TPPPA Spring Conference - May 17th to May 19th
Congresswoman Krysten Sinema joins the FTC, CFPB Ombudsman's Office, FinCEN, NACHA, and other industry leaders as speakers at our Conference in Washington DC. Check out our amazing agenda, including a visit to Capitol Hill!
To see the agenda and to register, please Click Here!
Intro to the TPPPA - May 2nd at 1:00 PM EDT
The Third Party Payment Processors Association (TPPPA) is a not-for-profit membership association for third-party payment processors and banks with third-party payment processor programs. We were formed in 2013 to raise awareness of the important role payment processors play in the payments industry and the economy, and to promote industry best practices through our TPPPA Compliance Management System (CMS), a free member benefit. Learn more about the TPPPA, member benefits, and our industry best practices, training and compliance products and support, and the important state-level work we will be taking on in the upcoming year.
Click Here to Register!
Upcoming Public Training
May 03, 2017 at 2:00 PM EDT.
Clearly there has been a shift in policy with a new Republican President and Republican controlled Congress. The Trump Administration's policy is based on reducing regulation, the opposite of what we saw with the Obama Administration. The question is, just how much change can the payments industry expect, particularly in the realm of consumer protection enforcement and Know Your Customer requirements, like the beneficial ownership rule.
Join the TPPPA and our Legal and Regulatory counsel Troutman Sanders as we discuss how policy has shaped enforcement of laws and regulations at a federal and state level in the past, and what to watch for in 2017 in the legal and regulatory arena.
Click Here to Register!
Visit the TPPPA at PAYMENTS 2017 at Booth 722
The TPPPA is a sponsor and exhibitor at PAYMENTS 2017 again this year! Stop by Booth 722 and play our "Guess How Much Cash" game.
April 23rd through April 26th in Austin, TX
Upcoming Member Training
TPPPA Best Practices for Banks
Join us for another great TPPPA Member's Only Series "TPPPA Bank Road to Certification" where we will delve into the details of the TPPPA Compliance Management System for Banks. TPPPA Members never pay for our training! All courses begin at 2:00 PM ET and will be recorded for members that cannot participate.
- TPPP Program Due Diligence & Oversight - March 16th
- Program Level Risk Assessment - March 30th
- Program Policies, Procedures & Internal Controls - April 6th
- TPPP Due Diligence, Agreements & Approval - April 20th
- Monitoring & Reporting - May 4th
- Program Manager Duties - May 25th
TPPPA Member Overview of Beneficial Ownership Tool
April 11th and April 19th at 2:00 PM EDT
Many TPPPA Members are struggling over how to address the new Beneficial Ownership Rule. Bureau Van Dijk, a new affiliate member of the TPPPA, has tools to address this need. Join us for a demonstration of these tools and a discussion about how these tools can support your company's compliance with this important rule. Bureau Van Dijk brings a measure of certainty surrounding who controls your clients, and the associated risks to your company. Topics include:
- Who are your clients' beneficial owners?
- Automating the client onboarding KYC Risk Assessment
- Scoring the risk found during onboarding
- Managing workflow to remediate risk
- Monitoring the client relationships for new risk
Like our member training offering? We never charge our members for training. Click Here for more information about becoming a TPPPA Member.
FinTek Talent Showcase/TekStream Solutions
Since the January 20th inauguration, discussion around reorganizing or eliminating certain regulatory bureaus are high on everyone's radar. You want to have your best foot forward, and that starts with your human capital team. Each month, our FinTech Recruiting Team interviews hundreds of professionals with varying skillsets within the industry. We want to give you the best, therefore - we're giving you an insider look of the most potentially impactful contenders amongst all those we interviewed.
Compliance Manager Showcase:
With 12 years of PCI Risk & Data Security expertise, she has performed roles such as Director of Risk & Compliance, High-Risk Escalations Manager, and Risk Analyst. Her experience is in Risk & Compliance, Data Security, Chargebacks, Payment Card Rules & Regulations, PCI-DSS, and Fraud/High-Risk Prevention. She has managed multiple portfolios, MC & Visa fine recoverables, and worked with IT teams to develop in-house proprietary Risk systems.
Current Location: Florida (Remote, but able to travel as much as needed)
PCI Operational Fraud & Compliance Showcase:
With 15+ years of operational leadership & risk mitigation delivering measurable results, she's currently a Strategy Manager with a card brand, currently responsible for mitigating losses while implementing governance and compliance before any merchant services rollout. Her previous positions include: Fraud Operations, Compliance Manager and Communications Leader positions.
Current Location: Phoenix, AZ
Interested in a Conversation? Contact Jayme.Danielson@TekStream.com or 404-558-1118
Stay the Course
The recent national election has left many wondering what the impact will be to the regulatory environment of the financial services industry. A republican president and congress will have the potential to alter the regulatory environment, but questions remain about how much and how soon. Articles abound related to the new administration and their desire to alter the impact of, and potentially replace Dodd Frank, particularly related to the powers afforded the Consumer Financial Protection Bureau (CFPB). More questions arise as to the constitutionality of the Bureau's structure and its future. Many questions and no fast answers.
The Third Party Payment Processors Association (TPPPA) advocates on behalf of its payment processor and bank members and has created industry best practices for third-party payment processing designed to address the concerns of state and federal regulators and law enforcement. The TPPPA has been repeatedly asked what we think the regulatory environment will look like and if we can expect relief from compliance expectations and burdens. Our message is to stay the course. Here are some thoughts as to why.
The emphasis of the Obama Administration on consumer protection in the financial services industry had far-reaching impact to the payments industry. Participants in payments such as banks, payment processors and merchants, (particularly in industries deemed high-risk by the administration for consumer protection violations,) have been greatly impacted. Much of this resulted from the creation of the Consumer Protection Working Group in early 2012, as part of the Obama Administration's Financial Fraud Enforcement Task Force.
The Consumer Protection Working Group was said to be formed to "address several areas of concern, including payday lending and other high-pressure telemarketing or Internet scams, business opportunity schemes, for-profit schools that engage in fraud or misrepresentation, and fraudulent third-party payment processors that facilitate payments on behalf of other fraudsters without the permission of the customer." Members include: the Federal Trade Commission (FTC); the CFPB; the Department of Justice; bank regulators; FinCEN; various states' Attorneys General; and others. Inter-agency collaboration at a state and federal level continues and won't stop with a new administration.
Obligations related to anti-money laundering have been in place for decades and they aren't going to be lessened in the future. In fact, identifying beneficial ownership is a new requirement that all banks and payment processors will be required to comply with as part of global anti-money laundering and combatting terrorist financing efforts. The United States was recently criticized for its lack of progress in this area by the Financial Action Task Force (FATF), the multinational inter-governmental body formed to foster international action against money laundering. FinCEN and bank regulators will continue to have high expectations of banks and payment processors in these global efforts.
Consumer protection laws and regulations have also been in place for decades. While the CFPB has been the most aggressive enforcer in this area of late, the FTC and the state's Attorneys General have been enforcing consumer protection for years and will continue to do so. If the CFPB is reined in some by the Trump Administration and republican congress, first, it will take time, and second, the FTC and states will step in to fill the void.
Over the past few years, both the CFPB and the FTC have taken enforcement action against payment processors related to the alleged misconduct of the merchants that they process payments for. While the CFPB as a new enforcer has been most active in this regard, the FTC has utilized this kind of action against payment processors for several years. These agencies will continue to expect that payment processors restrict their merchants from committing consumer protection violations. Additionally, those consent orders already enforced are now considered to be guidance to other payment processors. This "guidance by consent order" will continue for the near term certainly, and likely the long term.
Payment processors take on some of the most critical compliance functions of their banks related to the merchants that process payments through these relationships. Bank regulators expect banks to demonstrate that their payment processors have the ability and the will to accept these responsibilities in order to keep their bank in compliance. Bank regulators will continue to expect payment processors to have robust compliance practices that support their banks' compliance obligations related to anti-money laundering and consumer protection. This will not change with a new administration.
As the payments landscape changes with new technology and innovation, the regulatory environment must adapt. With the complex coexistence of federal regulations and state laws, coupled with a changing environment, banks and processors engaged in third-party payment processing must continue to exercise sound compliance management. All regulators have expressed their expectations that compliance management systems need to be documented, risk-based systems that support a top-down culture of compliance.
Risk-based compliance management systems are designed to address core risks that don't go away with a change in administration. The TPPPA advises payment processors and banks to "stay the course" and continue efforts to refine and continually adapt their compliance management systems.
Marsha Jones, AAP, NCP, CAMS