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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.

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December 3, 2018

Building Blocks for the Sandbox

I just returned from a leave of absence to welcome my third child to this world. As I catch up on payments news, one theme emerging is the large number of state and federal regulatory bodies launching their own fintech sandboxes. Typically, these testing grounds allow businesses to experiment with various "building blocks" while they innovate. Some businesses are even allowed regulatory relief as they work out the kinks. As I've researched, I've found myself daydreaming about how my new little human also needs to work with the right building blocks, or core principles, to ensure he develops properly and "plays nice" in the sandbox.

But—back to work. What guidance do fintechs have available to them to grow and prosper?.

On July 31 of this year, the U.S. Department of the Treasury released a report suggesting regulatory reform to promote financial technology and innovation among both traditional financial institutions and nonbanks. The report in its entirety is worth a review, but I'll highlight some of it here.

The blueprint for a unified regulatory sandbox is still up for discussion, but the Treasury suggests a hierarchical structure, either overseen by a single regulator or by an entirely new regulator. The Treasury suggests that Congress will likely have to assist by passing legislation with the necessary preemptions to grant authority to the newly created agency or a newly named authoritative agency.

The report outlines these core principles of a unified regulatory sandbox:

  • Promote the adoption and growth of innovation and technological transformation in financial services.
  • Provide equal access to companies in various stages of the business lifecycle (e.g., startups and incumbents). [The regulator should define when a business could or should participate.]
  • Delineate clear and public processes and procedures, including a process by which firms enter and exit.
  • Provide targeted relief across multiple regulatory frameworks.
  • Offer the ability to achieve international regulatory cooperation or appropriate deference where applicable.
  • Maintain financial integrity, consumer protections, and investor protections commensurate with the scope of the project, not be based on the organization type (whether it's a bank or nonbank).
  • Increase the timeliness of regulator feedback offered throughout the product or service development lifecycle. [Slow regulator feedback is typically a deterrent for start-up participation.]

Clearly, the overarching intent of these principles is to help align guidance, standards, and regulation to meet the needs of a diverse group of participants. Should entities offering the same financial services be regulated similarly? More importantly, is such a mission readily achievable?

People have long recognized the fragmentation of the U.S. financial regulatory system. The number of agencies at the federal and state levels with a hand in financial services oversight creates inconsistencies and overlaps of powers. Fintech innovations even sometimes invite attention from regulators outside of the financial umbrella, regulators like the Federal Communications Commission or the Federal Trade Commission.

In the domain of financial services are kingdoms of industry. Take the payments kingdom, for example. Payments are interstate, global, and multi-schemed (each scheme with its own rules framework). And let's be honest, in the big picture of financial services innovations and in the minds of fintechs, payments are an afterthought, and they aren't front and center in business plans. Consumers want products or services; payments connect the dots. (In fact, the concept of invisible payments is only growing stronger.)

What is more, a fintech, even though it may have a payments component in its technology, might not identify itself as a fintech. And a business that doesn't see itself as a fintech is not going to get in line for a unified financial services regulator sandbox (though it might want to play in a payments regulator sandbox).

When regulatory restructuring takes place, I hope it will build a dedicated infrastructure to nurture the payments piece of fintech, so that all can play nice in the payments sandbox. (Insert crying baby.)

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

September 10, 2018

The Case of the Disappearing ATM

The longtime distribution goal of a major soft drink company is to have their product "within an arm's reach of desire." This goal might also be applied to ATMs—the United States has one of the highest concentration of ATMs per adult. In a recent post, I highlighted some of the findings from an ATM locational study conducted by a team of economics professors from the University of North Florida. Among their findings, for example, was that of the approximately 470,000 ATMs and cash dispensers in the United States, about 59 percent have been placed and are operated by independent entrepreneurs. Further, these independently owned ATMs "tend to be located in areas with less population, lower population density, lower median and average income (household and disposable), lower labor force participation rate, less college-educated population, higher unemployment rate, and lower home values."

This finding directly relates to the issue of financial inclusion, an issue that is a concern of the Federal Reserve's. A 2016 study by Accenture pointed "to the ATM as one of the most important channels, which can be leveraged for the provision of basic financial services to the underserved." I think most would agree that the majority of the unbanked and underbanked population is likely to reside in the demographic areas described above. One could conclude that the independent ATM operators are fulfilling a demand of people in these areas for access to cash, their primary method of payment.

Unfortunately for these communities, a number of independent operators are having to shut down and remove their ATMs because their banking relationships are being terminated. These closures started in late 2014, but a larger wave of account closures has been occurring over the last several months. In many cases, the operators are given no reason for the sudden termination. Some operators believe their settlement bank views them as a high-risk business related to money laundering, since the primary product of the ATM is cash. Financial institutions may incorrectly group these operators with money service businesses (MSB), even though state regulators do not consider them to be MSBs. Earlier this year, the U.S. House Financial Services Subcommittee on Financial Institutions and Consumer Credit held a hearing over concerns that this de-risking could be blocking consumers' (and small businesses') access to financial products and services. You can watch the hearing on video (the hearing actually begins at 16:40).

While a financial institution should certainly monitor its customer accounts to ensure compliance with its risk tolerance and compliance policies, we have to ask if the independent ATM operators are being painted with a risk brush that is too broad. The reality is that it is extremely difficult for an ATM operator to funnel "dirty money" through an ATM. First, to gain access to the various ATM networks, the operator has to be sponsored by a financial institution (FI). In the sponsorship process, the FI rigorously reviews the operator's financial stability and other business operations as well as compliance with BSA/AML because the FI sponsor is ultimately responsible for any network violations. Second, the networks handling the transaction are completely independent from the ATM owners. They produce financial reports that show the amount of funds that an ATM dispenses in any given period and generate the settlement transactions. These networks maintain controls that clearly document the funds flowing through the ATM, and a review of the settlement account activity would quickly identify any suspicious activity.

The industry groups representing the independent ATM operators appear to have gained a sympathetic ear from legislators and, to some degree, regulators. But the sympathy hasn't extended to those financial institutions that are accelerating account closures in some areas. We will continue to monitor this issue and report any major developments. Please let us know your thoughts.

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

August 27, 2018

Who Owns Your ATM?

Counting the number of ATMs in the United States has been a challenge since 1996, when independent operators (nonfinancial institutions) started deploying ATMs/cash dispensers. That was when Visa and MasterCard dropped their prohibition against surcharges. But a recent study sponsored by the National ATM Council largely overcame that challenge while also gathering some interesting results about the locational aspects of the independently owned ATMs compared to machines owned by financial institutions (FI).

The study was conducted earlier this year by a team of economics professors from the Department of Economics and Geography in the University of North Florida's Coggin School of Business. The study's primary objective was to determine whether the locations of independently owned ATMs and FI-owned ATMs were different in terms of demographics and socioeconomic status.

Using a database from Infogroup, the team identified 470,135 ATMs operating in 2016. About 41 percent of these were FI-owned, and the rest were independently owned. The majority of the independent ATMs are in retail establishments, with heavy concentrations in convenience stores, pharmacies, and casual dining locations.

FI owned ATMs Duval Median Household Income 2016 Independently owned ATMs Duval Median Household Income 2016
(Click on the images to enlarge.)

The research team plotted the locations of all the ATMs, overlaying demographic and socioeconomic data they obtained from the U.S. Census Bureau and its American Community Survey. Among the 10 main elements the researchers used were median age, unemployment rate, education level, household income, disposable income, and average home values.

They concluded that the independent ATMs "tend to be located in areas with less population, lower population density, lower median and average income (household and disposable), lower labor force participation rate, less college-educated population, higher unemployment rate and lower home values."

So what does this mean?

Well, it means that the independently owned ATMs are providing a vital service in rural and inner-city areas. Other studies—such as the Federal Reserve's Diary of Consumer Payment Choice—have shown that lower-income households (those earning less than $50,000) use cash as their primary method of payment. Therefore, these independent ATM owners are giving these households access to financial services that would otherwise be limited.

A post from December 2014 highlighted some of the challenges the independent operators were facing. Stand by for a future post that will provide an update on this part of our country's payment ecosystem.

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

December 18, 2017

Training Workers for Payments Jobs

Do you boast, or at least talk, about your work in payments at social events? When I tell someone in a social setting that I work in payments, they either move on, after a polite pause, to meet the next person, or they take a deep breath and ask, “What does that entail?” What is most humbling is when I overhear my husband trying to explain my job. And what has been the most entertaining was when a four-year old asked me to perform an interpretive dance representing my occupation—a payments Nutcracker, if you will. Whatever the circumstance, you have to be ready to engage and convey excitement about all things payments to keep our workforce thriving. The industry is growing so rapidly that many employers are struggling to fill positions.

Many people I meet assume I am a mathematician when I talk about my work in payments. While I do own a calculator, I tell them, people in the payments workforce have diverse skill sets that go above and beyond using calculators. This diversity becomes more important every day, as technology keeps growing and changing. Ultimately, the majority of the population may not care how payments work, and they may not care to see an interpretive dance about payments. But there are dedicated, skilled professionals who, thankfully, perform their payments-related jobs safely and efficiently. And we need more of them.

The payments industry is growing. Fintechs alone account for a good portion of this growth. According to an industry research firm, venture capital-backed fintech companies globally raised a total of $5.2 billion in the second quarter of this year—–a 19 percent increase from last year. U.S. fintech funding saw a 58 percent rise, to $1.9 billion in the second quarter this year compared to $1.2 billion in the first quarter.

We need a more robust pipeline of available workers to support the growth in the industry. We need to both cultivate new talent and attract available skilled talent. This task can be daunting given the range of jobs available in the industry that transcend traditional educational curriculums.

Here are just a very few of many inspiring workforce training initiatives supporting industry growth today:

  • FinTech Atlanta, along with the University System of Georgia and other colleges and universities in Georgia, launched a FinTech Degree and Certificate Programs to create needed talent to fuel the fintech workforce.
  • NACHA, with the regional payments associations, has launched a Payments Risk Professional accreditation program. The program brings together skills for managing risk combined with knowledge in payment services, whether for financial institutions, solution providers, processors, businesses, or other end users.
  • Workforce Innovation Hub, sponsored by Accenture and affiliated with Atlanta's City of Refuge, provides nonprofit technical education options to lift the underemployed and underprivileged. The IT training program teaches software and application development, IT support, web development, graphic design, and more—all skills that can be put to use in payments and fintechs.
  • Some professional development programs work with military veterans, offering career opportunities and education resources that can help prepare them for careers in the payments industry. One example is First Data Salutes; another is Syracuse University's Institute for Veterans and Military Families (IVMF) and its affiliated program Entrepreneurs Bootcamp for Veterans with Disabilities.

Be a payments ambassador at your next social event and talk about your favorite payments initiative. It is up to you to decide if you want to perform an interpretive dance of your payments job—but it's up to all of us to keep our workforce growing at pace with the industry.

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

 

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