The document provides an overview of regulatory developments in prepaid and emerging payments in 2013. It summarizes key issues including increased consumer protection scrutiny of payroll and student cards, data security fallout from breaches like Target, concerns about tax refund and benefits fraud, ongoing uncertainty around the Durbin interchange rules, and heightened anti-money laundering focus from FinCEN. It also discusses the fragmented development of mobile wallets and growing international regulatory differences.
Regulators on the Move – Recent Treasury and Comptroller Actions: How They Af...Winston & Strawn LLP
The U.S. Treasury and Comptroller of the Currency recently published reports and announced major initiatives of impact to financial institutions. What should directors know about these initiatives and how do they impact financial institution strategy? This webinar discussed those issues, addressed likely competition from fintech firms, and focused on the following topics:
- U.S. Department of the Treasury report on “Nonbank - Financial, Fintech, and Innovation”
OCC’s fintech charter
- Recent efforts by institutions to eliminate holding company regulations
Contact Winston & Strawn for more information about this presentation:
https://www.winston.com/en/thought-leadership/regulators-on-the-move-recent-treasury-and-comptroller-actions-how-they-affect-you.html
Holvi, Seed, CivilisedBank, Tide, Qonto, Azlo, Penta, Arival bank
Neobanks or fintechs for retail clients, which have launched business accounts recently: TransferWise, Revolut, StarlingBank, N26
(c) Life.SREDA VC
The Fintech industry which is the backbone of all economies has also been impacted because of Covid. What are the implications of Covid to an important sector?
Payment processing technology advances to allow businesses to process payments in a convenient, fast and reliable manner for all parties involved.
These payment trends should be in the radar of all business to stay ahead of payment processing innovation and offer the best solutions.
https://www.chetu.com/payments/billing.php
Regulators on the Move – Recent Treasury and Comptroller Actions: How They Af...Winston & Strawn LLP
The U.S. Treasury and Comptroller of the Currency recently published reports and announced major initiatives of impact to financial institutions. What should directors know about these initiatives and how do they impact financial institution strategy? This webinar discussed those issues, addressed likely competition from fintech firms, and focused on the following topics:
- U.S. Department of the Treasury report on “Nonbank - Financial, Fintech, and Innovation”
OCC’s fintech charter
- Recent efforts by institutions to eliminate holding company regulations
Contact Winston & Strawn for more information about this presentation:
https://www.winston.com/en/thought-leadership/regulators-on-the-move-recent-treasury-and-comptroller-actions-how-they-affect-you.html
Holvi, Seed, CivilisedBank, Tide, Qonto, Azlo, Penta, Arival bank
Neobanks or fintechs for retail clients, which have launched business accounts recently: TransferWise, Revolut, StarlingBank, N26
(c) Life.SREDA VC
The Fintech industry which is the backbone of all economies has also been impacted because of Covid. What are the implications of Covid to an important sector?
Payment processing technology advances to allow businesses to process payments in a convenient, fast and reliable manner for all parties involved.
These payment trends should be in the radar of all business to stay ahead of payment processing innovation and offer the best solutions.
https://www.chetu.com/payments/billing.php
Debt Resolve Inc. (OTCBB: DRSV) is a leading provider of patented online bidding solutions for the settlement and collection of defaulted consumer debt. The company also provides early stage solutions for delinquent debt that has not charged off. Unlike Portfolio Recovery Associates Inc. (NASDAQ: PRAA) and Asset Acceptance Capital Corporation (NASDAQ: AACC), the company does not buy debt but works as a pure play technology company with banks, creditors, law firms and collections agencies to help them more efficiently recover funds.
Carlos Conesa innovations and non-banks in retail paymentsBogdan Stavrev
1.What is the CPMI and what is its role?
2.Recent work of the CPMI in the field of retail
Innovations in retail payments (what?)
Non-banks in retail payments (who?)
3.Some conclusions and future outlook
Potential second round effects (“faster” payment systems?)
And what about virtual currencies?
Lessons for interoperability remedies from UK Open Bankingblogzilla
The UK’s Open Banking programme is a world-leading experiment in requiring banks to open up customer accounts (with their explicit consent) to third-party providers. What lessons can be learnt from this case for legislation that would require dominant platforms to provide similar functionality?
Presentation on mobile payments and mobile money at the June 2013 SmarterCommerce Global Summit in Monaco. Includes description of relevant IBM product families that support mobile money and mobile payments.
Impact of Technology on E-Banking; Cameroon PerspectivesEswar Publications
The financial services industry is experiencing rapid changes in services delivery and channels usage, and financial companies and users of financial services are looking at new technologies as they emerge and deciding whether or not to embrace them and the new opportunities to save and manage enormous time, cost and stress.
There is no doubt about the favourable and manifold impact of technology on e-banking as pictured in this review paper, almost all banks are with the least and most access e-banking Technological equipments like ATMs and Cards. On the other Hand cheap and readily available technology has opened a favourable competition in ebanking services business with a lot of wide range competitors competing with Commercial Banks in Cameroon in providing digital financial services.
10th Annual World Payments Report 2014 from Capgemini and The Royal Bank of S...Capgemini
Ten years after publishing the first World Payments Report, Capgemini and RBS continue to provides insight into global and regional non-cash payment trends. This year it gives us a view on cross border payments and a spotlight on the U.S. market; the latest regulatory and industry initiatives including PSD2, immediate payments and intraday liquidity management; innovation within payment processing; and key changes over the last 10 years and what can we expect from the payments industry over the next 10 years.
Debt Resolve Inc. (OTCBB: DRSV) is a leading provider of patented online bidding solutions for the settlement and collection of defaulted consumer debt. The company also provides early stage solutions for delinquent debt that has not charged off. Unlike Portfolio Recovery Associates Inc. (NASDAQ: PRAA) and Asset Acceptance Capital Corporation (NASDAQ: AACC), the company does not buy debt but works as a pure play technology company with banks, creditors, law firms and collections agencies to help them more efficiently recover funds.
Carlos Conesa innovations and non-banks in retail paymentsBogdan Stavrev
1.What is the CPMI and what is its role?
2.Recent work of the CPMI in the field of retail
Innovations in retail payments (what?)
Non-banks in retail payments (who?)
3.Some conclusions and future outlook
Potential second round effects (“faster” payment systems?)
And what about virtual currencies?
Lessons for interoperability remedies from UK Open Bankingblogzilla
The UK’s Open Banking programme is a world-leading experiment in requiring banks to open up customer accounts (with their explicit consent) to third-party providers. What lessons can be learnt from this case for legislation that would require dominant platforms to provide similar functionality?
Presentation on mobile payments and mobile money at the June 2013 SmarterCommerce Global Summit in Monaco. Includes description of relevant IBM product families that support mobile money and mobile payments.
Impact of Technology on E-Banking; Cameroon PerspectivesEswar Publications
The financial services industry is experiencing rapid changes in services delivery and channels usage, and financial companies and users of financial services are looking at new technologies as they emerge and deciding whether or not to embrace them and the new opportunities to save and manage enormous time, cost and stress.
There is no doubt about the favourable and manifold impact of technology on e-banking as pictured in this review paper, almost all banks are with the least and most access e-banking Technological equipments like ATMs and Cards. On the other Hand cheap and readily available technology has opened a favourable competition in ebanking services business with a lot of wide range competitors competing with Commercial Banks in Cameroon in providing digital financial services.
10th Annual World Payments Report 2014 from Capgemini and The Royal Bank of S...Capgemini
Ten years after publishing the first World Payments Report, Capgemini and RBS continue to provides insight into global and regional non-cash payment trends. This year it gives us a view on cross border payments and a spotlight on the U.S. market; the latest regulatory and industry initiatives including PSD2, immediate payments and intraday liquidity management; innovation within payment processing; and key changes over the last 10 years and what can we expect from the payments industry over the next 10 years.
Aligning data life cycle with qb d risk management principle across the produ...SANDEEP DIWAKER
Dear all,
Herewith sharing the presentation on “Aligning Data Life Cycle with QbD Risk Management Principle across the product life cycle” session conducted in Biotrains event on “Data Integrity”
Over view of the value of job order contracting programs for facilities and construction in public funded building efforts. Written by Kristin Atwater for Government Procurement Journal and reprinted in the Washington Building Congress newsletter Bulletin - David Carrithers helped get the article placed and also the supporting pictures (was the cover story on July/Aug 2006
Presentation Slides for Keynote Address ... SUCCESS AND HAPPINESS Chris Walker
You Can't Give What You Haven't Got. The Size of Your Vision determines the size of your life. Balanced people are balanced in all seven areas of life.
Rising Above Uncertainty: Opportunities and Challenges for Credit Unions in P...NAFCU Services Corporation
The retail financial services market is in a transformative period where new stakeholders and business models are reshaping the industry. Credit unions still have the opportunity for retention and growth, but must continue to compete. In this presentation, you will get an in-depth look at key market dynamics, including evolving financial services models and regulatory impact; learn about emerging strategies and their impact to credit unions, including EMV, prepaid, and mobile; and find out how to prepare for the future.
1.3. Definition of terms
“Credit policy” means a general framework approved by the board that spells out and guides the bank’s credit/financing strategic directions and credit /financing decisions.
“Credit Scoring” means judging/evaluating the creditworthiness of a customer based on basic characteristics and past performance in credit and other relationships with Bank.
“Digital Micro Credit” means micro loans that are requested, received and repaid all through mobile phones (or any other appropriate tools) via interaction with a computer system.
“Digital MSL Policy” means a policy document that governs the management of digital micro saving and credit services.
“Fixed Account” means a saving account locked for a certain period, a minimum of three months, based on the preference of the customers to fulfil their designated plan.
“Lending officials” means any person involved in MSL business of customer acquisition, Credit Worthiness evaluation, Credit operation, Collection, monitoring and decision-making as well as write off and post write off follow up process.
“Loan Pricing” means setting the interest rate, fees, commission, and others to be charged by the Bank on loans, advances, and guarantees extended to customers.
“Retail and Micro Business Segment” means a category of customers having less investible asset, trading transaction and return from business.
“Micro loan” means a small amount of loan availed to micro businesses and individuals for the purpose of supporting businesses and consumption.
“Micro Saving” means a saving scheme designed for small deposits from micro businesses and low income individuals
"Micro business customers" means customers having less investable asset, trading transaction and return from business. They represent the lower class of wholesale banking customer segments of the Bank.
“President” means the highest-ranking executive officer who is primarily responsible for the day – to- day management affairs of the bank;
“Target Account” means a saving account that allows the customers to set target for a minimum of three months and make deposits towards achieving their target
“The Bank” means the Commercial Bank of Ethiopia.
Agent: Shall mean a person engaged in a commercial/business activity and has been
contracted by the bank to provide the services on its behalf.
Financial Transaction: shall mean an event which involves money or payment, such as deposit money into a bank account, borrow money to customers.
Merchant: shall mean an entity that contract with an acquirer to originate transactions and accepts cards for payment and displaying bank’s and the issuer's logo.
Mobile Money System (MMS): shall mean performing banking activities which primarily
consists of opening and maintaining mobile/regular accounts and accepting deposits;
Furthermore, it includes performing fund transfer or cash in and cash out services using mobile devices.
Personal Identification Number (PIN): shall mean a secret numeric passwor
Financial Service Development in Kenya ppt.pptxetebarkhmichale
MEMORANDUM OF UNDERSTANDING (MoU)
This MEMORANDUM OF UNDERSTANDING (MOU) (hereinafter referred to as the “MoU”) is signed in Addis Ababa on the _____________ of ____ 2023 between:
Commercial Bank of Ethiopia (CBE), a company incorporated in Ethiopia having a Registered License No. BBL/001/63 to engage in commercial banking services with head office at Kirkos sub-city, Gambia Street, /P.O. Box 255, Tel +251115515004, Addis Ababa, Ethiopia (hereinafter referred to as “CBE”) which term or expression shall, unless it is repugnant to the context or meaning thereof, be deemed to mean and include its successor and permitted assigns of the First Part.
And
Ministry of Innovation and Technology Ethiopia (MinT), hereinafter referred to as “MinT”, is an Ethiopian government agency responsible for science and technology development in Ethiopia accountable to the office of the prime minister after duly established as per Article 55 Sub Article 1 of the FDRE Proclamation No. 1097/2019. Tel. +251 11265737; E-mail: contact@mint.gov.et Addis Ababa, Ethiopia, which term or expression shall, unless it is repugnant to the context or meaning thereof, be deemed to mean and include its successor and permitted assigns of the Second Part.
(“CBE” and “MinT” shall hereinafter be referred to as individually as a “Party” and collectively as “Parties”.)
Article 1: Preamble
Whereas, CBE is a government-owned bank in Ethiopia and a pioneer and backbone of the Ethiopian financial industry in its over 80 fruitful years;
Whereas, CBE intends to provide flexible access to lending products through simplified qualifying criteria and innovative credit scoring based on CBE Birr transaction history or account inflows;
Whereas, CBE is ready to partner with the MinT to unlock the financial constraints of underserved and unserved segments of the population, and to leverage the potential of the Ethiopian startup ecosystem and thereby enhance financial inclusion;
Whereas, MinT entrusted the task of nucleating and promoting start-ups for the benefit of the society by providing facilities to innovative entrepreneurs in Ethiopia;
Whereas, the Mint shall support/guide/stimulate/promote entrepreneurial and management development of start-ups by integrating platforms and by policy formulation, planning, implementing, and monitoring of start-up promotions;
Whereas, the Parties recognize the existing partnership and its importance for start-up financing for the good of both parties;
Whereas, the parties believe that the cooperation would serve them to achieve their common objectives and contribute to national development;
Now, Therefore, as duly communicated and agreed by and between the Parties the conditions of this MoU are as follows:
Article 2: Definition of Terms
As used herein, the following terms will have the following meanings set out below:
• Start-up shall mean a newly formed business that aims to grow rapidly by offerin
This is equally important with:
11 Leadership Lessons from" The Leader in you"-Dale Carnegie
1. Talk less, listen more.
People will pay attention to what you say, just because of your position. The leader’s job is to pay attention to what other people say, especially those who think their views don’t count. Show you’re listening by acting on what people tell you, and gain their trust by giving them the credit.
2. Don’t step in with solutions too quickly.
No-one learns anything new if you keep doing what you already know how to do, and don’t allow others to try. Anyway, they may find a different, or better way, and if not… mistakes are valuable too.
3. Be authentic.
Be authentic, passionate, even emotional, about what you believe in. Share your vision and live your values. The personal is more engaging, even inspiring, than the process.
4. Don’t ‘dis’ downwards.
Once a decision is made by the Board, or the leadership team, it’s yours even if you argued against it during discussions. Your job as leader is to get others to believe in, and work towards, a shared goal, not to divide opinion or loyalties.
5. I’m OK: You’re OK.
Start from the position that everyone is doing the best they can, then look for ways to support and encourage them – which is so much more rewarding than finding fault.
6. Don’t be the smartest person in the room.
Being a leader does not mean knowing more than anyone else. Recognise, encourage and promote others as experts. Give them the trust and autonomy to be creative and do excellent work, defined in their terms. You simply provide the direction, so that this excellent work contributes to a shared purpose.
7. Sense of purpose.
Your team know what they do and how to do it, but you can make a big difference by sharing a strong sense of why they’re doing it and where it’s heading. Help them develop a broad understanding of the team’s purpose, and faith in how their role contributes to the whole. (Remember the floor-sweeper at NASA?)
8. Being right isn’t enough.
A great idea is of no consequence unless you can convince others to believe it too, and then persuade them to help you make your idea a reality. The best way to do this is to make the idea theirs.
9. Focus on a few things.
Focusing on the things that really matter and where you can make a difference. There may be a hundred different distractions and demands on your time and a hundred ways you could respond, but it’s the dozen carefully chosen actions that deliver the results.
10. Get out and about.
Get out and about and in the work. It’s hard to retain that sense of what the job’s really about when you are sitting.
so Please read it.
Disruptive vs. Top Down Change in US Payments in 2016Walter Kitchenman
Innovation in Payments is rarely “Disruptive,” but is normally Top Down, driven by public private cooperation, where change is mandated from the top, and entrepreneurs respond to consumer preferences at the margins. In this presentation we show how mobile payments and the Cloud, accompanied by the requirements of likely eCity networks and APPs wlll emerge in 2016 and benefit IT innovators and non-FSIs (non-Financial Service Institutions).
What is Social KYC?
We generate large amounts of data about ourselves online every single day. All of this activity, when analysed as a whole, builds up a very deep and unique digital footprint — something that’s exceedingly difficult for someone to steal or fake convincingly.
Social KYC harnesses this data and uses it to establish a person’s identity — on a consent driven basis, of course. Using algorithms to analyse and corroborate various data attributes across multiple online accounts it is possible to quickly establish the likelihood of a person being:
- real
- who they claim to be (including various demographic data related thereto)
- a legitimate potential user (rather than a fraudster trying to access your platform with malicious intent)
We’re all used to Single Sign On – using an existing social media account to sign up to a new service — and Social KYC is an extension of this. As all you’re doing is asking a user to log in to a variety of their online accounts to prove who they are, it makes for a far more fluid sign up experience which in turn will encourage more users onto your platform.
Webinar: Bitcoin, Blockchain, and the LawLogikcull
Erica G. Wilson, of Vuono & Gray, and Stephen T. Middlebrook, of Womble Carlyle, look at the basics of blockchain and bitcoin technology, the legal issues they raise, and the evolving regulatory landscape.
This presentation explores what future of commerce may look like given the current trends in mobile devices, digital payments, social commerce and security including tokenization and new forms of identity verification
Major impact on the mobile payments industry
Consumers and businesses have been forced to drastically change their purchasing habits
Banking industry works to maintain cash access, while keeping customers safe
The economic and human impact of this pandemic is significant
MasterSnacks Cryptocurrency: Legal Issues in Cryptocurrency and BlockchainCitrin Cooperman
If your business is involved in cryptocurrency or Blockchain, it is in your best interest to understand the legal implications that may come along with transacting in digital assets. In this session, Jeff Neuburger, partner at Proskauer Rose and head of its Blockchain Practice, to covered the following topics and more:
- Categorization of cryptocurrencies as securities and resulting implications
- Types of licenses necessary to be involved in a cryptocurrency business
- Non-fungible tokens and associated legal issues
- Smart contracts
2012 China Financial Industry Trends and OutlookKapronasia
While the rest of the world struggles with a lingering financial crisis, Chinese Financial institutions will continue investing in financial technology innovation in 2012. New technologies such as EMV and mobile near-field payments will drive significant investment as financial institutions continue to modernize and expand both the breadth and depth of their product offerings.
This webinar from Kapronasia will look at some of the key insights from Kapronasia’s “China Financial Technology 2012 – Top 10 Trends Shaping the Industry" report, a comprehensive look at the key issues and challenges and how banks are overcoming them.
Pli workplace privacy in the year 2013 2013-6-13mkeane
Addresses privacy issues associated with hiring in a social media world, privacy issues associated with BYOD programs; employee privacy rights associated with off-duty activity including Facebook postings and activity protected by lifestyle laws.
At the yearly conference, held in Phoenix AZ this year, David Carrithers received the Emeritus Member Chairman’s Award from the Center For Job Order Contracting Excellence for his 16+ years of support to the industry and CJE. Job order contracting is a contracting form for public funded renovation and construction originated with the Department of Defense in the 1980’s.
“It was a great honor to receive this award from the Industry Chair Mike Bevis, CJP and the board of this important industry association it means a great deal to me. Over the years I have meet and worked alongside so many amazing members and leaders at CJE. It is always up lifting to not just work with others in the A/E/C/ Facilities (Architecture/ Engineering/ Construction) industry but grow to call these hardworking people friends.” says Carrithers.
► Engaging Operations and Strategy Executive possessing a winning blend of business expertise, skill in operations management, and practical experience. Experienced in driving revenue growth and brand visibility in challenging markets.
► Leverages a unique mix of strategic and analytical expertise, consistently exceeding performance and revenue goals by aligning the effort of strong teams with organizational objectives.
Targeting Realtors whose clients are foreign nationals purchasing property in the US and moving to the states, at the same time foreign Realtors representing US nationals overseas buying vacation property or retiring overseas.
Transformational Strategies Creating Team, Brand & Market Results!
My passion is in better business growth through better branding, marketing, sales and new development processes. I bring to life transformational strategies, aligned team efforts and create targeted growth. I have mastered building industry alliances, stronger relationships with clients and growing the top line business volume while improving the bottom-line profit margin.
High Definition Impressions (HDI) develops grassroots educational marketing strategies that help healthcare providers and manufacturers expand market share, while promoting patient loyalty and best practices branding. Our well planned and research-based programs are co-created with medical experts for medical experts.
Personal Brand Statement:
As an Army veteran dedicated to lifelong learning, I bring a disciplined, strategic mindset to my pursuits. I am constantly expanding my knowledge to innovate and lead effectively. My journey is driven by a commitment to excellence, and to make a meaningful impact in the world.
3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
Putting the SPARK into Virtual Training.pptxCynthia Clay
This 60-minute webinar, sponsored by Adobe, was delivered for the Training Mag Network. It explored the five elements of SPARK: Storytelling, Purpose, Action, Relationships, and Kudos. Knowing how to tell a well-structured story is key to building long-term memory. Stating a clear purpose that doesn't take away from the discovery learning process is critical. Ensuring that people move from theory to practical application is imperative. Creating strong social learning is the key to commitment and engagement. Validating and affirming participants' comments is the way to create a positive learning environment.
Business Valuation Principles for EntrepreneursBen Wann
This insightful presentation is designed to equip entrepreneurs with the essential knowledge and tools needed to accurately value their businesses. Understanding business valuation is crucial for making informed decisions, whether you're seeking investment, planning to sell, or simply want to gauge your company's worth.
The key differences between the MDR and IVDR in the EUAllensmith572606
In the European Union (EU), two significant regulations have been introduced to enhance the safety and effectiveness of medical devices – the In Vitro Diagnostic Regulation (IVDR) and the Medical Device Regulation (MDR).
https://mavenprofserv.com/comparison-and-highlighting-of-the-key-differences-between-the-mdr-and-ivdr-in-the-eu/
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, you’ll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
Cracking the Workplace Discipline Code Main.pptxWorkforce Group
Cultivating and maintaining discipline within teams is a critical differentiator for successful organisations.
Forward-thinking leaders and business managers understand the impact that discipline has on organisational success. A disciplined workforce operates with clarity, focus, and a shared understanding of expectations, ultimately driving better results, optimising productivity, and facilitating seamless collaboration.
Although discipline is not a one-size-fits-all approach, it can help create a work environment that encourages personal growth and accountability rather than solely relying on punitive measures.
In this deck, you will learn the significance of workplace discipline for organisational success. You’ll also learn
• Four (4) workplace discipline methods you should consider
• The best and most practical approach to implementing workplace discipline.
• Three (3) key tips to maintain a disciplined workplace.
Recruiting in the Digital Age: A Social Media MasterclassLuanWise
In this masterclass, presented at the Global HR Summit on 5th June 2024, Luan Wise explored the essential features of social media platforms that support talent acquisition, including LinkedIn, Facebook, Instagram, X (formerly Twitter) and TikTok.
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
2013 Prepaid and Emerging Electronics Payments In Review jan 15 2015-v1
1. 2013: Prepaid and Emerging
Electronic Payments Year in Review
Judith Rinearson - John ReVeal
Linda Odom
And the Bryan Cave Payments Team:
Margo Strahlberg – Jennifer Crowder
Alan Solarz - Courtney Stolz – Seyi Iwarere
Louise Nutt – Rob Lystad – Karen Neely Louis
January 15, 2014
1
2. Agenda
• Introduction “Themes for 2013” – Judie Rinearson
• Hot Topics
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
The Consumer Protection Flash Mob – Linda Odom
The Payroll and Student Card Drama Scenes – Margo Strahlberg
Target and Similar Data Breaches Fall-Out – Courtney Stolz
The Tax Refund/Government Benefit Fraud Fears – Jennifer Crowder
The Durbin Roller-Coaster – Judie Rinearson
The FinCEN AML Reinvention - Seyi Iwarere
The Mobile Wallet Tower of Babel – Dan Wheeler
The Virtual Currency Hysteria – Louise Nutt and Alan Solarz
The Short-Term Credit/Overdraft Siege - Rob Lystad
The Money Transmitter Licensing Blitz – Karen Neely Louis
Federal Banking Regulatory Angst– John ReVeal
International Regulatory Conundrum - Judie Rinearson
2
4. Q: Why Flash Mob?
• Federal Regulators: CFPB pending regulations; FTC
Guidance
• Federal Legislators: Sen. Menendez proposed
legislation (and now Sen. Warner)
• State Regulators: Connecticut, Illinois
• Consumer Groups: Pew Charitable Trust; Center for
American Progress, National Consumer Law Center
• Media: NY Times, USA Today
4
5. What is likely to happen?
• Pending federal legislation may impact on CFPB
• CFPB Regs now due in May
• Expected measures - –
–
–
–
–
FDIC insurance
Regulation E protections (payroll card version)
Specific Fee disclosure requirements
Some fee prohibitions (balance inquiries; decline fees)
Credit access limitations
5
6. Other top CFPB News for 2013
•
•
•
•
Cordray confirmed
Remittance rules take effect
Enforcement attorneys no longer participate in exams
CFPB is criticized for collecting personal consumer
data – and argues that it does not monitor accounts
• Ongoing Republican efforts to change CFPB’s
structure, impose financial oversight – not successful
• Guidance issued for “self-policing” and “self-reporting
of consumer protection violations
6
8. Q: Why Drama Scenes?
Payroll
– Litigation led to front page NY Times Story
• Mandatory Cards
• Fees so high that employee gets less than minimum wage
–
–
–
–
–
16 Senators Send letters to Dept of Labor and CFPB
NY Attorney General Send Info Requests to 20 Employers
CFPB issues guidance confirming law - - no mandatory cards
Class Action in California
Payroll card legislation passed - CT, MI, OR
8
9. Student Cards
• Following on from 2012 Higher One and US PIRG report,
CFPB investigates University and College financial
products offered to students
• Democratic House and Senate Leaders send letters to 8
major banks seeking information on student card
programs
• CFPB calls on financial institutions to “voluntarily” disclose
to the public its financial product marketing agreements
made with colleges and universities
• CFPB holds public forum on student financial products
9
10. What is likely to happen?
• Speculation is that new CFPB GPR regulations will
include specific provisions on Payroll and Student
Cards
• Menendez legislation has new language requiring
that employees receive a choice in form of payment,
including check or direct deposit
• Expect more state activity
10
11. Target and Similar Data Breaches
“Fall-Out”
Courtney Stolz
Washington DC
11
12. Q: Why Fall-Out?
•
•
•
•
Sen. Blumenthal called for the FTC to investigate
Sen. Schumer urged CFPB to investigate.
Sen. Leahy reintroduced data security legislation.
Sen. Menendez asked the FTC to recommend further
legislative action to ensure consumers are protected.
• Media calls for EMV - - USA Today – 1/10/14:
– Data breaches like the one at Target that exposed information for
up to 110 million customers would be pointless for criminals if U.S.
banks switched to the secure [EMV] …
• Senators call for hearings about EMV adoption
– Banks are under no mandate to issue EMV cards but are likely to
issue EMV-compliant cards widely by 2015 to be ready for the
fraud liability shift in October 2015.
12
13. What is likely to happen?
• Calls for earlier adoption of EMV
– Could impact on Durbin Reg II Routing requirements
– Major payment networks and banks oppose
– Recent poll of merchants indicates that merchants would
prefer to invest in mobile phone POS and not anti-fraud
systems
• Potential federal legislation to protect consumers
• Potential new wave of state breach notification laws
• Class Actions and litigation
13
14. The Tax Refunds and
Government Benefits
“Fraud Fears ”
Jennifer Crowder
Kansas City
14
15. Q: Why Fraud Fears?
Tax Fraud
• Sen. Nelson introduces the Identity Theft and Tax
Fraud Prevention Act of 2013 – distinguishes between
“at risk” and “verified” accounts – limits number of
refunds to the same account.
• IRS Crackdown on “Refund Fraud & ID Theft”; IRS
warnings on pervasive telephone scam
• Congressional hearings on IRS Tax fraud
• FinCEN issues Tax Fraud Advisory
15
16. Other fraud-related items
• Massive global cyber fraud hits Omani Bank - $42
million withdrawn
• Congressional Hearings on Jamaican Lottery Scam
• FTC issues warning bulleting on utility bill scam
• Internet Crime Complaint Center (IC3) issues warning
on gift card tampering
• Three states pass laws restricting usage of
government benefit/EBT cards at liquor stores, race
tracks, and other inappropriate locations
16
17. What is likely to happen?
• Increased pressure to monitor transactions
• Increased pressure for more internal controls at
government agencies such as IRS
• Banks scrutinize their prepaid tax refund programs
• Concerns that regulators might limit or restrict which cards
can accept government payments
• Potential new regulations on warning notices to
consumers
• Potential push for EMV as a fraud deterrent
17
18. Durbin and Reg II
“Roller-Coaster”
Judith Rinearson
NYC
18
19. Q: Why Roller Coaster?
•
•
•
•
•
•
•
•
•
•
Dodd Frank Act – Passed in May 2010
Proposed Regulations Issued December 16, 2010
Final Regulations issued June 29, 2011
Exclusivity for Payment Networks - October 1, 2011
Routing and Exclusivity generally for issuers - April 1, 2012
Routing and Exclusivity for HSA / FSA / HRA cards (those
using transaction substantiation systems) – April 1, 2013
Effective Date for general use prepaid April 1, 2013
Revised FAQs issued March 13, 2013; May 2013
NACS Litigation decision issued July 31, 2013
NACS appeal pending – oral arguments Friday Jan 17th
19
20. What is likely to happen?
• If Judge Leon’s NACS decision is upheld….
– Business as usual until new regulations are proposed and finalized;
expedited regulatory process likely, with comment period
– Interchange rates likely to be lowered
– Multiple routing options will likely create operational nightmares
– No changes anticipated in the exemptions for small banks and for
certain GPR cards
• Potential increase in GPR usage
• If NACS is not upheld….
– Most likely back to business as usual
– Industry still grappling with PIN issuance at point of sale or prior to card
issuance or usage
Of course other option is that Judge Leon’s decision could be upheld in part and reversed in part….
20
22. Q: Why Reinvention?
• New Director Jennifer Shasky Calvery – former DOJ
prosecutor – institutes changes - meets with industry
• Cross-border regulations that would designate prepaid as
“monetary instruments” – has been a OMB for months and
is now apparently being reconsidered.
• 314(b) Guidance responsive to requests from MSBs for
clarification on ability to participate in the 314(b) information
sharing process under a safe harbor
• Issues Guidance that secondary market for closed loop
cards does not change the intrinsic status of the card
• Takes on virtual currencies with new guidance on
exchanges and administrators in March 2013
22
23. What is likely to happen?
• Likely there WILL BE some cross-border regulations
requiring certain prepaid cards to be declared.
– Perhaps only anonymous cards. Hard to say.
• Increased focus on ID verification – when needed;
looking for 21st century solutions.
• Expect some high-profile law enforcement proceedings
• Increased interest in off-shore products, banks, and
issuers.
• Increased interest in mobile payments and virtual
currencies
23
25. Q: Why Tower of Babel?
• NFC and Contactless payments
– ISIS - A mobile payments venture owned by AT&T, Verizon Wireless
and T-Mobile USA – partners with American Express – studies
suggest 50% of smart phones to be NFC enabled. NFC is being
used by Android, Samsung, BlackBerry and Windows Phone
operating systems
• Apple has rejected NFC:
– Apple uses iBeacon; Touch ID; Rumors say iPhone6 may have NFC
• Paypal also uses iBeacon – Bluetooth wifi communicates
with a “beacon” installed at retailers locations
• MCX – Retailers’ Network: cloud-based-relies on bar codes
• Square Wallet – Combines GPS and Photo ID
25
26. What is likely to happen?
Hard to Predict - - Not a legal issue….
• Possible that new laws or regulations or more major data
security breaches will lead to EMV (chip and pin)
technology in order to reduce fraud
• Nevertheless, consumers and merchants seem to both
want the convenience and innovations brought through the
use of mobile wallets/apps
• What Apple decides will impact industry
• One suggestion: EMV can be compatible within NFC
mobile devices – through the use of “EMV contactless” - If
the payments industry will be upgrading for EMV, why not
do both?
26
28. Q: Why Hysteria?
• March 18, 2013 – FinCEN Guidance
– Exchangers and Administrators must register as “money transmitters”
• Senate Hearings on “Potential Risks, Threats and Promises”
of Virtual Currencies -November 2013
• Bitcoin value exceeds $1200 in November; New York Times
publishes 17 articles on Bitcoin and other virtual currencies
between in less than 3 weeks.
• California DFI issues a cease and desist order against the
Bitcoin Foundation. Questions of state licensing arise.
• Law enforcement: : TX Ponzi scheme; Liberty Reserve; Silk
Road; Mt.Gox.
28
29. Current Status
• FinCEN Rules
– “User” - A user is a person that obtains virtual currency to
purchase goods or services.
– “Exchanger” - An exchanger is a person engaged as a
business in the exchange of virtual currency for real currency,
funds, or other virtual currency.
– “Administrator” - An administrator is a person engaged as a
business in issuing (putting into circulation) a virtual currency,
and who has the authority to redeem (to withdraw from
circulation) such virtual currency.
• NY DFS issues subpoenas; hearings on “BitLicenses”
scheduled for January 28-29th.
• At least one state issues license; most are waiting…
29
30. What is likely to happen?
• Tax issues – IRS is studying. Is it a “currency”? A “capital
asset”? A commodity?
• Global acceptance – Thailand prohibits; China bans; UK’s
FSA considering regulatory position
• Overstock.com - - as merchant acceptance grows, usage
will grow, call for regulation will grow
• Possible outcomes:
– Optimists: “Internet” for money; changes the entire payments
infrastructure; becomes ubiquitous
– The middle road: Acceptance and growth through a network of
“compliant” licensed exchanges around the globe.
– Pessimists: The bubble bursts; globally outlawed.
30
32. Q: Why Siege?
• March 2013 Federal legislation introduced in March 2013 to regulate
banks' overdraft protection plans
• Spring 2013: Fed and OCC “crackdown” on payday lending; CFPB
white paper highly critical of payday and deposit advance loans
• August 2013: NYDFI Targets Online Payday Lenders; Pressures from
Federal Regulators Increase regarding Banks that Process their
Transactions
• October 2013: Consumer groups urge federal agencies to take “further
strong action to protect consumers and the integrity of the payment
system by stopping [banks] and payment processors” from facilitating
electronic payments on behalf of Internet and tribal payday lenders
• November 2013: OCC and FDIC jointly issued final guidance on deposit
advance products
• November 2013: CFPB begins accepting payday lending complaints
32
33. What is likely to happen?
• Banks will be very hesitant to offer short-term, small
dollar loans
• Banks will be strongly discouraged from issuing prepaid
cards with lending lines or overdraft features
• It is possible that CFPB regs will prohibit prepaid cards
from offering credit features, even on a opt-in basis with
full disclosures.
• Credit will be harder to get, and more consumers with
poor credit history may be forced to go to unregulated
sources
33
35. Q: Why Blitz?
• Florida: Square Fined $507,000 for operating without a
money transmitter license from February 2010 until Nov. 13,
2012, when it applied for a license
• Illinois: Issued cease and desist orders from January 2013
against six entities for alleged unlicensed activities,
including NetSpend, Square, TouchPay and Skrill
• Wave of new laws: 23 new state money transmitter
licensing laws passed in 2013, from 19 different states.
• Non-Uniform and Inconsistent: State laws are not
uniform, and are interpreted disparately. But under 18 USC
1960 it is a federal crime to conduct an unlicensed money
transmitter business.
35
36. What is likely to happen?
• More state licensing laws applicable to both traditional
and emerging payments.
• More enforcement actions and cease & desist orders.
• More licensed money transmitters partnering with
payments businesses to sponsor licensed payment
services
• There have been calls for a national federal licensing
law to supplant the patchwork quilt of state laws.
36
38. Q: Why Angst?
• OCC/Fed Guidance on Managing Outsource Risks: Seen
as a warning to the banking that third-party relationship
management to be a significant focus in coming examinations.
• FFIEC Guidance on Social Media Risks: Banks must adopt
a risk management program to help identify, measure, monitor
and control the risks related to social media.
• FDIC Guidance on Customers that Engage in Higher-Risk
Activities: Banks providing payment processing services
directly or indirectly to merchants engaged in “higher-risk”
activities must perform appropriate due diligence to ensure
that the merchants operate in accordance with applicable law.
38
39. What is likely to happen?
• Heightened focus on a bank’s relationships with program
managers and other third-party service providers
• Third party service providers can expect their bank
partners to increase demands and expectations
• Banks (especially small banks) may feel pressured by their
regulators to terminate prepaid and emerging payment
programs.
39
41. Q: Why Conundrum?
•
•
•
•
•
•
•
Canada : New regulations covering “prepaid payment products”
China: The central bank of the China for the first time issued third party
payment licenses to foreign payment companies.
Hong Kong: Proposed a new regulatory framework for device and non-device
stored value products.
EU: Revised Payment Services Directive intended to enhance transparency,
innovation and security in the field of retail payments. The EC also
recommended capping debit and prepaid card interchange fees to 0.2 percent,
and capping credit card interchange at 0.3%.
France Adopts Second E-Money Directive. The French Parliament recently
adopted the Second European Directive on Electronic Money
U.K banks: . Reported to no longer willing to offer banking services to a
electronic money and payment companies, including money services
businesses, merchant acquirers, and prepaid card issuers.
FATF: Issues Guidance for a Risk-Based Approach to Prepaid Cards, Mobile
Payments and Internet-Based Payment Services
41
42. What is likely to happen?
•
Similar forces impact international laws:
– Major data security breaches and fraud losses
– Consumer and consumer group complaints about high fees, unfair
terms, misleading advertising
• Competitive pressures as well are evident in global payment
developments
– Central banks and well entrenched financial services companies
protecting their turf
– Dominant mobile carriers and phone manufacturers can set the rules
for others.
• Laws will seek for more transparency, lower fees, and
(hopefully) risk-based AML controls
42