WEBVTT

NOTE
This file was generated by Descript 

00:00:00.470 --> 00:00:02.420
Samantha: Hello, this is Samantha Shares.

00:00:02.870 --> 00:00:04.130
This episode covers

00:00:04.920 --> 00:00:09.990
Fighting Payments Fraud: A Deep Dive into
Federal Banking Agencies' New Initiative

00:00:10.691 --> 00:00:13.741
The following is an audio
version summary of that document.

00:00:14.301 --> 00:00:17.501
This podcast is educational
and is not legal advice.

00:00:17.971 --> 00:00:21.931
We are sponsored by Credit Union
Exam Solutions Incorporated, whose

00:00:21.931 --> 00:00:25.041
team has over two hundred and
Forty years of National Credit

00:00:25.041 --> 00:00:26.871
Union  Administration experience.

00:00:27.441 --> 00:00:31.091
We assist our clients with N C
U A so they save time and money.

00:00:31.481 --> 00:00:35.511
If you are worried about a recent,
upcoming or in process N C U A

00:00:35.511 --> 00:00:39.831
examination, reach out to learn how they
can assist at Mark Treichel DOT COM.

00:00:40.351 --> 00:00:44.691
Also check out our other podcast called
With Flying Colors where we provide tips

00:00:44.721 --> 00:00:47.271
on how to achieve success with N C U A.

00:00:48.002 --> 00:00:51.642
And now summary of the request for
comment on fighting payments fraud.

00:00:52.482 --> 00:00:57.602
Fighting Payments Fraud: A Deep Dive into
Federal Banking Agencies' New Initiative

00:00:58.294 --> 00:01:01.864
today we're diving into a significant
new initiative from three major

00:01:01.864 --> 00:01:05.814
federal banking agencies to combat
the growing threat of payments fraud.

00:01:06.636 --> 00:01:11.146
On June 20th, 2025, the Office of
the Comptroller of the Currency, the

00:01:11.146 --> 00:01:15.526
Federal Reserve System, and the Federal
Deposit Insurance Corporation jointly

00:01:15.526 --> 00:01:19.476
issued a Request for Information
seeking public input on how to better

00:01:19.476 --> 00:01:21.406
address payments fraud across the U.S.

00:01:21.406 --> 00:01:22.376
financial system.

00:01:23.139 --> 00:01:24.139
The Growing Problem

00:01:24.844 --> 00:01:26.544
Let's start with the scope of the problem.

00:01:27.214 --> 00:01:30.774
According to the agencies, payments
fraud is inflicting significant

00:01:30.774 --> 00:01:34.454
harm on consumers, businesses,
and financial institutions.

00:01:35.154 --> 00:01:39.394
They define payments fraud as quote
"the use of illegal means, including

00:01:39.394 --> 00:01:44.284
intentional deception, misrepresentation,
or manipulation, to make or receive

00:01:44.284 --> 00:01:45.764
payments for personal gain."

00:01:46.580 --> 00:01:47.880
The numbers are staggering.

00:01:48.480 --> 00:01:51.870
Data from the Federal Trade Commission
shows that losses reported for

00:01:51.870 --> 00:01:57.340
non-card payments fraud increased
271 percent between 2020 and 2024.

00:01:57.990 --> 00:02:01.680
Meanwhile, data from the Treasury's
Financial Crimes Enforcement Network

00:02:01.940 --> 00:02:05.510
shows that Suspicious Activity
Reports filed related to check,

00:02:05.710 --> 00:02:11.380
ACH, and wire fraud have increased
489 percent between 2014 and 2024.

00:02:12.201 --> 00:02:14.331
Check fraud is particularly concerning.

00:02:14.971 --> 00:02:18.501
The Treasury Department reports that
check fraud in the United States has

00:02:18.501 --> 00:02:24.371
risen 385 percent since the COVID-19
pandemic, and FinCEN reports that check

00:02:24.371 --> 00:02:28.321
fraud accounted for approximately 30
percent of fraud-related Suspicious

00:02:28.321 --> 00:02:30.851
Activity Reports filed in 2023.

00:02:31.666 --> 00:02:32.656
Why This Matters

00:02:33.321 --> 00:02:37.501
The agencies emphasize that payments
fraud quote "has the potential to

00:02:37.501 --> 00:02:41.571
erode public trust inâand undermine
the safety, accessibility, and

00:02:41.571 --> 00:02:45.041
efficiency ofâthe nation's payments
system, upon which the U.S.

00:02:45.041 --> 00:02:46.611
financial system depends."

00:02:47.418 --> 00:02:52.038
What makes this particularly challenging
is that, as the agencies note, quote "a

00:02:52.038 --> 00:02:56.968
payments fraud scheme may involve multiple
institutions and payment methods, each

00:02:56.968 --> 00:03:00.648
of which may fall within the remit of
different Federal and State agencies."

00:03:01.468 --> 00:03:05.418
They acknowledge that quote "no
agency or private-sector entity can

00:03:05.418 --> 00:03:07.308
address payments fraud on its own."

00:03:08.165 --> 00:03:09.935
Five Key Areas for Action

00:03:10.681 --> 00:03:15.071
The Request for Information focuses on
five potential areas for improvement:

00:03:15.882 --> 00:03:16.222
1.

00:03:16.802 --> 00:03:20.752
External Collaboration The agencies
are asking: What actions could

00:03:20.752 --> 00:03:24.362
increase collaboration among
stakeholders to address payments fraud?

00:03:25.102 --> 00:03:28.182
They're particularly interested in
standard setting and identifying

00:03:28.182 --> 00:03:31.602
organizations outside the payments
and banking industry that might

00:03:31.602 --> 00:03:33.162
provide additional insights.

00:03:33.897 --> 00:03:34.207
2.

00:03:34.767 --> 00:03:38.867
Consumer, Business, and Industry
Education While financial education

00:03:38.867 --> 00:03:43.037
resources exist, the agencies
recognize there may be a need for more

00:03:43.037 --> 00:03:45.157
specific payments fraud education.

00:03:45.817 --> 00:03:49.077
They're asking what types of
education are most effective and how

00:03:49.077 --> 00:03:51.097
to make existing resources better.

00:03:51.862 --> 00:03:52.192
3.

00:03:52.712 --> 00:03:57.202
Regulation and Supervision The agencies
want input on potential regulatory

00:03:57.202 --> 00:04:01.492
changes and whether existing supervisory
guidance is sufficient and clear.

00:04:02.242 --> 00:04:05.962
They're particularly interested in how
to help small community banks detect,

00:04:06.072 --> 00:04:08.142
prevent, and mitigate payments fraud.

00:04:09.009 --> 00:04:09.399
4.

00:04:09.989 --> 00:04:13.919
Payments Fraud Data Collection and
Information Sharing Currently, payments

00:04:13.919 --> 00:04:18.339
fraud data is, quote "collected in
an incomplete, non-standardized,

00:04:18.499 --> 00:04:20.279
ad hoc, and fragmented way."

00:04:21.169 --> 00:04:25.269
The agencies are exploring ways to
improve data collection and sharing while

00:04:25.269 --> 00:04:27.569
addressing privacy and legal concerns.

00:04:28.402 --> 00:04:28.762
5.

00:04:29.442 --> 00:04:33.282
Reserve Banks' Operator Tools and
Services The Federal Reserve Banks

00:04:33.362 --> 00:04:37.782
already provide risk management tools,
but they believe quote "there may be

00:04:37.782 --> 00:04:41.932
further opportunities for the Reserve
Banks, as a payments system operator,

00:04:42.212 --> 00:04:46.192
to provide additional tools and services
designed to reduce payments fraud."

00:04:47.027 --> 00:04:48.977
Specific Focus on Check Fraud

00:04:49.802 --> 00:04:53.202
Given the particular problem with
check fraud, the Federal Reserve

00:04:53.202 --> 00:04:56.942
is specifically seeking input on
potential amendments to Regulation

00:04:56.942 --> 00:04:59.482
CC, which governs funds availability.

00:04:59.912 --> 00:05:02.752
They're asking whether technological
advancements have reduced the

00:05:02.752 --> 00:05:06.332
time it takes to detect fraud
such that funds availability

00:05:06.332 --> 00:05:07.852
requirements should be shortened.

00:05:08.572 --> 00:05:12.382
The Fed notes that checks contain
sensitive information including quote

00:05:12.742 --> 00:05:17.102
"the payor's name, account number, routing
number, address, and signatureâthat

00:05:17.102 --> 00:05:20.612
can be used by criminals to conduct
other forms of payments fraud."

00:05:21.502 --> 00:05:22.722
Looking for Solutions

00:05:23.371 --> 00:05:27.401
The agencies are asking some practical
questions that affect everyday banking:

00:05:28.136 --> 00:05:31.936
â¢	Should Reserve Banks require fraud
reporting for all payment rails?

00:05:32.583 --> 00:05:36.363
â¢	Would confirmation of payee services
help mitigate fraudulent payments?

00:05:37.006 --> 00:05:40.176
â¢	How can financial institutions
better resolve disputes about

00:05:40.176 --> 00:05:41.816
allegedly fraudulent checks?

00:05:42.428 --> 00:05:46.148
â¢	What technological solutions have been
most effective in preventing fraud?

00:05:46.803 --> 00:05:47.833
Industry Impact

00:05:48.510 --> 00:05:51.890
The document reveals that the
agencies have quote "received

00:05:51.890 --> 00:05:55.310
complaints from supervised
institutions regarding challenges in

00:05:55.310 --> 00:05:59.180
resolving disputes about liability
for allegedly fraudulent checks."

00:05:59.920 --> 00:06:02.910
This suggests the problem is
significant enough that banks are

00:06:02.960 --> 00:06:05.280
actively seeking regulatory guidance.

00:06:05.893 --> 00:06:06.643
Next Steps

00:06:07.322 --> 00:06:12.022
Comments on this Request for Information
are due by September 18, 2025.

00:06:12.752 --> 00:06:16.982
The agencies are particularly interested
in hearing from a variety of stakeholders

00:06:17.042 --> 00:06:22.082
including consumers, businesses, financial
institutions, and technology providers.

00:06:22.811 --> 00:06:27.051
As one of the questions in the
RFI asks: quote "What measures,

00:06:27.131 --> 00:06:31.291
including technological solutions or
services, have been most effective in

00:06:31.291 --> 00:06:35.611
identifying, preventing, and mitigating
payments fraud at your institution?"

00:06:36.373 --> 00:06:37.073
Conclusion

00:06:37.748 --> 00:06:41.298
This comprehensive Request for
Information represents a significant

00:06:41.298 --> 00:06:45.338
coordinated effort by federal banking
regulators to tackle payments fraud.

00:06:45.898 --> 00:06:49.718
With fraud losses in the billions
and growing rapidly, the agencies are

00:06:49.718 --> 00:06:53.748
clearly taking a proactive approach
to protect consumers and maintain

00:06:53.748 --> 00:06:55.458
confidence in the payments system.

00:06:56.196 --> 00:06:59.786
The 26 detailed questions they've
posed show they're serious about

00:06:59.786 --> 00:07:03.316
getting input from all corners of
the financial services industry.

00:07:03.826 --> 00:07:07.656
Whether you're a bank, a fintech
company, a consumer advocate, or just

00:07:07.656 --> 00:07:11.676
someone who's been affected by payments
fraud, your input could help shape the

00:07:11.676 --> 00:07:13.846
future of fraud prevention in America.

00:07:14.598 --> 00:07:18.688
That's all for today's deep dive into
the federal response to payments fraud.

00:07:19.278 --> 00:07:20.708
Thanks for listening

00:07:21.509 --> 00:07:34.039
________________________________________ This podcast script is based on
the Federal Register document

00:07:34.039 --> 00:07:55.089
dated June 20, 2025, Volume 90,
Number 117, pages 26293-26298.

00:07:55.848 --> 00:07:57.278
This concludes our summary.

00:07:57.949 --> 00:08:02.089
If your Credit union could use assistance
with your exam, reach out to Mark Treichel

00:08:02.089 --> 00:08:04.839
on LinkedIn, or at mark Treichel dot com.

00:08:05.419 --> 00:08:08.029
This is Samantha Shares and
we Thank you for listening.