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.
Comments are moderated and will not appear until the moderator has approved them.
Please submit appropriate comments. Inappropriate comments include content that is abusive, harassing, or threatening; obscene, vulgar, or profane; an attack of a personal nature; or overtly political.
In addition, no off-topic remarks or spam is permitted.
Federal Reserve Web Sites
Other Bank Regulatory Sites
September 16, 2019
Is There a Generation Gap in Cash Use?
How different are millennials from boomers in their reported payment habits, especially regarding their use of cash? New data from the Survey of Consumer Payment Choice, out this month, lets us look at age segments using the interactive charts accompanying the report.
For example, in 2018, consumers overall made 17 payments a month in cash. Drilling down, consumers aged 25 to 34—that is, millennials—used cash for 15 payments per month. Consumers 55 to 64—the boomers—used cash for 18 payments a month.
It's good to put these numbers in context. Here's a fact that surprised me: the younger group makes more total payments per month (73) than does the older group (67). That means that, as a percentage share of all payments, the difference by age is more pronounced:
- Millennials: 21 percent of their payments in cash
- Boomers: 27 percent of their payments in cash
The differences are similar when we look at paper checks, which the younger group used for 2 payments per month (3 percent of their payments) and the older group for 4 payments per month (6 percent).
You'll notice in the chart that payments instrument usage has been relatively stable for all the age groups since 2015.
Millennials' relatively lower use of cash doesn't mean, however, that the cashless society is going to arrive any time soon. In 2018, 85 of 100 consumers used cash in a typical month. And, in an analysis that incorporates a complete set of demographic variables plus income, differences by age could prove not so relevant. So, is there a generation gap in cash use? Yes. Does it mean the end of cash? No.
The charts at the website let you look at consumer payment choice by household income group and by the type of transaction. For example, you can examine how consumers' use of payment instruments is different for P2P payments than for bill payments. Check them out.
February 19, 2019
Acute Audit Appendicitis
My son came home from school the other day and told me that his friend’s kidney had "popped." With great concern and further investigation, I found out that his friend had suffered from appendicitis but had since recovered. Luckily, fifth grade boys and most of the human race can get along fine without an appendix. And, as it turns out, there is another type of appendix people can live without: Appendix Eight—Audit Requirements—in the NACHA Operating Rules. NACHA members recently voted to cut this part out.
But wait—don’t celebrate too soon. The change doesn’t eliminate the requirement to conduct an annual ACH rules compliance audit. Rather, members voted to modify "the Rules to provide financial institutions [FI] and third-party service providers with greater flexibility in conducting annual Rules compliance audits." Specifically, the change—which was effective January 1, 2019—affected the following areas of the NACHA Operating Rules:
- Article One, Subsection 1.2.2 (Audits of Rules Compliance): Consolidates the core audit requirements described within Appendix Eight under the general obligation of participating DFIs and third-party service providers/senders to conduct an audit.
- Appendix Eight (Rule Compliance Audit Requirements): Eliminates the current language contained within Appendix Eight; combines relevant provisions with the general audit obligation required under Article One, Subsection 1.2.2.
FIs and ACH payment processors must still conduct, either internally or outsourced, an annual audit of their compliance with the ACH rules each year. They also must retain adequate proof of completion for no less than six years and may, during that term, need to provide proof to NACHA or a regulator. And they will have to adjust their audit methodologies to ensure that they comply with all relevant rules rather than just rely on the former Appendix Eight checklist.
The new audit process necessitates a risk-based approach, which is a strategy regulators have been encouraging in recent years. With so many emerging technologies, products, and services in the payments industry, FIs and ACH payment processors can no longer take a one-size-fits-all approach for compliance. They also no longer have a single access point to ACH—rather, they must consider many access points when auditing for Rules compliance.
These institutions may not have previously had to take into account other areas that touch payments. For example, the risk-based audit doesn’t explore just the deposit operations department; it analyzes how the whole enterprise interacts with ACH systems. Additionally, it may need to include loan operations, online account opening, person-to-person (P2P) products, investment management, and other new digital channels.
Life without Appendix Eight will be an adjustment, but its removal won’t be fatal. I think ACH participants will recover quickly and be even healthier—embracing the new risk-based compliance model will likely strengthen enterprise risk management and promote increased safety and stability in our payment systems.
By Jessica Washington, AAP, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
June 11, 2018
Consumer Habits and Cash Use
As my colleague Doug King pointed out last month, cash is not going away anytime soon, Yanny/Laurel notwithstanding. By number, almost one-third of U.S. consumer payments were made in cash in 2017. Every year since 2008, the Survey of Consumer Payment Choice has found that cash is consumers' most popular or next-most-popular way to pay.
Many factors underlie cash's resilience, including access, current shopping habits, consumer ratings, and demographics.
Universal access. Paypal's chief financial officer commented to the Wall Street Journal earlier this year, "I don't think we will ever be entirely cashless, maybe in large part because I don't know if we will ever be in a world that every person has a smartphone or a mobile device."
Shopping habits. Most purchases—nine in 10—are made in person, not online (2015 Survey of Consumer Payment Choice). And when shopping in person, consumers prefer cash for small-dollar transactions. Two-thirds of U.S. consumers report that they prefer cash for in-person payments of less than $10 (2016 Dairy of Consumer Payment Choice). Forty percent prefer cash for in-person payments between $10 and $25.
Consumer ratings. Consumers say cash is the most cost-effective way to pay. The Survey of Consumer Payment Choice asks respondents to rate the cost of using a particular payment method, taking into account that fees, penalties, interest paid, etc. can raise the cost of a payment method, while discounts and rewards can lower it.
Demographics. People with fewer payment options use cash. That includes low-income people who have less access to credit cards as well as people without bank accounts who have no access to non-prepaid debit cards. It also includes millennials, who used cash for almost 30 percent of their payments in 2016 (Diary of Consumer Payment Choice).
You probably already know that card payments dwarf cash payments—almost 60 percent of consumer payments are made with some type of card, whether it's debit, prepaid, or credit. Yet cash persists. Recently, a new acquaintance told me he "never" uses cash. As evidence, he reported that he had no cash in his pocket, explaining "that's because I used my last $2 to buy coffee this morning."
Hmm. What does this say about the health of cash? What Dave Lott wrote in 2016 is still true today: not dead yet.
Next post: Merchant acceptance and the use of cash
To learn more about consumer payment choices and preferences, visit the Federal Reserve Bank of Atlanta’s new consumer payments web page that houses a variety of surveys, studies, and research reports on the topic.
By Claire Greene, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
April 30, 2018
Cash Discount Programs: The Flip Side of Surcharging?
In a recent post, I reviewed the structure of credit card surcharging programs that a panel discussed at the Southeast Acquirers Association conference earlier this year. Since that post, some of my colleagues who have encountered cash discount programs asked me if they were simply the flip side of credit card surcharging. While there are some similarities in the requirements of the two programs, there are some key differences.
Cash discount programs became legal across the United States in October 2011, following the passage of the Durbin amendment of the Dodd–Frank Act. That amendment permitted merchants to offer a discount to cash (or check) customers as an incentive to use those payment methods instead of cards. The way it works is that the merchant charges a service fee to all transactions that the merchant then reverses or discounts if the customer pays with cash or check.
The sample receipts below illustrate the difference between a purchase made with a payment card and a cash payment from a merchant who uses a flat service charge pricing option.
Unlike surcharges, which apply only to credit card payments, service fees are applied against all types of card payments. And while surcharge program fees are always a certain percentage of the transaction, a cash discount program can use a flat fee (usually based on the average ticket size) or a percentage of the transaction amount. Businesses with a wide range of sales values would best be served using the percentage model, while a flat fee works better for businesses with relatively consistent ticket sizes. Credit card surcharge program rates are capped at 4 percent of the transaction amount, but cash discounting has no restriction. Of course, the higher the service fee the more likely the customer will be to notice and possibly move to another merchant who does not have such a program.
As with surcharges, the cash discount merchant must prominently display consumer notices at the entry points of the store as well as at the register about the service charge—that the customer can reduce or avoid by using cash. In addition, the sales receipt must explicitly display the service charge and, when applicable, the cash discount.
Among the possible benefits, merchants can lower their effective card processing expenses by collecting the service charge. Colleagues at the Boston Fed authored a discussion paper titled "Why Don't Most Merchants Use Price Discounts to Steer Consumer Payment Choice?" in late 2012 that reviewed a number of factors that might cause merchants to think twice about implementing a cash discount program. I believe the factors they reviewed are as relevant today as they were at the time of the paper. As for the credit card surcharge, the merchant has to consider customers' potentially negative response to such a fee, especially if they believe that the merchant has already built much of the cost of payment acceptance into the goods and services.
Merchants have to register credit card surcharge programs with the card brands prior to implementation. However, cash discount programs have no such requirement, so their adoption rate among the merchant community is difficult to quantify. One indicator may be from the Federal Reserve's 2015 Diary of Consumer Payment Choices. According to an analysis of the data, the national sample of respondents indicated they received a cash discount on 1.9 percent of their non-bill transactions that had a median value of $20. Interestingly, in a breakdown by industry type, transactions at automobile/vehicle-related and entertainment/transportation businesses were more likely to offer a cash discount—of 8.2 percent and 5.1 percent, respectively.
What has been your experience with cash discount or credit card surcharging programs? Did such a program cause you to change your initial form of payment?
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
Take On Payments Search
- account takeovers
- ATM fraud
- bank supervision
- banking regulations
- banks and banking
- card networks
- check fraud
- consumer fraud
- consumer protection
- credit cards
- crossborder wires
- data security
- debit cards
- emerging payments
- financial services
- financial technology
- identity theft
- law enforcement
- mobile banking
- mobile money transfer
- mobile network operator MNO
- mobile payments
- money laundering
- money services business MSB
- online banking fraud
- online retail
- payments fraud
- payments innovation
- payments risk
- payments study
- payments systems
- Payment Services Directive
- phone fraud
- remotely created checks
- risk management
- Section 1073
- skills gap
- social networks
- thirdparty service provider
- trusted service manager
- Unfair and Deceptive Acts and Practices UDAP
- wire transfer fraud
- workforce development
- workplace fraud