schemes and fees, points to the need for industry dialogue on what new regulatory governance is needed in prepaid services today.

Growth in prepaid
The Federal Reserve’s last triennial payment study revealed that prepaid cards, particularly the general-purpose reloadable (GPR) variety, were the fastest growing retail payment in recent years, even though they represent a relatively small piece of the overall pie of preferred retail payment types. GPR cards allow the consumer—or another party, like an employer—to add funds to the card. This reloadable feature makes the product functional and convenient, and allows consumers who traditionally relied on cash to participate in the electronic economy.

Recent growth in prepaid cards

Increased e-commerce is in turn leading to the use of prepaid in the mobile environment. Payment providers have been experimenting in recent years with bridge technologies such as prepaid card stickers using contactless technology. The sticker is put on the mobile handset, and is intended to influence consumer payment behavior by offering consumers the opportunity to tap their mobile phones at the merchant’s point of sale. As a result, the advanced notice of rulemaking notes that a prepaid "card" may also take the form of other access devices, such as key fobs, or even a cell phone application that accesses a prepaid financial account.

What the CFPB is offering consumers
When it comes to prepaid cards, the public hearing made it clear that the CFPB wants to make sure, first and foremost, that consumers’ funds are safe, especially because not all prepaid accounts are structured so that they are protected by deposit insurance. The agency also wants to make sure that consumers have access to clearly written disclosures on card terms and fees before they even open a prepaid account. In the hearing, the CFPB also discussed a proposal to extend Regulation E protections to include GPR cards specifically. Furthermore, the CFPB also launched "Ask CFPB: Prepaid Cards" on its website to provide consumers with information about prepaid cards in a question-and-answer format.

Cindy MerrittBy Cynthia Merritt, assistant director of the Retail Payments Risk Forum

June 4, 2012 in consumer protection, payments, prepaid | Permalink


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September 26, 2011

I can’t use my prepaid card for that now?

The focus of the Portals and Rails blog is usually related to fraud or operational risks to the payments system. Today's blog will take a look into a different type of risk, the risk of reduced functionality for general purpose reloadable (GPR) prepaid cards. An interesting development with GPR prepaid cards has risen out of the recent Regulation II (Reg II) ruling. Considering that 1.3 billion general purpose prepaid card transactions were conducted in 2009, according to the 2010 Federal Reserve Payments Study, changes affecting GPR prepaid cards could affect many people.

Reg II, which was instituted in response to the statute commonly referred to as the Durbin Amendment, has an unintended consequence. Consumers risk losing some payment functionality with prepaid cards, including the ability to have funds auto-drafted via ACH from GPR prepaid cards. The risks of unintended consequences such as this one has not gone unnoticed by the Federal Reserve Board. In fact, during the June 29 Open Board Meeting, Governor Duke expressed her concern on this topic and would eventually like the Board to "undertake a study to quantify the overall effect of this rule on consumers."

With the Reg II interchange cap set to go into effect on October 1, many institutions are implementing new checking account fees and debit card fees that will undoubtedly make checking accounts and debit cards costlier for consumers. However, outside of eliminating or reducing rewards, institutions will offer consumers the same benefits and functionality for debit cards as they did before Reg II. It does not appear that the same can be said for the functionality and convenience of GPR prepaid cards.

To be exempt from the interchange cap, a GPR prepaid card must be the only means for a consumer to access the funds on that card or the card issuer must qualify for the small-issuer exemption (assets of less than $10 billion). If the consumer can access funds on a GPR prepaid card issued by a large issuer (assets of $10B or more) with a check, ACH, wire, or other account transfer method, then the card is viewed as a "deposit account" and therefore not exempt from the Reg II interchange cap. It was critical that the regulation include this language concerning GPR prepaid cards to prevent the widespread evasion of the interchange cap by issuers labeling traditional debit cards and their underlying deposit accounts as prepaid cards.

Conceivably, a GPR prepaid card issuer could be exempt from the Reg II interchange cap by eliminating payment functionality beyond the purchasing function of the prepaid card. Under this scenario, consumers would no longer be able to use their GPR prepaid cards to auto-draft funds via ACH from the card to pay recurring bills, such as utility bills.

According to recent comments by the CEO of Green Dot, the largest GPR prepaid card program manager, "all Green Dot managed programs, including our Walmart MoneyCard program, will be exempt from interchange restrictions under the Durbin interchange amendment and therefore, our programs will not be subject to lower interchange." A recent article in the American Banker noted that Green Dot would need to either remove features of its cards or switch bank issuers (neither of Green Dot's current issuers can qualify as small) for its cards to be exempt from the interchange cap.

Implications for GPR prepaid card users
With Green Dot cards set to be exempt from the Reg II interchange cap, many GPR prepaid card users should prepare for the loss of the direct debit functionality of their cards. And with the loss of this payment option, prepaid card users that currently use their cards' direct debit functionality to pay bills will now be more at risk of making late payments and having to pay the accompanying late fees. Furthermore, because many recurring billers, including utility companies, often charge a fee for card-based payments, GPR prepaid card users can expect to pay a service fee for paying some of these bills. To avoid these service fees for card-based payments, GPR prepaid card users may be forced to make cash payments in person, which can be both inconvenient for the consumer and costly for the biller.

A final thought
Perhaps the most surprising information from the Green Dot announcement is the fact that the WalMart Money Card will also be exempt from the interchange cap. With merchants being some of the biggest proponents of the Reg II interchange cap, it's interesting to learn that a merchant cobranded prepaid card will be stripped of a feature that provides consumers with a free, safe, and convenient way to pay bills all in the name of earning the higher interchange and presumably maintaining low costs for consumers. Given the utility of GPR prepaid cards for the un- and underbanked population, will removing electronic payment functionality from the cards further disenfranchise these consumers from banks? Or would increasing consumers' cost for the product to maintain its current functionality lead this segment away from electronic payments and back to cash?

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

September 26, 2011 in payments, prepaid, regulators | Permalink


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Although article focuses on loss of direct ACH debit from prepaid cards, these same programs are also eliminating their web billpay offerings -- this is probably an even bigger customer impact as web billpay usage exceeds that of direct debit.

Posted by: dave fortney | October 3, 2011 at 10:25 AM

How absurd that a piece of legislation intended to curb debit interchange earnings for banks is singling out transactions that do not generate any interchange (ACH, checks).
Under-banked people encouraged by the government to receive their tax refunds into prepaid cards will be delighted to learn that they can no longer pay their bills conveniently with the money received...
There are plenty of non-evil large banks that will think twice before offering prepaid cards as an entry product, if the cards loose a large part of their usefulness.

Posted by: Patrice Peyret | September 27, 2011 at 09:02 PM

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