Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.
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April 22, 2019
The Prepaid Rule: All Jokes Aside
A payments compliance rule took effect this year on April Fools' Day, and it occurred to me that when a compliance deadline is approaching, you might not feel like joking around. The Prepaid Accounts Final Rule was issued a few years ago, in 2016, but after a number of postponements, its effective date is finally behind us.
The rule standardizes disclosures, error resolution procedures, consumer liability limits, and access to records. These changes are intended to provide comprehensive consumer protections for prepaid accounts under the Electronic Fund Transfer Act, or Regulation E. The rule is fairly comprehensive, but for the sake of brevity, I'm going to look at only a couple areas of the rule—those that stand out to me.
Consumers can now expect protections over their transaction accounts regardless of whether the account is offered directly by a traditional financial institution or by a third party, such as a fintech or merchant, as they make electronic payments (debit, prepaid, ACH). Also, fintech companies that allow consumers to store funds or are thinking about adding that ability may want to prepare themselves to be designated as prepaid services providers and therefore subject to the regulatory and licensing requirements that go along with that designation. To that point, I am not surprised to see several big names recently listed on the FinCen Money Service Business Registration as "Providers of prepaid access." (To see the list, scroll down the web page to the MSB registration form; on the MSB ACTIVITIES field, click the down arrow to open the dropdown list; select Provider of prepaid access and click the Submit button.)
Established prepaid issuers have long been preparing for the new prepaid rule despite the stops and starts of an effective date and the uncertainty about some of its key provisions. Because consumers open prepaid accounts in a variety of ways—from starting a new job to purchasing prepaid cards at a retail checkout lane—it can be difficult to accommodate the disclosure requirements, such as those for listing fees, that the prepaid rule prescribes. Most issuers have changed product packaging to accommodate the new disclosures. These changes required complicated logistics coordination for the prepaid supply chain to replace old, noncompliant inventory with new, compliant card packages. Some issuers are still grappling with how to list types of fees that may not apply to their particular account program.
Many issuers had already been providing some level of consumer protection from unauthorized transactions before the rule requirement took effect. Now there will be a standard expectation. Limited liability and error resolution benefits need apply only to customers who have successfully completed the identification and verification process, if there is one for their particular program. Regulation E's error resolution and limited liability requirements do not extend to prepaid accounts (other than payroll or government benefit accounts) that have not completed the verification process, one of the key revisions after the rule's initial issue.
The rule will change the way we categorize prepaid services. For instance, in the past, discussion around prepaid products focused on whether the product was open- or closed-loop, and whether it was reloadable or nonreloadable. While those characteristics still exist, they are not necessarily a determinant as to whether the rule applies to a particular product or not. There are clear exclusions for certain products like those that are marketed and labeled as gift cards, health care savings cards, or disaster relief cards. However, even if a product doesn't have "prepaid" on its label, it may still fall under Regulation E. Coverage extends to asset accounts that consumers can use to conduct transactions with multiple, unaffiliated merchants for goods or services, to pull cash from automated teller machines, or to make person-to-person transfers.
For both incumbents and those finding themselves new in prepaid, it has been no joke to prepare to comply with the new rule. Despite the extra burden, do you think we will look back on this milestone favorably in the future? I think the new prepaid rule will lead to strengthening trust and confidence in these products. The Consumer Financial Protection Bureau (CFPB) pledges to be vigilant in evaluating new rules. Moreover, the CFPB is required to submit a formal evaluation five years following a rule's effective date. The industry should be ready to help measure the rule's impact.
By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
July 12, 2018
Behind the Growth in Debit Card Payments
U.S. consumers make more payments with nonprepaid debit cards than with other types of cards (credit and prepaid) combined. The 2016 Federal Reserve Payments Study found that consumers made 57.5 billion payments in 2015 using nonprepaid debit cards.
That's a 26 percent increase over 2012, when consumers made 45.7 billion nonprepaid debit card payments.
No doubt, effects of more favorable economic conditions—including declining unemployment, increasing wages, and greater consumer confidence—were important factors in increased consumer spending from 2012 to 2015. But from a payment choice perspective, such as which method or card to use, what might be driving this increase of almost 12 billion? Two factors related to those choices could be at play:
- Maybe people started using the cards more intensively. That is, people who owned nonprepaid debit cards started using them more often, making more payments per card per month.
- Maybe people started using the cards more extensively. That is, more people owned and actively used a nonprepaid debit card or more people owned and actively used multiple cards.
For this discussion, an "active" card is defined to be one that is not expired and had purchase activity or bill pay associated with the card during at least one month of the year 2015 or, for the 2012 estimate, at least one transaction during the month of March 2013. Note that the difference between the 2012 and 2015 estimates could, in part, be related to the different definitions of the measurement periods. (The Federal Reserve Payments Study also measures nonprepaid debit, credit, and prepaid cards that are in circulation but not used.)
Let's look at the numbers:
- In 2012, there were 173.9 million active consumer nonprepaid debit cards in circulation. These cards are linked to a transaction account at a financial institution and can be used to make purchases at the point of sale.
- In 2015, there were 209.6 million active consumer nonprepaid debit cards. That's an increase of 21 percent over the three years.
- In 2012, U.S. consumers made 21.9 purchases per month per active nonprepaid debit card. In 2015, on average, across the months, they made 22.8 per card. That's almost flat—an increase of just four percent in the number of payments per card per month over three years.
These numbers overall tell us that increases in payments per card is not the main driver of this phenomenal increase in the number of nonprepaid debit card payments (see the chart). Note that payments per card is an average of various behaviors. Some people could be using their cards more—for example, new debit card owners may be moving from using cash or prepaid cards. Others could be using their cards less—for example, new owners of credit cards may be moving away from debit cards.
Rather, the increased number of active cards seems to be the source of the jump in the number of nonprepaid debit card payments. Here are some factors that could relate to the greater numbers of cards:
- The U.S. population ages 18 and older grew from 240 million to 247 million during this time, a three percent increase (American FactFinder search).
- The percentage share of consumers with a bank account (and thus able to own a nonprepaid debit card) increased from 91.8 percent in 2011 to 93 percent in 2015 (FDIC Survey of Banked and Unbanked Consumers [2012 estimate not available]).
- By birth year, the share of people more likely to own a debit card increased. Young people born between 1995 and 1997 turned 18 between 2012 and 2015—about 14 million of them (American FactFinder search). At the same time, the population of people born before 1940 declined by about 4 million between 2012 and 2015.
Whatever the source of the increase in the number of cards, we see here that typical behavior for an active nonprepaid debt card is around 23 purchases per month. How many times per month do you use your card or cards?
By Claire Greene, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
May 7, 2018
Evidence of the Digital Age
Are you one of the estimated 90 percent of Americans who have shopped online over the past year? According to the most recent data published by the Federal Reserve Payment Study, remote payments grew faster than in-person payments by both volume and value. For example, from 2015 to 2016, remote general-purpose credit card payments grew at the rate of 16.6 percent, compared to 7.9 percent for in-person credit card payments. (See the chart.) Remote spending drove almost all of the growth of the general-purpose prepaid card during 2015–16, according to the study. If we had any doubts before, this growth shows us clearly that we're in the digital age, a time in history when digital technology has become ubiquitous.
The shift from in-person payment to remote payment is certainly telling a story that will affect our future conversations and research. We need to take into consideration that as remote payments grow, they will become less and less connected to a physical card. Eventually, consumers may stop considering them to be card payments at all. They will likely start thinking first of their ability to make a payment with a digital account, with subsequent transactions eligible to ride a number of different payment rails, like ledger transfers, ACH, or other faster payments models.
The U.S. Census Bureau estimated that total ecommerce sales for 2017 were about $453.5 billion, an increase of 16 percent from the year before and accounting for 8.9 percent of total sales in 2017. Last year the Department of Commerce reported ecommerce sales have been growing nine times faster than traditional in-store sales since 1998. And remote payments will continue to accelerate. Consider the top retail trends of the year, according to research from the National Retail Federation:
- Online purchase, store pickup: Stores are adding lockers for easier pickup.
- Talking tech: Virtual assistants are rapidly growing in popularity and are ready and able to help customers make purchases.
- Showrooms without inventory: Stores offer browsing, testing, and fitting, with the customer subsequently making the purchase online. This approach helps showrooms reduce their overhead and give consumers customized options.
- Membership clubs: Stores collect customers' money upfront (sort of like prepaid) and send merchandise later, depending on what analytics have taught them about their customers and consultative sales touchpoints.
Future Federal Reserve Payment Studies will continue to track shifts in payments. However, we may need to adapt the ways we discuss these types of payments as the digital-first age leads to innovative transaction accounts with subsequent remote payments untethered from plastic cards.
By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
January 9, 2017
The Year in Review
As we move into 2017, the Take on Payments team would like to share its perspectives of major payment-related events and issues that took place in the United States in 2016, in no particular order of importance.
Cybersecurity Moves to Forefront—While cyber protection is certainly not new, the increased frequency and sophistication of cyber threats in 2016 accelerated the need for financial services enterprises, businesses, and governmental agencies to step up their external and internal defenses with more staff and better protection and detection tools. The federal government released a Cybersecurity National Action Plan and established the Federal Chief Information Security Office position to oversee governmental agencies' management of cybersecurity and protection of critical infrastructure.
Same-Day ACH—Last September, NACHA's three-phase rules change took effect, mandating initially a credit-only same-day ACH service. It is uncertain this early whether NACHA will meet its expectations of same-day ACH garnering 1 percent of total ACH payment volume by October 2017. Anecdotally, we are hearing that some payments processors have been slow in supporting the service. Further clarity on the significance of same-day service will become evident with the addition of debit items in phase two, which takes effect this September.
Faster Payments—Maybe we're the only ones who see it this way, but in this country, "faster payments" looks like the Wild West—at least if you remember to say, "Howdy, pardner!" Word counts won't let us name or fully describe all of the various wagon trains racing for a faster payments land grab, but it seemed to start in October 2015 when The Clearing House announced it was teaming with FIS to deliver a real-time payment system for the United States. By March 2016, Jack Henry and Associates Inc. had joined the effort. Meanwhile, Early Warning completed its acquisition of clearXchange and announced a real-time offering in February. By August, this solution had been added to Fiserv's offerings. With Mastercard and Visa hovering around their own solutions and also attaching to any number of others, it seems like everybody is trying to make sure they don't get left behind.
Prepaid Card Account Rules—When it comes to compliance, "prepaid card" is now a misnomer based on the release of the Consumer Financial Protection Bureau's 2016 final ruling. The rule is access-device-agnostic, so the same requirements are applied to stored funds on a card, fob, or mobile phone app, to name a few. Prepaid accounts that are transactional and ready to use at a variety of merchants or ATMS, or for person-to-person, are now covered by Reg. E-Lite, and possibly Reg. Z, when overdraft or credit features apply. In industry speak, the rule applies to payroll cards, government benefit cards, PayPal-like accounts, and general-purpose reloadable cards—but not to gift cards, health or flexible savings accounts, corporate reimbursement cards, or disaster-relief-type accounts, for example.
Mobile Payments Move at Evolutionary, Not Revolutionary, Pace—While the Apple, Google, and Samsung Pay wallets continued to move forward with increasing financial institution and merchant participation, consumer usage remained anemic. With the retailer consortium wallet venture MCX going into hibernation, a number of major retailers announced or introduced closed-loop mobile wallet programs hoping to emulate the success of retailers such as Starbucks and Dunkin' Brands. The magic formula of payments, loyalty, and couponing interwoven into a single application remains elusive.
EMV Migration—The migration to chip cards and terminals in the United States continued with chip cards now representing approximately 70 percent of credit/debit cards in the United States. Merchant adoption of chip-enabled terminals stands just below 40 percent of the market. The ATM liability shift for Mastercard payment cards took effect October 21, with only an estimated 30 percent of non-FI-owned ATMs being EMV operational. Recognizing some of the unique challenges to the gasoline retailers, the brands pushed back the liability shift timetable for automated fuel dispensers three years, to October 2020. Chip card migration has clearly reduced counterfeit card fraud, but card-not-present (CNP) fraud has ballooned. Data for 2015 from the 2016 Federal Reserve Payments Study show card fraud by channel in the United States at 54 percent for in person and 46 percent for remote (or CNP). This is in contrast to comparable fraud data in other countries further along in EMV implementation, where remote fraud accounts for the majority of card fraud.
Distributed Ledger—Although venture capital funding in blockchain and distributed ledger startups significantly decreased in 2016 from 2015, interest remains high. Rather than investing in startups, financial institutions and established technology companies, such as IBM, shifted their funding focus to developing internal solutions and their technology focus from consumer-facing use cases such as Bitcoin to back-end clearing and settlement solutions and the execution of smart contracts.
Same Song, Same Verse—Some things just don't seem to change from year to year. Notifications of data breaches of financial institutions, businesses, and governmental agencies appear to have been as numerous as in previous years. The Fed's Consumer Payment Choices study continued to show that cash remains the most frequent payment method, especially for transactions under 10 dollars.
All of us at the Retail Payments Risk Forum wish all our Take On Payments readers a prosperous 2017.
May 31, 2016
What Is GPR Feeding On? Part 1 of 2
I recently gave a presentation titled "Where We Are Going, We Won't Need Checking Accounts" at the NACHA Payments Conference in Phoenix. This session focused on the increasing use of alternative financial accounts such as general purpose reloadable (GPR) cards in place of traditional bank accounts. After the presentation, I overheard an attendee comment, "I don't even understand why a product like prepaid exists, when the majority of its use is attributed to those seeking anonymity to conduct fraud." While I will cover common prepaid fraud schemes in the next installment, first I think it is important to consider why prepaid products like the GPR card deserves a seat at the payments table.
I'll start with an egalitarian comparison. Consumers have the right to choose a leather or Velcro wallet and then store their cash in that wallet. In today's digital world, shouldn't a consumer also have the right to acquire a GPR card, e-wallet, or other account to store money electronically? If a consumer receives or spends money illegally in any form, then the justice system should enforce the law. Funds stored in a GPR account or a demand deposit account (DDA) is e-money, a representation of cash in your wallet. The GPR card is an access device to the stored money, functioning like the beloved debit card to the DDA.
In June 2015, the Pew Charitable Trusts published Banking On Prepaid, a report of the motivations and views of prepaid card users. The study concludes that the main reasons for prepaid card use for both banked and unbanked users are to avoid overdraft fees, debt, and check cashing fees. In addition, most GPR users are attracted to the budgeting and savings tools provided by these types of accounts. The report also found that most GPR users don't aim to be anonymous: 74 percent of unbanked GPR cardholders registered their cards, and 52 percent of banked cardholders registered. The primary benefit to registering is that the cardholder gets consumer protections like limited liability and, in many cases, insurance from the Federal Deposit Insurance Corporation.
Susan Herbst-Murphy and Greg Weed, in their 2015 paper "Millennials with Money Revisited," collected data that challenges preconceptions of GPR cards as a product for low-income and unbanked customers. These researchers identify a "power user" group of young, banked, middle- to upper-income levels as well as a "hybrid" user group that combines GPR accounts with traditional bank accounts and other alternative financial services. They suggest we look to the power users to understand why and how the product is being used.
Clearly, there is a market with a strong appetite for this financial product.
Stay tuned for the next installment, when we examine the GPR market for bad apples.
By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
January 11, 2016
Prisoner Release Cards: How to Protect the Interests of Recently Released Inmates?
I recently watched a late-night comedian criticize prison reentry programs in the United States. The segment focused on the resources—or lack thereof—that are provided to released inmates. One of these resources, I have recently learned, is increasingly a prepaid card.
Upon imprisonment, inmates are given a trust account to hold money that they receive for prison work and from family and friends. When they are released, they may also receive start-up funds to help with the reentry process. According to the Federal Bureau of Prison's Inmate and Custody Management Policy, "an inmate being released to the community will have suitable clothing, transportation to inmate's release destination, and some funds to use until he or she begins to receive income. Based on the inmate's need and financial resources, a discretionary gratuity up to the amount permitted by statute may be granted." While the policy expands the details of what constitutes suitable clothing and the method of transportation, there is no mention of how to disburse funds to the released individuals.
Enter prison-release prepaid cards. Many state and federal prison systems enter into contracts with prepaid card providers pursuant to a public bidding process to provide prison release funds through a prepaid card as an alternative to cash or checks. This shift in disbursement methods may be attributable to concerns about cash controls in the prison setting and the high check-cashing fees some inmates who lack traditional bank accounts incur, to name a couple of possibilities. Regardless of the disbursement method that the correctional agency chooses, this vulnerable population depends on every last penny.
Some people maintain that account fees are too high on these prepaid cards and that agreements with cardholders contain forced arbitration clauses. Could the correctional agency negotiate better terms on behalf of the released prisoner? Or could the inmate possibly be given options for the trust fund distribution—cash, check, prepaid card, or even a Paypal account?
A late-night comedian may have the ability to isolate one slice of the problem with prison release programs, but our regulations shouldn't piece together a solution to an overarching issue. Likewise, there are challenges with creating blanket regulations for a product category like prepaid cards that contains many different products meeting a wide variety of distinct needs, each with unique characteristics and different users. Isn't the goal is to provide released prisoners the freedom to use money that belongs to them, as for any other citizen?
By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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!
- Allows you to earn interest on your account balance.
- Offers a loyalty program at selected merchants.
- Has no annual or monthly fee.
- Can be used at any domestic ATM.
- Can be used to pay bills.
- Allows person-to-person money transfers.
- Offers customer service 24/7.
- Offers cash-back rewards.
- Is usable for purchases in-person (POS) or online.
- Protects against unauthorized purchases and fraud.
- Allows access to account information via online or mobile application.
- Has budgeting features.
- Connects you to more than one account and allows you to manage multiple accounts under one main account.
- Issues mobile alerts.
- Has optional plastic card; can be all-virtual management.
- Offers mobile check deposit.
- Allows stop payments on previously scheduled transactions.
- Offers the ability to cover some purchase transactions over the account balance.
- Accepts direct deposit via ACH for payroll or other deposits.
- 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.
By Jessica J. Trundley, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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.
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!
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.
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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.
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.
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.
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
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- payments innovation
- payments risk
- payments study
- payments systems
- phone fraud
- remotely created checks
- risk management
- Section 1073
- skills gap
- social networks
- third-party service provider
- trusted service manager
- Unfair and Deceptive Acts and Practices (UDAP)
- wire transfer fraud
- workforce development
- workplace fraud