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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

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November 24, 2014


What’s Unsettled in Faster Payments?

When I started at the Federal Reserve Bank 27 years ago, the phrase "faster payments" was rarely spoken. Indeed, if people talking of payments were musing on speed (or the lack thereof), two things were a safe bet: first, the conversation was likely among bankers and, second, the talk revolved around check float and the tools for reducing it—check sort patterns, airplanes, or optimized ground routes. Those tools are not part of today's "faster payments" conversations, and the universe of discussants is much broader; it's not just bankers anymore.

Payments essentially comprise two components. The first is messaging—the instruction that delineates who is to be paid, by whom, and in what amount. The second component is settlement. Settlement is the event that finishes a payment. It is also commonly the slowest aspect within any given payment scheme. Settlement is the actual transfer of funds, the account adjustments directed by the messaging components.

For many payments, settlement takes much longer than appears to be the case, particularly from the perspective of the end user. For example, in a typical payment card transaction between a consumer and a retailer, once the card is swiped and "approved," the consumer is considered to have paid and can generally leave with the goods. But the merchant has received only the promise of payment. Settlement between card issuers and acquiring banks must occur before the merchant is paid. This can take more than a day and illustrates one issue with settlement lags: consequential strains on liquidity that merchants experience when they need to replace goods but may not have received payment to fund the resupply.

So will a faster payment solution resolve the liquidity issues currently experienced in many of the extant payment schemes? At this point, the answer is not a simple one. In town hall-style meetings and other updates, Fed speakers have noted that "real-time settlement is not required for real-time availability." This suggests that at least at the outset, a faster payments scheme here may not include immediate settlement. And if settlement does not occur simultaneously with messaging, certain parties in the transaction remain exposed to liquidity as well as other settlement risks. This doesn't mean that a new scheme will be plagued with settlement risk. The UK has successfully offered real-time clearing and availability without real-time settlement. However, other countries have built real-time settlement into their new systems because it does indeed reduce systemic risk. If a new system here is to be built from scratch, it seems important to probe fully the range of design issues and options and consider solving all of the longstanding payment risks that can be feasibly solved.

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


November 24, 2014 | Permalink

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From my vantage point of having being involved with the implementation of Faster Payments for a Top 5 UK Bank, I believe the non-availability problem is overstated: (1) Retailers typically enjoy 30-60-90 days credit from their suppliers, so having to wait for a few hours / couple of days for their sales proceeds via a non realtime settlement system like FPS shouldn't really affect their ability to fund resupplies (2) In fact, immediate realization of sale proceeds may ironically cause problems for some of them! A couple of days after FPS went live in May 2008, I remember a leading MNO calling us up and telling us NOT to credit their customer payments immediately. When we inquired why, they told us that their payable systems swept their collection accounts only for bills due 2 days before. So, after FPS, they started missing payments that were credited on the due date. This apparently led them to suspending service to their prompt paying customers and all kinds of customer dissatisfaction!

PS: Hi @TomH: Nice to bump into you on Portals & Rails!

Posted by: Ketharaman Swaminathan (GTM360 Marketing Solutions) | November 27, 2014 at 08:15 AM

As someone who was heavily involved with the design of settlement for UK Faster Payments I can confirm that several options were considered before choosing the Deferred Net Settlement model, with exposure limits enforced per bank. Real-time settlement imposes a huge load on RTGS systems which were designed to handle low volumes of high value transactions, not high volumes of low value. It also adds significant complexity to ensuring integrity across the sending and receiving bank systems, the message switch and the RTGS system, as well as adding a delay to message processing and introducing a potential single point of failure.

Banking is about determining acceptable risk levels, not completely eliminating risks. RIsk experts must work closely with their technical colleagues to create a system design that balances settlement risk management with system performance, integrity and cost.

Posted by: Tom Hay | November 26, 2014 at 02:55 AM

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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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November 10, 2014


Virtual Currency Environment Still Fluid after Latest Rulings

The end of October was filled with multiple news-grabbing headlines reflecting the growing fears of Ebola, the exciting seven-game World Series, and the release of the first-ever college football playoff rankings. The launch of ApplePay also saw its fair share of headlines, but one piece of payments-related news might have flown a bit under the radar. On October 27, the United States Department of Treasury's Financial Crime Enforcement Network (FinCEN) issued two virtual currency administrative rulings stemming from its March 2013 guidance on regulations to persons administering, exchanging, or using virtual currencies.

The first administrative ruling involves a virtual currency trading platform that matches its customers' buy-and-sell orders for currencies. The company requesting this ruling stated that they operated the trading platform only and were not involved with money transmissions between it and any counterparty. FinCEN determined that money transmission does, in fact, occur between the platform operator and both the buyer and seller. Consequently, FinCEN said that this company and other virtual currency trading platform operators should be considered "exchangers" or "operators" and required to register as money transmitters subject to Bank Secrecy Act (BSA) requirements.

The second administrative ruling involves a company that enables virtual currency payments to merchants. This company receives payment in fiat currency from the buyer (or consumer) but transfers an equivalent amount of virtual currency to the seller (or merchant) using its own inventory of virtual currency to pay the merchant. This particular company asserted that it wasn"t an "exchanger" since it wasn't converting fiat currency to virtual currency because it was using its own reserve of virtual currency to pay merchants. However, FinCEN determined that this company, and similar companies, is a money transmitter because it accepts fiat currency from one party and transmits virtual currency to another party.

These two rulings confirm that if a virtual currency-related company's services allow for the movement of funds between two parties, that company will be viewed as a money transmitter and will be subject to BSA requirements as a registered money transmitter. As financial institutions consider business relationships with these types of companies, they should make sure that these companies are registered as money transmitters and have BSA programs in place.

The virtual currency regulatory environment continues to be fluid. For example, in his recent comments at the Money 2020 Conference, Benjamin Lawsky, superintendent of the New York Department of Financial Services, suggested that his office will soon be releasing its second draft of a proposed framework for virtual currency business operating in New York. Portals and Rails will continue to monitor this regulatory environment at the state and federal level.

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

November 10, 2014 in currency, mobile banking, mobile payments, transmitters | Permalink

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