As I discussed in a previous blog, consumers have not been extensively educated on the impact that PSD2 will have on them. Many of the outcomes of PSD2 will be positive – the Account Information Service Providers (AISPs) and Payment Initiation Service Providers (PISPs) will give people access to a range of new services that will help them to manage their money better and give them more flexibility in the payment providers they use. However, the fraud prevention measures that form an integral part of PSD2 will have a knock-on effect for consumers. In some instances, security checks will make initiating a payment more difficult and irritating. Sometimes the checks may even stop it. Poor Customer Management will Impact the Bottom Line We already know that introducing friction into customer transactions is viewed negatively. Many organisations consider losses to abandoned transactions as important or more important as losses to fraud. PSD2... [Read More]
Worried about increasing levels of fraud, particularly in remote payments, the regulators have made fraud prevention a cornerstone of PSD2. The regulated use of Strong Customer Authentication (SCA) by payment service providers (PSPs) to secure payments is laid out in the Regulatory Technical Standards for PSD2. However, the use of SCA to secure every payment over €30 could cause problems for PSPs. It could impact the level of customer service they can offer by forcing them to add friction to the consumers’ payment process, forcing consumers to re-authenticate themselves using multiple factors at the point of payment. There is a difficult balancing act between fraud reduction and customer experience. PSPs will be allowed to manage this balance by securing payments using transaction risk analysis (TRA) – as long as they can keep their fraud rates low enough (see the transaction value table from the regulatory technical standard, below). TRA is... [Read More]
There’s a clear pecking order when it comes to the IFRS 9 accounting standard that goes into effect in January. It’s an accounting standard, not a piece of banking regulation, so the hierarchy is Finance, Risk and then Collections. This makes sense, but for debt managers it will cause problems. It’s likely that many debt managers will be blind next year on how they can influence impairments. Here’s how things will happen. Your Finance team will talk to your organization’s accounting firm and auditors, and they will agree how IFRS 9 should be implemented. They will probably work your Risk department when it comes to preparing the predictive models that are required to determine expected loss under IFRS 9. Once that’s done, the rules for your organization will be binding. It’s unlikely that the Collections team will be part of the process. And if you’re in Collections, you might think... [Read More]
Whenever there’s a major change in standards looming, companies subject to it understandably go into heads-down mode, focusing on what they need to do to become compliant. Often, there’s an enormous challenge just getting to the start line—the point where the change is required standard practice. For help with reaching the starting line for CECL, the new current expected credit loss impairment model in the US, check out FICO’s just-published CECL Hot Topics Q&A. My colleague Lynda Woodward and I answer questions such as: What is the biggest difference in the change from incurred loss to expected loss? What if we don’t have sufficient data to estimate lifetime losses? There’s a lot of talk about increased volatility in allowance estimates under both CECL and IFRS 9. What are the main causes? Are there some hidden implications of CECL for customer experience and relationship building that I should be considering early... [Read More]
Arguably, there are more financial institutions located in the New York metropolitan area than anywhere else on the planet, so it was only fitting for a conference on AI, Technology Innovation & Compliance to be held in NYC – at the storied Princeton Club, no less. A few weeks ago I had the pleasure of speaking at this one-day conference, and found the attendees’ receptivity to artificial intelligence (AI), and creativity in applying it, to be inspiring and energizing. Here’s what I learned. CCOs Want AI Choices As you might expect, the Chief Compliance Officers (CCOs) attending the AI conference were extremely interested in applying artificial intelligence to their business, whether in the form of machine learning models, natural language processing or robotic process automation – or all three. These CCOs already had a good understanding of AI in the context of compliance, knowing that: Working the sets of rules... [Read More]
PSD2 is on its way but in many respects it feels like it will never happen. So much is still undefined; it’s not yet transposed into national law, the complete Regulatory Technical Standards are not issued and much is still open to interpretation. Given this uncertainty, it is not unreasonable to take a wait and see attitude to preparation – after all it’s likely to be more than a year before you will be expected to apply PSD2 to your payment operations. A laissez faire attitude to preparing your fraud operations for PSD2 may however be a bad move. NOW is the right time to get ready. Read our executive brief Getting Your Fraud Operations Ready for PSD2 so that you can understand the three reasons why you should act now: You will want to secure payments with Transaction Risk Analysis – but that will bring fraud challenges. You will... [Read More]
Debt collectors, like everyone else in financial services, are drowning in regulatory changes. In my last posts I’ve discussed IFRS 9, GDPR and, to a lesser extent, the basket of fun known as PSD2. One of the natural human responses to change is to narrow one’s focus to the necessary task at hand and push everything else away. Just focus on ticking the boxes, and ignore the cries to rethink the way we’re doing business. Sweat what we’ve got and don’t spend any money. That’s what I’m hearing at many collection shops when the conversation turns to optimization or advanced analytics. There’s a cost to this approach, though. Collectors are in danger of leaving money — a lot of money — on the table. The IFRS 9 Bucket Challenge Here’s the first reason: Impairment provisions and losses. This is what I have dubbed the IFRS 9 Bucket Challenge. I wrote... [Read More]
Several top global banks have made it into the press again — for the wrong reasons, reasons to do with international money laundering schemes. From facilitating trading with companies in sanctioned countries, to moving cash for Russian launderers to channeling Mexican drug money, these banks were caught and assessed steep fines by regulators. Even worse is the reputational damage that comes from not . These banks probably thought they were taking the “risk-based approach” that is at the center of most anti-money laundering (AML) regulations and know your customer (KYC) appraoches. But were they doing enough? Did they truly know the customer, their business and the relationship? Did they understand who stood behind the customer – where the funds were coming from? Over the past years, regulatory pressure on banks has increased and resulted in more sophisticated risk-based approaches that require banks to consider much more information on the customer... [Read More]
As a result of several recent policy developments, talk of achieving meaningful US financial regulatory reform is getting louder. The passage in the House of the Republican-backed Financial CHOICE Act of 2017 (Choice Act), the ongoing federal agency activity in response to a number of regulatory reform-related Executive Orders by President Trump, and the positive results from the Fed’s annual supervisory stress tests of large banks are examples of efforts that appear to be moving the reform movement forward. Yet formidable political obstacles remain, leading many to ask: What is achievable and what path will regulatory reform follow? Here is my take. A Legislative Solution Is Not on the Horizon … at Least Not Any Time Soon In June, the House adopted, along a party line vote, the Choice Act, which aims to make broad changes to the 2010 Dodd-Frank statute. While Democrats and Republicans have both discussed their willingness... [Read More]
Rather like Brexit, the Second Payment Services Directive (PSD2) is coming and whether you like it or not, it will bring important and sustained changes. In the case of PSD2 those changes will disrupt the way that payments work all around Europe. So, what will the changes be? While much is uncertain, we can highlight some impacts which are almost guaranteed. In particular, those at the rock face of PSD2 agree on Strong Customer Authentication (SCA): Do whatever you can to avoid it. There are good reasons for PSD2 uncertainty. Key parts of the directive aren’t fully documented. More importantly, because the programme has been designed to be open to interpretation, to be flexible, even when it is written down, there is a lot of space for interpretation. And there are plenty of people who want to fill the gaps in to suit their own ambitions. Who will emerge as... [Read More]
