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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January 27, 2020
Mobile Banking Nearing Ubiquity
In June 2019, eight Federal Reserve districts,1 led by the Federal Reserve Bank of Boston's Payment Strategies Group, surveyed financial institutions (FI) based in their respective districts about their current and planned mobile banking and mobile payment service offerings. The survey defined mobile banking as the use of a mobile phone to connect to a financial institution to access bank or credit account information (including to view balances), transfer funds between accounts, pay bills, set up account alerts, locate ATMs, deposit checks, and more. The term mobile payments described the use of a mobile phone to pay at the point of sale, remotely for a retail item (or items) using near field communication or a quick response code, or via mobile app or web for digital content, goods, or services (such as transit, parking, or ticketing).
You can find the full 2019 Mobile Financial Services Survey report, including the survey questionnaire, on the Boston Fed website. This collaborative survey effort previously took place in 2014 and 2016.
The survey found that 96 percent of the respondents currently offered or planned to offer mobile banking services. (As expected, most of the respondents who indicated they had no plans to offer mobile banking—18 of the 23—were the smallest FIs [those with assets under $50 million]). Support for mobile payment services had increased significantly since the 2016 survey, going from 24 percent to 43 percent in 2019, with an additional 26 percent planning to support mobile payments within two years.
Especially interesting to me were the responses to a new survey question regarding FIs' plans to issue contactless payment cards. Many of the largest FIs began issuing contactless cards in 2019. The survey found that while only 5 percent of respondents were issuing contactless cards, 21 percent plan to do so within two years and an additional 18 percent plan to issue them in the next two to five years. As the chart shows, although nearly two-thirds of the smallest FIs indicated no plans to offer a contactless card, a relatively high percentage (43%) of the larger FIs also indicated no plans to do so. I am curious to see how these plan responses change, if any, in future surveys.
A total of 504 financial institutions responded—337 banks and 167 credit unions (CUs)—which represented 6 percent of all banks and 3 percent of all CUs in the United States. It is important to note that none of the top 100 banks by asset size and only four of the top 100 CUs by asset size are included in the survey. Almost half of the responding CUs have assets under $100 million. The distribution of survey respondents (displayed in the chart below) helps us better understand the development of mobile financial services in the mid- and small-sized FIs.
The Boston Fed's Payment Strategies Group will present a webinar on the full survey report later this year. We will be sure to keep Take On Payments readers apprised of those plans. In the meantime, if you have any questions regarding the survey or the results, please be sure to contact me.
1Atlanta, Boston, Cleveland, Kansas City, Minneapolis, Philadelphia, Richmond, and San Francisco
September 3, 2019
Is Friction in Payments Always Bad?
Numerous posts in this blog have noted the conventional wisdom that the less friction there is for a consumer in making a payment, the likelier it is that the consumer will have a good experience. Merchants, especially ecommerce retailers, point to studies consistently showing that when customers are required, for stronger authentication, to enter more information than they're used to during a payment, the cart abandonment rate increases and merchants lose sales. I have learned from my own conversations with merchants that some have backed away from adding more risk management tools because they would rather take the financial loss from a fraudulent transaction than discourage an otherwise legitimate sale. This balancing act between reducing friction for the customer and reducing fraud risk to the merchant or payment card issuer is a constant challenge.
Many merchants have incorporated mobile devices' biometric authentication features into their mobile apps to keep the customer from having to provide additional authentication data. Some other vendors have recently developed risk mitigation and authentication tools that work completely in the background and give them more confidence that the individual conducting the transaction is legitimate. These tools range from behavioral analytics that rely on patterns of previous transactions—whether they're based on a specific customer or on a group of customers with a similar profile—to electronic device information, called device fingerprinting, that validates that the device being used is actually the customer's. The customer is unaware that these tools are being used, so experiences lower friction.
A new term being used for what is regarded as an improved payment experience is the invisible payment transaction. This happens when a payment is triggered automatically without any customer intervention at the time of the transaction. The best examples of invisible transactions are in the sectors of subscription or card-on-file services. Subscription services include any service where the customer has provided, for example, a payment card or deposit account for a transaction and authorized the merchant or service provider to make future payments using that account. Online retailers, rideshare services, and recurring payments for health clubs, parking garages, utility companies, and charitable organizations are all types of businesses that use subscription services. A relatively recent entrant in the invisible payment segment is the computer/camera monitored shopping experience at some retailers.
So do invisible payments mean we've achieved nirvana? While they certainly provide the lowest level of customer interaction, they also have some possible disadvantages. Consumer advocates are concerned about the impact such payments might have on an individual's budget management. What if they forget about a subscription payment, and when it's deducted from their account, it creates an overdraft or insufficient funds return? Will invisible payments result in increased spending by the consumer? And then there is the bother of updating a bunch of subscriptions if the consumer changes the funding account.
While research has shown that consumers see convenience as a positive factor, they also want to be confident that there is a security process that will make them less likely to be victims of fraud. Will we ever reach the place of total payments peace and happiness with the right balance of security and convenience? Please let us know what you think.
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
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