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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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September 21, 2020

Personal Responsibility for Irrevocable Payment Scams

Those who have experience with parenting know that with many joys come challenges. For me, one of those challenges is teaching my children the importance of personal responsibility. Picking up after themselves, making sure their chores are finished before running out the door to play, and owning up to mistakes are just some of the personal responsibilities that they struggle with daily. And while there is a light at the end of the tunnel for this struggle, I firmly believe it is their having to experience the consequences that is getting us there. In this parent's opinion, knowing there are consequences for their actions helps children become responsible.

You might be thinking, "What does this notion of teaching personal responsibility have to do with payments?" Earlier this year, my colleague Dave Lott started the dialogue among those of us at the Risk Forum, and perhaps within some of our readers' circles, when in a post he posed the question "What is the likelihood that similar protections will be extended to consumers here (United States)?" The post was related to the extension of consumer protections in the United Kingdom to combat its growing problem of authorized push payment (APP) fraudOff-site link.

In August, a UK-based consumer advocate organization called Which?Off-site link released a research reportOff-site link based on the experiences of 150 consumers related to the Contingent Reimbursement Model (CRM) Code adopted by many financial institutions in the United Kingdom in 2019. The CRM Code has two primary goals: to reduce the occurrence of APP fraud and, for the fraud that occurs, to reduce the impact. Many of these scam payments in the United Kingdom are occurring on their faster payments rail, which was designed to make payments immediate and irrevocable. The report concluded that consumers' experiences with reimbursement for APP scams were mixed. Some consumers were reimbursed by their financial institution after authorizing payments to scammers while others were unable to receive any reimbursements.

The primary payment instrument in the United States today for large-scale corporate APP scams is wire. For consumers, person-to-person (P2P) services such as CashApp, Venmo, and Zelle are being used to scam individuals out of money. All these payments, both business and consumer, are irrevocable. Once the payments leave their accounts, neither the financial institution nor service provider has liability. But should individuals in the United States, like those in the United Kingdom, be afforded protections for these wire and P2P payments if they're scammed? And should these protections also apply to newer real-time payment schemes here in the United States?

My personal belief is that financial institutions or P2P services should not be responsible for people who fall victim to APP scams. Their responsibility should be limited to educating their customers on the rules around these payments and their finality when executed. APP scams are often the result of social engineering campaigns, and I am of the thought that, just as I expect my children to accept personal responsibility for their mistakes, it's fair for consumers to accept their responsibility for making sure they do not become the next social engineering victim. Do you think this is a reasonable approach to these scams and payments? Or should the United States banking industry and regulators move toward a model like the United Kingdom has in place?

July 27, 2020

SNAP Gets Snappier and Offers Ecommerce and Fraud Prevention

In April 2019, the USDA launched the Supplemental Nutrition Assistance Program (SNAP) online purchasing pilot programOff-site link, which allows participants to purchase groceries online. What began as a two-year pilot program in one state with a gradual rollout to additional states is now available in 40 states (with five additional states granted approval and in the planning phase). The COVID-19 public health emergency, which has made access to online grocery shopping critical, expedited the program's deployment. The USDA also rolled out the Pandemic Electronic Benefits Transfer (P-EBT) program as a SNAP extension. With P-EBT, children in low-income households continued to receive the free or reduced-priced meals that they would normally have received in school during the 2019–20 school year.

This is certainly a positive move toward advancing ecommerce inclusion. However, more ecommerce transactions present more fraud risks and opportunities for criminals. (My colleague Doug King blogged a few years ago about fraud risks SNAP was already experiencing, including trafficking.) To mitigate some of these ecommerce risks, the Department of Agriculture's (USDA) Food and Nutrition Service (FNS), which administers SNAP, has increased security for online EBT card use. SNAP benefits and P-EBT benefits are both delivered on PIN-enabled EBT cards that function like prepaid debit cards. Retailers must use a USDA-approved, third-party processor that offers secure PIN-on-glass entryOff-site link for online purchases. When customers transact online using their EBT card, they must enter their EBT PIN to complete their purchase. In addition, retailers must successfully meet the FNS's stringent technology and testing requirementsOff-site link.

Unfortunately, these technology and testing requirements to integrate a secure online purchasing environment with the grocer's EBT benefits system are extensive and cannot be done overnight. As a workaround until retailers can fully integrate their systems, the USDA recommendsOff-site link that SNAP customers take advantage of existing services like "pay at pickup," where customers place grocery orders online and pay with their SNAP EBT card when they get their groceries—which allows them to follow both social distancing and ecommerce fraud-prevention guidelines.

The USDA's SNAP Fraud FrameworkOff-site link offers states resources to help them proactively identify potential fraud and suggests best practices on fraud prevention and mitigation. You can learn more about the USDA's efforts to manage fraud risk by visiting their websiteOff-site link

June 1, 2020

My Dog the Cybercriminal

As I write, my dog Coco gazes at me soulfully in a bid to wrangle a bite of my peanut butter sandwich or, even better, the whole sandwich. This cute yet parasitical behavior is typical. In fact, after some weeks of close association, I have come to realize that Coco exhibits not only the skills but also the personality traits of a cybercriminal:

Coco, my dog.
  • She tracks my every move and knows when she's most likely to get a treat, just as scammers prepare for phishing attacks by learning about a business's vendors, billing systems, and "even the CEO's style of communication Adobe PDF file formatOff-site link."
  • She leaps at opportunities—butter on a counter, an open dishwasher—just as scammers are leaping at the chance to steal Economic Impact Payments, as Take On Payments reported in early May.
  • She balances work and reward. Coco knows the difference between kibble and mozzarella cheese and differentiates her efforts accordingly. In trainer lingo, the mozzarella is a "high-value treat," analogous to the personal information a criminal might be able to obtain via health care and Medicare fraudOff-site link.
  • She repeats successful tactics, like counter surfing. Similarly, perpetrators of the "grandparent scamOff-site link" know that what worked with imaginary bachelor parties in 2019 will work with imaginary emergency hospitalizations in 2020.
  • She's persistent. Again and again, she noses my hand away from my keyboard. Eventually, a treat or walk will ensue. Again and again, scammers email fraudulent COVID-19 cures and investment opportunitiesOff-site link in the hope of eventual success.
  • She adapts. How can she get the treat? Sit? Lie down? Roll over? Sit again? Criminal enterprises continually experiment and adjust, for example, by changing the threat of shut-off in the "classic utility scamOff-site link" to an offering of discounts on utility bills.
  • She's adorable. Every dog is, but trust me, Coco is especially adorable, just like the photo in a phishing email posing as an appeal from a worthy charity Adobe PDF file formatOff-site link.
  • She is utterly unconcerned with the needs and preferences of others: the criminal mind at work.

No doggy day care. No walker. Me and Coco, 24/7. Did I mention that she's adorable?

It you sight any of these doggy behaviors, you can report coronavirus-related complaints to the Justice Department National Center for Disaster FraudOff-site link.

May 11, 2020

Seeing the Future through a Morning with Fifth Graders

Early in March, I spent the morning with four fifth-grade classes at an elementary school as part of their college and career day. My son had asked me not to talk about writing blogs and papers but rather to talk about "cool" things in payments and fraud. So that's exactly what I did with each class for 15 minutes, leaving the remaining 10 minutes of the time for questions or discussion. Looking back, I wish I had allotted more time for the final portion because these fifth graders were as engaging an audience as I have ever had. I left the school with two thoughts that I think the payments industry could find valuable, so thought it would be worthy of sharing with our readers today.

First, I was surprised by the general level of awareness that the fifth graders exhibited around online safety. Many had stories to share of both successful and unsuccessful attempts of their relatives being scammed online or through the phone. Others shared stories of their parents' bank accounts or cards being compromised. Several students talked about how they search safely on the internet. I was probably naïve going into the day about their level of knowledge and awareness seeing that these kids have grown up with this technology a part of their daily lives, but call me impressed that many of them are well aware of dangers lurking and eager to learn how to better protect themselves.

Second, I was blown away by the kids' access to and use of smart-assistant speakers. I have heard a number of people project that speech recognition is the future of commerce and if the kids I met with are any indication of their generation, then I think I can get on board with those projections. In an unscientific survey, I would estimate that nearly 90 percent of the kids had access to at least one smart-assistant speaker, and amazingly 75 percent had one in their room. Without naming any names, one company dominated this space for the group. While the "phone" aspect of the mobile phone for many kids is foreign as it's primarily used as a camera or texting device, it seems that they actually are comfortable having a conversation with a speaker.

As I walked back to my car, my mind was filled with thoughts about the future. On the one hand, I was smiling because this young generation is going to be better prepared in understanding the risks of the cyberworld that will continue to play a more prominent role in our lives. People will always be vulnerable but I left with confidence that our young people are aware that there are bad people lurking behind computer screens. On the other hand, my mind was spinning because I predict that commerce through a smart-assistant speaker will be as common a practice for them as dipping a card is for me. How different that world will look from where we are today!

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