Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

Samantha: Hello, this is Samantha Shares.

This episode covers

Fighting Payments Fraud: A Deep Dive into
Federal Banking Agencies' New Initiative

The following is an audio
version summary of that document.

This podcast is educational
and is not legal advice.

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And now summary of the request for
comment on fighting payments fraud.

Fighting Payments Fraud: A Deep Dive into
Federal Banking Agencies' New Initiative

today we're diving into a significant
new initiative from three major

federal banking agencies to combat
the growing threat of payments fraud.

On June 20th, 2025, the Office of
the Comptroller of the Currency, the

Federal Reserve System, and the Federal
Deposit Insurance Corporation jointly

issued a Request for Information
seeking public input on how to better

address payments fraud across the U.S.

financial system.

The Growing Problem

Let's start with the scope of the problem.

According to the agencies, payments
fraud is inflicting significant

harm on consumers, businesses,
and financial institutions.

They define payments fraud as quote
"the use of illegal means, including

intentional deception, misrepresentation,
or manipulation, to make or receive

payments for personal gain."

The numbers are staggering.

Data from the Federal Trade Commission
shows that losses reported for

non-card payments fraud increased
271 percent between 2020 and 2024.

Meanwhile, data from the Treasury's
Financial Crimes Enforcement Network

shows that Suspicious Activity
Reports filed related to check,

ACH, and wire fraud have increased
489 percent between 2014 and 2024.

Check fraud is particularly concerning.

The Treasury Department reports that
check fraud in the United States has

risen 385 percent since the COVID-19
pandemic, and FinCEN reports that check

fraud accounted for approximately 30
percent of fraud-related Suspicious

Activity Reports filed in 2023.

Why This Matters

The agencies emphasize that payments
fraud quote "has the potential to

erode public trust in—and undermine
the safety, accessibility, and

efficiency of—the nation's payments
system, upon which the U.S.

financial system depends."

What makes this particularly challenging
is that, as the agencies note, quote "a

payments fraud scheme may involve multiple
institutions and payment methods, each

of which may fall within the remit of
different Federal and State agencies."

They acknowledge that quote "no
agency or private-sector entity can

address payments fraud on its own."

Five Key Areas for Action

The Request for Information focuses on
five potential areas for improvement:

1.

External Collaboration The agencies
are asking: What actions could

increase collaboration among
stakeholders to address payments fraud?

They're particularly interested in
standard setting and identifying

organizations outside the payments
and banking industry that might

provide additional insights.

2.

Consumer, Business, and Industry
Education While financial education

resources exist, the agencies
recognize there may be a need for more

specific payments fraud education.

They're asking what types of
education are most effective and how

to make existing resources better.

3.

Regulation and Supervision The agencies
want input on potential regulatory

changes and whether existing supervisory
guidance is sufficient and clear.

They're particularly interested in how
to help small community banks detect,

prevent, and mitigate payments fraud.

4.

Payments Fraud Data Collection and
Information Sharing Currently, payments

fraud data is, quote "collected in
an incomplete, non-standardized,

ad hoc, and fragmented way."

The agencies are exploring ways to
improve data collection and sharing while

addressing privacy and legal concerns.

5.

Reserve Banks' Operator Tools and
Services The Federal Reserve Banks

already provide risk management tools,
but they believe quote "there may be

further opportunities for the Reserve
Banks, as a payments system operator,

to provide additional tools and services
designed to reduce payments fraud."

Specific Focus on Check Fraud

Given the particular problem with
check fraud, the Federal Reserve

is specifically seeking input on
potential amendments to Regulation

CC, which governs funds availability.

They're asking whether technological
advancements have reduced the

time it takes to detect fraud
such that funds availability

requirements should be shortened.

The Fed notes that checks contain
sensitive information including quote

"the payor's name, account number, routing
number, address, and signature—that

can be used by criminals to conduct
other forms of payments fraud."

Looking for Solutions

The agencies are asking some practical
questions that affect everyday banking:

• Should Reserve Banks require fraud
reporting for all payment rails?

• Would confirmation of payee services
help mitigate fraudulent payments?

• How can financial institutions
better resolve disputes about

allegedly fraudulent checks?

• What technological solutions have been
most effective in preventing fraud?

Industry Impact

The document reveals that the
agencies have quote "received

complaints from supervised
institutions regarding challenges in

resolving disputes about liability
for allegedly fraudulent checks."

This suggests the problem is
significant enough that banks are

actively seeking regulatory guidance.

Next Steps

Comments on this Request for Information
are due by September 18, 2025.

The agencies are particularly interested
in hearing from a variety of stakeholders

including consumers, businesses, financial
institutions, and technology providers.

As one of the questions in the
RFI asks: quote "What measures,

including technological solutions or
services, have been most effective in

identifying, preventing, and mitigating
payments fraud at your institution?"

Conclusion

This comprehensive Request for
Information represents a significant

coordinated effort by federal banking
regulators to tackle payments fraud.

With fraud losses in the billions
and growing rapidly, the agencies are

clearly taking a proactive approach
to protect consumers and maintain

confidence in the payments system.

The 26 detailed questions they've
posed show they're serious about

getting input from all corners of
the financial services industry.

Whether you're a bank, a fintech
company, a consumer advocate, or just

someone who's been affected by payments
fraud, your input could help shape the

future of fraud prevention in America.

That's all for today's deep dive into
the federal response to payments fraud.

Thanks for listening

________________________________________
This podcast script is based on
the Federal Register document

dated June 20, 2025, Volume 90,
Number 117, pages 26293-26298.

This concludes our summary.

If your Credit union could use assistance
with your exam, reach out to Mark Treichel

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This is Samantha Shares and
we Thank you for listening.