Fraud, Trust and Real Time

To “defeat” MVP and Amex, in consumer trust, is a very hard undertaking. You not only need to solve a problem they don’t solve, you must also surpass the investments made by every participant in their network(s) with a BETTER economic model.  Good luck with that. 

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Equifax, Facebook and Dangers of Centralization [of Data]

Equifax. It’s hard to sit on sit my hands and not write on this one. My perspective is shaped through running 2 of the largest online banks in the world, developing state of the art fraud prevention systems with the top 20 banks, working with Google and today creating Commerce Signals.

Enron has new competition for the company name that denotes loss and fraud. Equifax may be the single largest breach of consumer information in history…. It is everything from social to DOBs, DL #s, …. How did Equifax get our data?

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PIN Debit at the POS

Most of you have read that Walmart, Home Depot and Kroger have launched new litigation against Visa for “PIN” and Debit.  This issue is so complex it makes my head spin… For those unfamiliar with some of the basics see this article, my prior blog on PIN debit consolidation,  AT Kearney, Digital Transactions: PIN Debit Claw Back and Pinless PIN Debit.

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Perfect Authentication… A Nightmare?

This question is very similar to the story above on EMV. The engineer in me recoils at the thought that a sophisticated technology (which decreases risk), would not be welcomed within a market. To understand WHY, you must answer the question: WHO benefits from the risk reduction? If your business is risk management, and someone takes risk away, what is your business?

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Authentication – A Core Battle for Monetizing Mobile

Those of you with more than 15 yrs in the industry will remember dedicated T1 lines that moved data in secure pipes from one location to another. We now have VPNs, transaction signing and encryption that allows for use of generic pipes between COMPANIES. Authentication at a USER LEVEL will now permit yet a finer grained LEVEL of Secure Services and Data ACROSS companies. Today we have Cloud services from Apple, Amazon, Google but how do you navigate amongst them? How can a Start Up develop services that SPAN them? Authentication and is Key…. And MNOs may be best placed to deliver this service.

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MasterCard follows Visa’s lead on EMV Push

Yesterday MA followed lead and announced plans to support US rollout of EMV. Many of you are probably wondering what this all means in light of mandates and deadlines. The politics and business drivers behind this push are quite complex, but the most important to note that neither large US issuers or retailers are enthused about this push as there is no business case for the change on either side.

31 January 2012

http://www.mastercard.us/mchip-emv.html

Yesterday MA followed lead and announced plans to support US rollout of EMV. Many of you are probably wondering what this all means in light of mandates and deadlines. The politics and business drivers behind this push are quite complex, but it is important to note that neither large US issuers nor retailers are enthused about this push for one primary reason: there is no business case for the change (on either side). Historically, networks do not change without sound financial incentives ( or there is some sort of regulatory mandate).

A Bank makes money by managing risk. Within the payments space large banks have invested billions of dollars in custom fraud infrastructure. The effect (if not the goal) of bank investment in custom fraud infrastructure is to push fraud into the weakest link (or bank) in the network. Smaller banks must seek partners like FIS, FirstData and the Networks to help them keep up. The EMV standard is used by card issuers in just about every market globally, except the US. EMV is effective in addressing certain kinds of fraud such as counterfeit and skimming. Within an EMV environment, international issuers and acquires thus could relax in maintaining related fraud controls IF cards existing in an EMV only environment.  However international travelers to the US and US travelers abroad lead to fraud “leakage”. US issuers did not suffer, due to their fraud infrastructure, but the other banks have.

Thus the “true” benefits of EMV cannot occur until there is 100% adoption at POS (10M in US), complete elimination of the mag stripe in the plastic that we all carry (approximately 1.5 billion in US). This is the conundrum facing any new technology here:  New Plastic must completely replace the old. In other words there is no “Incremental” fraud savings to an incremental rollout, nor is there a business case for either issuer or retailer to implement. Take this on top of the fact the EMV is 20 year old technology and we have a very challenging environment.

What are the benefits in retail? Both Visa and MA have established a carrot and stick approach. Given only the issuer can reduce interchange, the carrot is reduced PCI compliance costs and some terminal subsidy. The stick is a liability shift for to the merchant  if a consumer presents an EMV capable card and the merchant terminal does not accept it.  Given that the big issuers have no plans to reissue cards, the merchant risk is fraudulent EMV cards (starting in Oct 2015 for Visa). Perhaps if retailers see an EMV card, they should request an ID.  For issuers, the compliance dates are longer and the stick which Visa and MA have constructed is weaker given that US issuers already bear costs of card present fraud.

So what are Visa and Mastercard trying to accomplish? From a political standpoint they must address the international issuer concerns and be viewed as supportive of the EMV standard. But more importantly Visa and MA want to cement their control of the network, particularly in two areas: mobile and US debit cards. In mobile, Visa and Mastercard are aggressively trying to make mobile POS payments a “premium” service used exclusively by credit cards. A key to success in mobile is POS readiness to support contactless payment. The EMV mandate certainly helps provide another incentive to merchants. With respect to the Debit, the Durbin Amendment has impacted the incentives for US banks to continue support of Signature Debit. In the US, PIN Debit enjoys a slightly higher growth rate (15.6% vs 14.3%), consumer preference (48% vs 34%), lower fraud rate (2009: Signature $1.12B, $181M PIN debit card),  and obvious merchant preferences (96% of PIN fraud losses assumed by issuers, vs 56% in Signature). PIN debit transactions do not need to be routed through Visa and MA, and PIN only cards do not require their logo. EMV debit cards may be a tool for Visa to maintain a US debit business (MA US debit penetration is low).

What to expect?

Note that in virtually every geography, EMV was a regulatory driven initiative. In the US this is not the case, as the large banks have proven capable of managing fraud. Large issuers are thus reluctant to undertake any mass reissuance of cards, and US regulators are reluctant to have US Banks pay for a system that will primarily benefit issuers outside of the US. My guess is that we will start to see a trickle of new cards being issued on EMV starting in 2014 or so.

Retailers will have a similar adoption dynamic as they assess cards being used at their stores, and what future payment networks may offer not only in terms of compliance and interchange, but also in delivering customers through incentives and advertising.  I’m certain that the retail “first movers” in NFC must be pulling their hair out as they discover that their new NFC payment terminals are not equipped to accept the mandated EMV card. These retail CEOs will discover that the “stutter” in reterminalization was intentional and it will be a cost they will bear twice in 2 years.

In this dynamic environment, there will be high demand for companies that can help retailers develop a plan and navigate this chaotic environment. Oddly enough, start ups like Square and Payfone may have a tremendous advantage in simplifying the checkout process. In other words, EMV could actually provide the impetus for new payment networks to gain a foothold.

Mobile Swipe: Risk is Behavior … not Security

There is no single solution for all of this fraud, it is a constant battle and weapons just continue to improve and evolve on both sides. For banks, there are 2 common elements to all fraud strategies: educating customers, and security of customer data. In the US, consumers are quite fortunate to have the risks associated with fraud completely borne by banks (Reg E/Z). Outside of the US if you have fraud on your credit card it is your job to prove it. Hence a UK consumer is much less likely to give their card to just anyone, which is why the waiter stands at your table with a mobile card reader for you to enter your PIN.. your card is never out of your sight.

11 March 2011

I’ve been rather unambiguous in my views on Square. Yesterday I received a number of calls from my card friends, with over 50% in support of Square. After pondering their feedback, my bigger concern is customer behavior… a concern that expands beyond Square to all swipe based mobile payments (although I still feel quite strongly that they are not playing by the rules that everyone else agreed to).

For background, beyond my role as alternate channels head for Citi (Outside of the US), I also led sales and marketing for a little start up backed by Kleiner Perkins (41st Parameter) that focused on fraud. Through this role, I was fortunate to develop relationships with the fraud heads of every major US and UK bank and card network. Truly fantastic people… think of them as a mixture of James Bond, CSI, and Elliott Ness (Famous FBI guy). To be honest, I never saw these fraud teams during my time as a banker, and never really appreciated their role in keeping the banking system safe.

Frank Abagnale (of Catch me if you can) was on 41st’s Advisory Board. 40 years ago, this was the kind of fraudster that the bank’s team had to track down.. one guy in a garage with a printing press (magnetic ink). Today, the nature of fraud has changed tremendously. Well organized rings are flourishing, one of which has over 500 employees with product, engineering, marketing, sales…. a specialization of labor. Phishing was a great success, as customers responded to e-mails looking legit. Banks responded with improved online security. Fraud rings responded with malware and “man in the middle” attacks.. point is that this is a dynamic war taking place and bank fraud teams are the “special forces” that crack the code.  The online fraud environment is the most complex battlefield of all. 

It takes resources to win any battle. To give you an idea of the size of risk, gross fraud (attempted) at PayPal was around $500M dollars last year. Through technology and people, PayPal reduced that number to under $50. Bank margin is driven by the ability to manage risk; this is the nature of banking. The top banks, Paypal, Amazon and Apple all have world class teams and resources in this area… thus they seek both higher margin (ie risk) and volume. In essence they “compete” by managing risk more effectively than their peers. A well known axiom applies: If a hungry bear comes into your campsite, you don’t have to be faster than the bear.. just faster than all of the other campers.

There is no single solution for all of this fraud, it is a constant battle and weapons just continue to improve and evolve on both sides. For banks, there are 2 common elements to all fraud strategies: educating customers, and security of customer data. In the US, consumers are quite fortunate to have the risks associated with fraud completely borne by banks (Reg E/Z). Outside of the US if you have fraud on your credit card it is your job to prove it. Hence a UK consumer is much less likely to give their card to just anyone, which is why the waiter stands at your table with a mobile card reader for you to enter your PIN.. your card is never out of your sight.

Example story from yesterday.

Groups of brilliant fraudsters created small mini kiosks called “card cleaners” and placed them in ATM booths, grocery stores, vending machines.. “Clean your credit cards for free”..  I’m not making this up.. people really used them. The crooks just took the numbers and sent them to Algeria (a favorite destination) to create new cards, or to sell to other organized rings. The rest of world hates US use of magstripe.. we are the only country in the world that has not adopted the EMV standard (aka chip and PIN). EU readers still take mag stripe because of the US tourist dollars..

These fraudsters were successful with just magstripe. What if they had your name, e-mail, phone number, … ? If you went to the grocery store, and the clerk asked you for name and phone number and put it in her phone prior to authorizing your transaction would you provide it? This is exactly what Square is doing. Read Dorsey’s response to Verifone’s security concerns. Giving merchants additional data will not decrease fraud, but establish new patterns of customer behavior which will increase it for all. We have a “battle” within the banks today: The card business want to grow transaction volume. The fraud organizations want to protect customer information and ensure customers don’t give their data out to just any hot dog vendor on the street.

Future Scenario

A good crook would probably spend a few days developing an iPhone app that swiped your card, asked for your PIN, took a picture of the back of your card (w/ CVV), obtain phone number and e-mail address. A fraud ring sets up hot dog or ice cream stands (that only take cards) with $0.50 ice cream… they would never even use Square’s software.. or even try to submit a transactions. They would give the food away for free just to get the data.  Once I have this data, I could send within seconds to my HQ to commit ATM, online or even POS fraud in any number of countries.

Was Square’s technology any part of this? Nope.. people could do this today. Is Square encouraging a sustainable consumer behavior? Nope. Smart merchants (Apple, PayPal, …) are choosing Verifone PayWare Mobile because the device is secure.. your employees can’t put on a skimming app because the data is encrypted when it enters the phone. But do I want my bank customers examining the make and model of the card reader before they turn over there card? Heck no! So what do I tell my bank customers? Only give your cards out to merchants you can trust? Do banks incent proper consumer behavior on card use? No.  You get the picture… life just got much more difficult for the fraud and customer experience teams.

Individual issuers have the power to decline square transactions. My guess is that at least 2 major banks will begin to decline all square transactions within next month. Beyond the fraud risk, it also competes with their own mobile initiatives (Barclays/ISIS, Mastercard/RIM, …).

NFC is a step beyond EMV in security… subject for another blog.

Comments appreciated.

Verifone Builds Square Fraud App in 1 hour

Verifone’s CEO (Doug Bergeron) published an open letter to the industry on Square’s flaw. The Square doggle is not PCI compliant (see my blog from last year). Verifone is spot on… they built this skimming application in ONE HOUR.

I took a look at my blog stats today… and they went through the roof.

Verifone’s CEO (Doug Bergeron) published an open letter to the industry on Square’s flaw. The Square doggle is not PCI compliant (see my blog from last year). Verifone is spot on… they built this skimming application in ONE HOUR.

YouTube Video just pulled.. . you can still view at http://www.sq-skim.com/

Chase Paymenttech is Square’s acquirer, and I spoke to them specifically about the Square risks last year. This is an industry issue.. as stolen cards and fraud generate both issuer losses (card present transaction) and a tremendous hassle for customers. I don’t understand why Chase supported this thing… Was told last week that Square’s fraud is off the charts. As I said back in 16 month ago in January 2010

The acquirer that takes this on will likely have a few headaches when the first major craigslist merchant starts using the device to skim and resell card information (among other things). There is a reason for PCI compliance and for my “securing” my physical card and CVV. I can’t wait to see Square’s Payment Services Agreement (PSA). Operationally, the issuer’s have control over card authorization through systems like HNC’s Falcon or SAS Raptor. This means that if SquareUp is found to have contributed to a data loss, or has a high number of fraudulent transactions (see link) customer would see their card transaction declined, or the network (Visa/MC) would shut SquareUp down.

The great thing about the PayPal model is that the customer funded the account after agreeing to terms. In Square’s model, consumers are unregistered, Square is acting as an agent of the merchant. For Square’s investors, there is atypical risk which they will see through “unique” bonding/insurance requirements from the acquirer.  Just as with any company, Square will face unlimited liability associated with loss of consumer information (think TJX). To get an idea for potential mis-use see you tube video below.. crooks invest quite a bit in technology here… will SquareUp make it easier for every iPhone owner to become a skimmer?

Update Thurs Mar 10

Networks are dependent upon everyone following the same rules. Rules are what make networks work, and are essential in “trusting” the transactions coming in. PCI rules were agreed to by all.. Square’s reader does not comply, nor does its iPhone app.  That said we have a very mixed bag of incentives within the current card networks. Banks and the networks want Square to succeed, as it will drive more transaction volume AND drive card use further down market with small merchants… see Visa’s blog

http://blog.visa.com/2011/02/14/emerging-payment-types-new-opportunities/

Bank margin is driven by the ability to manage risk. This is the nature of banking. Within credit card, Big banks like Chase have tremendous experience in fraud and risk.. they the seek both higher margin and volume.  Chase is comfortable with the risk it is enabling with square as both issuer and acquirer. However, their acquisition relationship with Square (through PaymentTech) enables fraud to enter the network, and other banks may have not updated their authorization rules to accomodate. For Example, Bank of America certainly wants increase transaction volume .. but is it willing to pay the price of  BOTH fraud loss AND of encouraging a change in customer behavior (give their cards to anyone with an iPhone and card reader)?

From my background at 41st Parameter, I was fortunate to develop relationships with the fraud heads of every major US and UK bank and card network. This will be an active discussion for them today. Bank decisions are caught up in the business dilemea of how to respond to Durbin, as well as their own mobile strategies and EMV perspective. Fraud usually develops once critical mass is reached, as fraudsters don’t want to waste their own resources developing a compromise unless there is volume.  My view is that Square’s reader and iPhone application are clearly not compliant with PCI rules and that Visa and Mastercard must shut them down. They have no choice.

Perhaps a story is in order to talk about potential impact. Groups of brilliant fraudsters created small mini kiosks called “card cleaners” and placed them in ATM booths, grocery stores, vending machines.. “Clean your credit cards for free”..  I’m not making this up.. people really used them. The crooks just took the numbers and sent them to Algeria (a favorite destination) to create new cards, or to sell to other organized rings. The rest of world hates US use of magstripe.. we are the only country in the world that has not adopted the EMV standard (aka chip and PIN). EU readers still take mag stripe because of the US tourist dollars.. and claim that we are responsible for their fraud (they have a decent case).  Verifone’s 1 hour fraud app (www.sq-skim.com) is not a technology issue as much as a behavior one. A good crook would probably spend a few days developing an iPhone app that asked for your PIN…. and took a picture of the back of your card w/ CVV, I noticed in Square’s response that they also ask customers for phone number and e-mail address (normally). This data is beyond the wildest dreams of fraud organizations.  I can just imagine a fraud ring setting up hot dog or ice cream stands that only take cards.. .and sell the ice cream for $.50… they would never even use square’s software.. or even try to submit a transactions. They would give the food away for free just to get the data.

As a side note Square is not winning against Verifone. Square has only 5k-10k active merchants (see blog) and $200k in revenue per MONTH… so lets stop this thing before it gets viral.

Square Up update

Square looks to be sitting on about 5k-15k customers and is in a holding pattern until they resolve fraud and risk issues

11 Dec 2010 (updated)

Previous post http://finventures.wordpress.com/2010/03/02/squareup-take-4/

Today’s Telegraph (UK)

Dorsey is a marketing machine! It’s just amazing how much buzz he has been able to create (yes I am envious). The Square application is stellar from a customer experience perspective. Although appshopper shows them in the top 20 free finance apps (~1M downloads), I estimate they are sitting on only 5k-15k active customers (this is the nature of a “free” app).  It also seems that they are in a holding pattern until they resolve fraud and risk issues (I covered this in last blog). From their FAQ

Until recently, Square was facing a big hardware shortage, but that’s now coming to a resolution. The problem has transitioned to something we’ve been working on simultaneously, a credit processing and risk issue: we need to strengthen our underwriting infrastructure so that we can handle the huge demand for readers and still manage the risk of chargebacks and fraud. This is the last thing preventing us from shipping readers as fast as we’d like, and we have almost the entire team working on it. We look forward to sending you a Square!

My guess on the hold up? iPhone cannot be made PCI compliant without first encrypting the card BEFORE it gets into the iPhone (see the Verifone solution). As you can see from the Visa PCI DSS list, Square is certified in 3 areas:

  •  IPSP (E-commerce)
  • Payment Gateway
  • Process Magnetic-Stripe Transactions

 This means that Square’s data center is approved to handle card data in these areas (ex. not leaving card numbers sitting around unencrypted). This does NOT mean that the Square Application or Doggle have been certified. In fact, a search in the PCI org’s list of approved applications has no mention of Square. Where Verifone’s Payware is shown approved (below).

This is certainly a driver for PayPal’s recent partnership with Verifone to enable PayPal to act as merchant acquirer (see Verifone Press Release)

My (somewhat educated) guess is that Square must redesign the “Square” for encryption AND its Application AND get it certified by the issuers. This is a 12-18 mo process … as I said last year.  Of course I could be wrong on this.. perhaps they are indeed near certification. Assuming they do get the US mag stripe issues resolves it will not translate into any global adoption. I laughed quite a bit after reading the UK Telegraph article.. particularly given the EMV (Chip and PIN) requirements in EVERY country outside of the US.  So a new “redesigned” Square for magstripe won’t work in europe.. that is yet another design challenge with its own certification process. Who said payments was easy?

The card networks and issuers want Square to be successful, as increased card acceptance means increased payment volume. But there is a reason that acquirers and merchant agreements exist. Fraud usually is 18mo-2 years behind a new payment method as its not worth the fraudsters time (and resource) to invent a compromise. Square will face unique risks not seen before by any acquirer. For example:  merchants accounts denied by other acquirers, physical card fraud rings, skimmers looking to take the cards and auth codes for use off line, virtual card fraud rings looking to “pump” card data through 100s of easy to set up Square accounts.

Square has a use, but the market is small. I expect many small merchants to give the service a try, but once they realize that it takes 30-60 days to settle and that they have a new burden (under reg z) for returns and consumer transaction dispute (ex reserves) they will decide that the headache is not worth it.  In other words they will face the same barriers that the large acquirers have in moving down market.  Dorsey was in a WSJ video yesterday outlining potential benefits for issuers using square. This is a soft repositioning of his company for a potential exit. He knows that the market is limited and is hoping for alliance plays with large issuers/acquirers. Banks are certainly in a better position to roll this out.. particularly because of their ability to manage card risk (but customer support is a “little” more robust as well). As I stated previously, smart money would wait for Dorsey to gain adoption and struggle through the issues before investing.

The problem that Dorsey is trying to solve is core to the acquiring business: how to grow card use among small merchants. Question remains on whether this is this a “technology problem”, or a business problem? For banks wanting to dip their toes in the technology: it is already available through teams like Verifone. For Small Merchants with a need for a convenient easy to use method for accepting cards:  go to www.paywaremobile.com and sign up with FirstData. For consumers: think twice about giving your card to the hot dog vendor..   banks own the risk (in the US), but there is still a big hastle in shutting down your account.

As I stated in my Jan 2010 blog, Square presents a risk to the payment system

The acquirer that takes this on will likely have a few headaches when the first major craigslist merchant starts using the device to skim and resell card information (among other things). There is a reason for PCI compliance and for my “securing” my physical card and CVV. I can’t wait to see Square’s Payment Services Agreement (PSA). Operationally, the issuer’s have control over card authorization through systems like HNC’s Falcon or SAS Raptor. This means that if SquareUp is found to have contributed to a data loss, or has a high number of fraudulent transactions (see link) customer would see their card transaction declined, or the network (Visa/MC) would shut SquareUp down.

The great thing about the PayPal model is that the customer funded the account after agreeing to terms. In Square’s model, consumers are unregistered, Square is acting as an agent of the merchant. For Square’s investors, there is atypical risk which they will see through “unique” bonding/insurance requirements from the acquirer.  Just as with any company, Square will face unlimited liability associated with loss of consumer information (think TJX). To get an idea for potential mis-use see you tube video below.. crooks invest quite a bit in technology here… will SquareUp make it easier for every iPhone owner to become a skimmer?

[youtube=http://www.youtube.com/watch?v=svzZxB0o8J8]