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aRTiCLeS


          Banks are recommended to contact                       Free Article Provides State of
          their ATM service providers for the
          latest security updates and patches                    Play on Payments Innovation
          to mitigate the risk from these                        In a free preview
          attacks, to ensure proper physical                     from the next
          security controls limiting access                      issue of the ABA
          to the machine and to monitor                          Banking Journal,
          for communications failures and                        ABA’s Tyler Mondres provides a state of play for the payments
          alarms.                                                ecosystem, with a focus on efforts to improve payment speed

          Diebold Nixdorf, a major ATM                           and efficiency. “The common theme in all of these categories is
          vendor, recommended limiting                           that they result in an improved customer experience by meeting
          physical access to the ATM;                            customer demands,” he writes.
          implementing protection mechanisms for cash modules;   Mondres covers the latest developments with the Federal Reserve’s
          monitoring unexpected opening of ATMs’ “top hats”; and   Faster Payments Task Force, same-day ACH, digital wallets and
          keeping operating systems, software stacks and configurations   person-to-person payment platforms like Zelle. He also explores
          up to date. NCR, another major ATM provider, also issued an   implications of ongoing innovation and experimentation with
          alert with specific recommendations to address common forms   open APIs and blockchain-based solutions.
          of logical attacks against ATMs.
                                                                 To read the article visit: https://bankingjournal.aba.
          To view the Diebold Nixdorf alert visit: http://image.exct.  com/2018/01/the-present-and-future-payments-ecosystem/
          net/lib/fe6b1570776c04787615/m/1/20180126+GLOBAL+SE
          CURITY+ALERT+018-04-0005+Potential+Jackpotting+US      CFPB Finalizes Changes to
          +Update+on++017-34-0002.pdf
                                                                 Prepaid Rule
          To view the NCR alert visit: http://app.response.ncr.com/e/es.
          aspx?s=116340975&e=57663&elqTrackId=fb662be781a7416    The CFPB has finalized changes to its rule on prepaid products,
          8b941c1d53dfd9363&elq=d13d1ce7c8a545da93de8e60bd59     including an overall delay of the rule’s effective date until April
          8fec&elqaid=3876&elqat=1                               1, 2019.  The changes would revise the error resolution and
                                                                 limited liability provisions to ensure that “financial institutions
          Mixed Ruling in Major                                  are not required to resolve errors or limit consumers’ liability

          CFPB Case Upholds Its                                  on unverified prepaid accounts.” The bureau also made other
                                                                 adjustments and clarifications that will reduce regulatory
          Constitutionality                                      burden, including ones related to compulsory use for certain
                                                                 cards such as jury cards, foreign language disclosures and
          A ruling by a federal appeals court                    submission of prepaid account agreements to the CFPB. There
          has some good and not-so-good in                       is still a concern that the rule fails to clearly distinguish between
          it. The good is that the court upheld                  “prepaid accounts” and “checking accounts,” which, given the
          a lower court panel’s ruling that the                  significantly different regulatory schemes, creates compliance
          CFPB and then director Richard                         uncertainty and risk.
          Cordray overstepped their authority
          in retroactively applying new RESPA                    To read more visit: http://files.consumerfinance.gov/f/
          interpretations to an enforcement                      documents/cfpb_prepaid_final-rule_2018-amendments.pdf
          action. The case arose in 2015, when Cordray overruled an
          administrative law judge’s recommendation for a $6.5 million   CFPB Seeks Feedback on Civil
          fine against mortgage lender PHH for allegedly engaging   Investigative Demands
          in  unlawful  arrangements  in  violation  of the Real Estate
          Settlement Procedures Act. Cordray demanded that PHH   The CFPB has issued a request for information seeking feedback
          pay 18 times more, or $109 million, for each time it received   from the public on its processes related to civil investigative
          a payment deemed improper by the bureau on or after July 21,   demands, which are issued during enforcement actions. The
          2008. On the downside, the court upheld the constitutionality   request came after Acting Director Mick Mulvaney announced
          of the CFPB’s leadership structure, a single powerful director   plans to undertake a broad public feedback initiative to ensure
          who can be removed by the president only “for cause,” not at   that the bureau is fulfilling its statutory requirement to protect
          will, reversing a three-judge panel’s decision made in 2016.  consumers.




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