Thank you so much for joining me on Fraud Forward.
Hailey, thank you for having me. I'm glad to be here.
We talked about it, I think, like three conferences in the past.
Like the timing just never worked, but now
finally Money 20/20, here you are.
It's my second time being here and first time on your
podcast, so I'm really excited for the combination.
First time, but definitely not the last.
We definitely got to bring you back. Um
There's a lot of content and fraud we can do.
There is. There is. There's so much.
Jeni, thank you so much for joining me on Fraud Forward.
You're welcome. I'm happy to be here. Thanks for inviting me.
All right, Jared, thank you so much
for joining me on Fraud Forward.
Absolutely. It's great to be here.
Angela, thank you so much for joining me on Fraud Forward.
Hi, Hailey. Thank you for having me.
I always love catching up with one of my favorite fraud fighters.
I have to say before we even get started, this booklet
found its way to me from another really good friend
in the industry and it is the Trust 25 Awards.
Says, "Meet the 25 uh leaders defining
trust in the digital economy. " And you, my friend, have a spread.
I am so so proud for you of you. Love this so much.
Um would love for you to number one, tell me, you
know, what it means to you to be honored here.
And then also, I'm going to need your autograph, but I just dropped
the pen, so I'm going to grab that while you answer that question.
Um so what it means to me is uh I am very very committed
um to driving change in the industry.
And I'm very very passionate about the humans
that are attached to the fraud.
So not just the losses and the metrics.
Um so that's really what identity means to me.
Identity is also one of the first points of risk management and
control when we think about the customer life cycle and how fraud
can enter the bank and just being recognized uh for the the work
that I have really dedicated my life to for the past 15 years.
And also to be alongside people that I've admired throughout
my entire career was very very humbling, um exciting.
And I'm very very very grateful for it.
Well, I'm super proud for you and it's very well deserved.
So, again, I'm gonna need you to sign this for me.
This is my copy that I picked up and I'm like,
I know these people and they're my favorite people
in the world and I'm just so grateful. Love it. Love it so much.
Thank you. Okay, so let's move on to why we're here.
Um, obviously, um, I've had a benchmark report that just recently
came out, so I'm going to have a few questions about that.
We're here live at Money20/20.
Uh I'd love to know uh how how often have you or
how many times have you come to Money 20/20?
So this is my second year at Money 2020.
Um and the major difference for me was just like last year was all
about just navigating the resort and the conference maps and trying
to juggle networking and attending the right sessions.
So this year I felt like I definitely um was a lot more comfortable.
I had a strategy. Uh I went to a lot of incredible sessions on Sunday.
So, I highly recommend people coming in for that Sunday.
It's a lot less crowded, great content.
Um, and I've just really enjoyed the quality people
and and getting to meet with a lot of really amazing
solutions and talk about emerging risks.
So, it's been a fantastic event.
I love that you say that. Um, and I agree.
Uh, the navigating thing was definitely last year.
This year though, like I think last
year I stayed in the south tower. This year I'm in the north tower.
So, I am still a little bit confused.
I'm like, I I should have just stayed in the south
tower again so that I know where everything is. But it's okay.
I I finally navigated it.
I know where to go to get to the uh conference hall and
luckily where our booth sits, I can find it easily.
Um Okay. So, let's just dive into it.
You've worked uh in both a startup and the corporate environment.
Uh what carries over when it comes to managing
fraud risk and what doesn't?
So in a startup environment you, because it's smaller, you don't
have as many organizations that are working in silos.
You get to have an understanding of every piece from fraud
investigations um to data and analytics to charge racks and disputes.
You typically own it and can see all of it. Compliance as well.
Um when I was at a startup I was in the e-commerce space.
So it was a little bit different, but you
really get to to learn that whole loop.
When, so understanding all of that made me a lot more successful
when I went over into large financial institutions.
Because in large financial institutions it's the organizations
are so large that you typically really focus on one area.
Um but you're going to be more successful in the area that you focus
in if you understand the upstream and downstream impacts.
Um so that absolutely carried over, and also foundational
fraud risk controls apply in a startup and in both e-commerce
merchant side and large financial institutions.
So that benefited me uh as well.
Yeah, it carried over and it's one of those things that even
if the corporate environment maybe didn't have what you had
in that startup uh you were able to bring that over.
Um, which I think is is super valuable and why
I also love getting that outside perspective.
Like when hiring um I had someone the other day say that you
know for their fraud manager it's their former role was
a branch manager and I'm like oh my god I love that.
I love that they have that firsthand frontline knowledge
of how and like what the the things are the how
to navigate like different conversations.
So whenever they are developing fraud training later like
imagine like how connected they'll be with that frontline
intuition almost um and be able to change that.
So I love that outside perspective can come in
and can absolutely influence for the better.
Um so in our benchmark that we just uh launched roughly
half of the institutions share data and workloads with
BSA, AML, cyber security and enterprise risk.
What makes cross functional collaboration work
in practice and then what breaks it?
So what makes it work in practice is and and kind of the same
concept I I just spoke to is understanding what fraud looks
like in different areas and how they intersect.
If cyber doesn't understand what fraud is, how it's defined, and then
what it looks like for them, they're not able to identify it in their
space and make the connection between what cyber might need to do uh
to fight fraud versus what the actual fraud groups need to do.
So that's super important.
Um where it can sometimes break um is in large complex organizations
there's a lot of stakeholders and a lot of decision makers.
Um so there can often be a struggle with understanding each
perspective, um coming to a quick well-informed decision
with the right rationale, and then being really good at turning
that collaboration into strategy and execution.
Um, so it's one of those things where strate collaboration, strategy,
and execution are the three most important things to me.
Um, I try to interlace them in all of of my work.
But, um, that's in a perfect world.
It does become challenging when you have different leaders,
perspectives, um, goals, budgets, uh, processes.
Um, so that's that's really where it breaks.
But I think the key to that is a really
good change governance program.
I spent about a year in change management and
compromised data as as one of my roles.
Um, and I do a lot of change governance now. I'm a stakeholder.
I approve a lot of changes with my leadership team.
Uh, so a really solid change governance is key.
Identifying who your key stakeholders are and your decision makers
and kind of cutting out the noise, not having too many voices
at the table, um, is is, you know, really, really important.
Um, and I guess that kind of even answers the question
of what does good fraud governance look like
in the day-to-day beyond that policy.
Where yeah, in in the policy we've got this, you know, almost like
legal wording that you know this is this is how we do what we
do, not the process, but as far as like how we govern it.
And then moving into the day-to-day processes, making sure that
what we've dictated as far as like this is how we view fraud.
This is what we classify under fraud.
This is how we this is our risk tolerance for fraud.
Um I I love that that strategy comment
that you were making about it.
So if there's anything more to add on the the dayto-day
So when we draft a policy, we're setting up what we feel um
should be like the gold standard of how to fight fraud.
And usually it does consist of the foundational things
like having the right authentication in pa in place.
Um how do we onboard you know what are the gold standards
for what we should have in place for onboarding our customers,
for transaction monitoring, risk scoring.
Where do we need to all have step up.
So we're setting just kind of an industry standard for what
we think um good fraud risk management should look like.
And then it's really important that then we work directly with the
business owners and the process owners to understand their processes.
And help them understand how the bank has defined
external fraud at the policy level.
How it applies to them with the activities
that take place within their processes.
And then what parts of the policy apply to them and how do they turn
that into practical risk management solutions within their processes.
So we do a lot, we don't just draft the policies and the
standards and and throw them out into the universe.
We do do a lot of collaboration uh again with the businesses
and we're right alongside them with figuring out um
you know what parts of that policy apply to them.
It's a very very long journey and it doesn't end because
we also, as policy owners, should be paying attention
to when our policy might be outdated.
Or when something that we put into our policy doesn't really show up
really well in practice and where we need to tweak and enhance.
Um so that's where again that collaboration and feedback
between stakeholders um is really really important.
I also love the idea that it's not just this department that's
going to make a policy, live in this little black box where it's
like, oh yeah, this is what it says on paper that we're doing,
but not making sure that it's being lived, you know.
Um, and that collaboration piece is so important.
Because I I know even when consulting and trying to help an
organization write their fraud policy, it was comparing it to
the other policies, making sure that we weren't contradicting
another one and also making sure that it it matched the overall
uh, you know, theme and tone of the other policies.
Because if it's a completely different policy that like
you know, we uh, you know, copied from a friend or you
know, cuz we didn't have one in place before, every
organization is not going to have the same policy.
They're not going to respond to fraud the same way and
making sure that we have that documented as as specific
as we can for our own organizations is so vital.
And taking feedback from uh the stakeholders on how
easy or difficult it is to interpret the policy.
If I'm, you know, if I were giving you directions
to my house, your success in getting to my house
depends on how well I gave you directions.
So that's an oversimplified version of drafting a policy.
And then the people that are reading the policy and interpreting
it and having to apply it um is really important.
So feed that feedback loop um and just being there for support.
I tell all the leaders within the bank um you
know we are there for support and guidance.
So they can reach out to us any time with policy inquiries.
And we will meet up with them, talk through it and then a lot of those
meetings let us know what parts of our policy might need to be
redrafted to be a little bit more understandable to the audience.
And for the record, don't ever give me like north or south.
Like don't don't do that. I don't need any of that.
I need to know uh buildings uh you know
turn left at the Hobby Lobby.
You'll go down two stop lights and take a right.
Don't don't give me uh you know the directions
you would give uh the explorers. I'm not I can't do that.
So yeah, I love that because also you know I have read policies
before where I'm like god this just seems so like a high level.
It's not specific enough to what I need to interpret
for how the organization feels about fraud.
So when you say like making sure that it is understandable to
those that are responsible for that piece of the policy.
That is so important and something that I hadn't considered
in speaking it, you know, out loud before,
Your interpretation of the policy might not align with my intent
of how I drafted it and that's that's really really important.
4% of the fraud leaders in our benchmark
track false positives, but only 69. 4% uh regularly report them.
And teams that formally report them were 90%
satisfied with their technology versus 71. 4 for for the rest.
How do you decide what's worth reporting upward
and how do you keep that efficient?
So false posit positives are extremely important to to report.
Um it doesn't, they're not as in my opinion necessary to report
upwards as they are as they should be a focus for the actual fraud
leaders as a feedback loop for where they are not being as targeted
and accurate as they should in how they've set up their fraud risk and controls.
It interferes with the customer experience which is really important.
Um but usually when we're reporting upward we are focused
more on high level metrics like loss dollars, complaints usually
goes upwards and complaints and false positives.
They they do go hand in hand to a certain extent because your
complaints are also where you see your customers getting hung up um
and where you you might need to be more targeted and and accurate.
So I think false positives are more important for the actual leaders
to consider as like feedback for where they need to tweak their rules,
their alerts, their monitoring or change, you know, the onboarding
experience like more so than it needs to necessarily go upward.
But there are certain regulations in place for the large financial
institutions around complaints um that might travel upward.
But again, I think that that ties into false positives really well.
It's definitely making sure that leadership is aware
of things that could, you know, impact uh cause member
harm or customer harm, reputational damage, regulatory
issues, things like that, things that matter.
Um, and I think the false positive thing like you were
even saying, it it says a lot about the vendor.
And and what's going on for how your organization is using one.
Maybe, you know, after tweaking there's still a a high false
positive rate and that's whenever you know, okay, maybe it's
time to shop around, you know, um but without having to just
say, hey, there's a new shiny toy, you're actually coming with
with data that proves that there there's kind of an an underlying
issue here or a gap that we need to try to fill.
Absolutely. I am very very data driven.
Um and in a in an industry like fraud like you really need
to be data driven especially in the larger the institution
um and especially the more complex the institution.
Um you were also named um a Trust 25 honoree
as a leader in agentic commerce.
As AI agents start uh transacting on behalf of customers.
What do you think changes for fraud teams?
I definitely think it's we're going to have to have discussions
and set like standards around accountability.
So, if I'm choosing to use an agent um in the commerce
environment, um you know, how do you identify that
that's an authorized agent acting on my behalf?
Um who is accountable for the agent behavior?
If I as a consumer claim that my agent did it, quote unquote, not me.
Um how do we tie the identity together that the agent is belongs
to me and I'm actually appropriately identified.
So, that's something that we're going to have to consider.
And just the decision um of do we allow consumers to use agents.
My opinion, and this is just my opinion, it's not tied to
any any banks that I've worked for, currently work for,
is that we absolutely should um be forward thinking.
And if our consumers want to be able to use agents, we need to
figure out then how to manage the risk of of them doing that.
That's the direction the world is going. Um, and that's our job.
That's why we keep on our toes.
We're constantly evolving new challenges, thinking through
and assessing these new risks and understanding them.
And I love that part of the job.
Um, so that's how what I think it's going to look like and I think
those are the things we're we're going to need to solve for.
And I'm here for it. Let's go.
You know, I I'm starting to get on the same level as you.
I'll be honest, as a small community bank, uh, and then credit
union fraud practitioner, things like that scared the mess out of me.
You know, I would think, why in the world are
you trying to do digital issuance right now?
You know, and like that's one of the things that like as a consumer
I'm like please I need digital like I'm traveling you know now
there's a fraud rule on my card and now you're telling me that I
have to wait you know seven days for it to get mailed to my home match.
I'm not home. I'm in another state. I am somewhere else.
I need and there's no local branches because
I was banking local or whatever. I I need that digital issuance.
That that's a great win for me.
Um I also struggle with like even account
opening for like the teenager accounts.
You know, I I finally had to go to, you know, one of the
P2P platforms because I wasn't liking any of the banking
experiences I was having, trying to make sure that, you
know, my card can my daughter can have a debit card.
Um, but I love that that you're mentioning uh, you know, just
that the the way that we should be forward thinking.
It It's not something to be afraid of as long as we have
the data that's needed and that we approach it in the
beginning ahead of time and not days before release.
But we actually take the time to understand how that technology
works, what it looks like on the the you know issuer side.
Um and if there are any data points that come over from
you know the card carriers of of can they detect a bot
or a uh you know agent that that's using the cards.
Yeah. Risk avoidance is not risk management.
Risk management is being willing to properly assess, have
rationale, make really well-informed decisions, and then
put yourself in a position to tweak and enhance as you
go with how that risk manifests in your environment.
Um, risk avoidance just isn't risk management.
And this is one of those circumstances where I feel like
we were going to be challenged because it's new.
It's something we haven't seen before.
But we need to rise up to the challenge.
And, you know, I'm never going to let the bad guys win.
And I want my consumers to be able to continue to innovate
and bank in the way that works for them.
I feel like that's our job as bankers to learn that and understand
that and figure out a way uh to let to allow our consumers to bank
that they that the way that they want to and state innovation, keep
up with that this is the future like whether we like it or not.
And no, it's it's actually not the future. It's here. Like
Yeah, it's here. It's here. It's here. We're here at Money 2020.
We see it. It's here. It's here. We know the technology is here.
Uh, a final question and then I'll let you get back to it.
I know that uh your schedule's been busy. So has mine.
We kind of I don't know how many steps you put
in yesterday, but I put in quite a bit.
And and my uh my watch is like um is it you or is
someone else cuz you normally don't get you normally
you rarely meet your daily step goal. What are you doing?
Has someone kidnapped you, made you walk.
Um, so my final question for you is what's one thing
you tell a smaller institution trying to build stronger
governance with like limited resources?
So, um, think about risk and controls when you build your process.
Um, because if you think about your risk and controls while you build
your process, um, you won't have to worry about remediation as much.
Um you will be in a much better position
to innovate quickly when you need to.
Because your risk and controls are already in place,
you did them in parallel with your process.
You understand how to tweak and enhance and have everything in
a really good inventory and really good process mapping.
That's something that we do in the large institutions,
but we do it, you know, to the umpteenth million.
And it's a lot more complex than that.
But it's far easier for a small institution when you
have ownership of several areas to to have everything
a lot more inventoried, um and documented.
So that you it's in an organized way so that it makes it so much
easier for for you to act quickly to identify where in the process
something is happening and how that ties to your risk and controls.
So that's a very very nerdy risk management
answer, but that's what I do.
Um, and I've worked at many, many banks
have helping them build that out.
And I know that once that hard work is done and that
foundation is laid, I know how impactful it is.
I love that so much. Angela, thank you again.
You are one of those people that as soon as
I see you, my day gets instantly better.
And having you on the podcast bringing your your infinite
knowledge, seriously, there were several moments where I
was like, gosh dog it, I don't have my notebook here.
Because that was a mic drop moment that she just
had and I didn't want to interrupt our flow.
You guys will know which moments those are.
Um, but I I'm so grateful to you uh and your leadership in the
space, and thanks again for joining me on Fraud Forward.
You're somebody that I just enjoy you allowing me to to use my voice.
You've been an excellent advocate for helping
me share my voice since I started.
You're also an amazing leader in the space.
And girl, you know, you got me on speed dial.
Yeah, that's right. That's right.
I think when I read your title, I was
really most excited to talk to you.
So, I'd love it if you could tell the audience uh a
little bit about your day-to-day like with qualitative
uh quantitative risk and fraud under one roof.
What does that combination let you see
that a pure fraud role wouldn't?
So, that's a great question.
Really, what it allows me to see is how, you know,
modern analytics and mathematics apply to fraud.
And I think a lot of times we look at fraud from more of a
qualitative standpoint when there's so many quantitative factors.
Whether it's velocity of spend patterns, login velocity, there's
so many little quantitative analytics that can be, you
know, used with mathematics to actually find fraud.
Compared to the more traditional quantitative, you
know, qualitative approach that we're used to. So
I think that honestly it's just so interesting because
for me, I'm not a math wiz, okay, at all.
Um I might can help a little bit with algebra, uh but that's it.
Well, I don't go into calculus, all of those things.
And so, when I was even learning how to do a fraud risk assessment,
understanding the math behind it, and how knowing like,
okay, the inherent risk times your, you know, the the
impact or significance will give you that score.
Then knowing, okay, if we look at our control effectiveness,
take away that from the inherent risk, and then
you're left um with that residual risk.
And knowing that you could actually put math behind it to kind of
simplify it, makes things so much more relatable, practical.
Um, so I love that that's your full role. That's really so cool.
I love that GBank has that.
Yeah, it's been phenomenal to actually get to do.
It's works fun every day, obviously. So,
You know, not many people can say that.
Um, when someone asked, "What were our fraud losses last year?
How many different answers could you give
and what decides which one you use? "
You know, that's a great question because that's
part of the problem I feel in fraud, right?
Um, so a lot of times I say there's three different answers.
Uh, you have your first party, you know, your third party
and your unknown, which is the biggest problem in our
industry is especially when it comes to first party.
It can be hard to kind of identify those losses initially
when they look like a normal delinquent portfolio.
So being able to kind of pinpoint those quicker is the
key to our role, you know, because when you are recording
it a quarter later, you know, nobody likes that. So
Um and someone um so I do an industry uh monthly
call each month with uh other practitioners.
And they were talking about uh where they differentiated
like account takeover and account give over.
And I thought that was so interesting that they
were using that as as one of the factors.
And then you know like you're saying where sometimes we
have that unknown of we don't know if they gave it over
we don't know you know we have to make sure that we're
use utilizing the tech we have the tech we have sometimes
we aren't able to properly identify it, you know.
If we are missing that in our tech stack, but being able to really
tie it back to something and then give those numbers.
I think it gives your your organization overall a a different view.
And also helps advocate, right.
For for what's needed as far as resources and tech things.
Yeah. And I think it also shows which resources are working.
You know, if you're able to pinpoint those quicker,
it really shows that the resources you have in
place are doing what they're supposed to.
Which can help them, you know, prove that they
are the right person in the right seat. Right.
We we did a great job hiring this person. They caught it.
And so now we're now we're proving that.
Um so in our benchmark uh 91.
3% of fraud leaders were confident in their loss data. Yet only 45.
8% had channel level numbers that reconciled
within give or take 20% um of their total.
Does that surprise you or does it feel familiar?
You know that's a familiar problem.
So I got to say cuz we're so confident you know in that moment
we're initially reporting numbers and those unknown variables
that's one of the areas where they're going to pop up.
So that does not surprise me here at all.
I also uh know that there's also that that give
and take of like you've got the investigative the
investigation that happened like for a reg. e claim, right.
Um where you know okay this is a loss.
But you're still waiting on Visa to finish their you know 60-day
timeline and your your reg,e timeline was up 45 days.
So you've got a 15-day window where you're sitting and it's showing
like a double negative almost and but you're just waiting
on that credit to come back from the Visa investigation.
So that that sometimes will factor into it as well but I I'm
I'm so appreciative to know that it's Not just me or not
just the ones in the survey that that you see that too.
Um where does the gap come from do you think?
Um scam losses overlapping with channel where money
left digital banking losses showing up under a
P2P or account fraud timing manual reporting.
Which which would you bet on first?
You know scams used to be very basic and with AI how advanced
that they have become I think it's much much more challenging
sometimes to realize what's going on initially.
So that a lot of times leads to that gap.
And I think that just that the industrialized scale that they're
now happening at and attacking our our members, our customers,
it's uh you know, it's an unprecedented time for us
When they have resources close to our level. It's very
Yeah. Um I just recently had a conversation um with Assaf Kipnis.
Um and he said um you know, too often we right
now are trying to use AI to replace people.
Where fraudsters are not doing that.
They're using AI to just become more effective,
but they're still keeping the people.
Like, they're just building on their level set
of what they can do and what's possible.
And so, we've got to stop trying to get rid of our resources,
keep them in house, but then make us more efficient
so that we can do more things, have these better
uh scaled investigations and things like that.
I haven't heard it put better. So,
What's one definition of or data decision
you'd standardize if you could? So loss numbers match across teams?
First party. So first party fraud losses I would say, you know.
That would be a dream. So
Um I totally agree with that. Um okay next question.
Prevented fraud is widely tracked but not always formally reported.
Um and there's no shared definition of fraud ROI.
How would you quantify the fraud that never became a loss?
It's a really good question.
Um you know I would say you know particularly for credit
card portfolios when they hit your application and
it prevents actual customers from coming through.
That's a number a lot of people don't look at.
And that's a significant revenue impact.
You don't see it on the financial statements, but those
type of losses where you're losing actual customers because
if fraud hits, that's something that never gets reported,
which is a huge financial loss for a company. So,
I actually had a CEO tell me one time, he was
like, I need to know an actual number.
Because you you you know, uh whenever we get like
the the debit card losses, it's like, okay, here's
here's the fraud that was prevented.
And the number's like astronomical.
And you're like, "No way that that we prevented all that.
" And it's like, "No, we did.
" Like, but it does seem like a a crazy out of reach item.
But if you can show like, hey, no, this is an actual
dollar amount that was going out that we stopped.
That's a that's a real number that they can hold.
And and can make that, you know, a decision of,
hey, they are actually doing something.
This is not a this is not just an expense department, right?
This is someone that's helping with recovery and um and and where
we're keeping the the funds here or for our members and customers.
That's put so well. It's like being on defense in sports.
Exactly. Exactly. Oh, what is that? Special teams. Whatever.
I'm trying to get better at my my football terminology. Um Okay.
Uh if a fraud leader at a smaller institution wanted more credible
loss numbers this quarter, what's the first thing they should do?
First thing they should do is incorporate AI.
You know, I would say there's so many phenomenal vendors out there
nowadays that that's the really the first step that you have to
take, especially for a smaller institution, whether you're building
your own in-house models or contracting with a vendor.
You know, you're just so far behind that curve
if you want to report accurate numbers. So,
We we've got to become more efficient at what we're doing so that
we can focus our efforts on the things we're supposed to.
Yeah. Actually, I'll give another shout out to someone else.
So John Wingate um wrote a book um Going Agentic just released.
Um and I've I'm reading it now and that's one of the things
he talked about is that hey you know I'm I you hired me as
a decision maker and right now I'm spending 20% of my morning
just clicking a button moving data from this sheet to this
platform to this thing that's not communicating.
And I'm being used as like the the central
hub to to connect these things. I'm the connective tissue.
And that's not what my role should be.
But you need me to make decisions.
You need me to be able to do these things.
So, making sure that like companies are getting their dollars worth
for the expertise that they hire to not be doing the busy work.
And so, bringing on an AI or an agent that can help um you know,
improve some of those things and get things moving quicker.
Totally right. I so agree.
That's put so well because the less time that we're making
decisions, the less effective we are and that we get
further and further behind the curb and fraud moves
so fast that you just you have to be on top of it.
Okay, final question and then I'll let you get back to Money 20/20.
Um, is there anything you wish more people in
our industry measured or stopped measuring?
It's a phenomenal question.
Um, kind of back to my point earlier, I think I wish more people
were measuring the losses of actual customers trying to get in when
fraud is kind of clogging where you're creating too much friction.
A lot of times with applications, you know, that's a financial
loss that never really is reported or looked at.
And I really wish more people were taking a look because if
you can narrow that number, you're doing your job well.
And you're you're showing truly just how great of
a of a department and what an asset you are. So, totally agree.
I Jared, I can't thank you enough.
I know that I kind of uh messaged you last week and was
like, "Hey, would you like to come on a podcast?
" I appreciate you uh taking the chance and joining me today.
I appreciate you. It was phenomenal to be on. So,
Awesome. Okay, that's it.
[Fighters, if you're anything like me, your
list of things to read keeps growing.
Your time to read them though, probably not so much.
That's why I write the Monday fraud fix.
It's the newsletter companion to Fraud Forward.
So, every Monday I'm sharing fraud trends that made me pause,
what I'm reading, conversations happening in our community,
and the fraud fighters that I think you should know.
I also bring my take, you know, what it means for the people
doing this work, and the questions we need to be asking.
Every now and again, I might leave you a
little Scooby snack to start your week.
You know, I just can't help myself.
You can find the Monday fraud fix on Substack or tap
the link in the episode show notes and subscribe.
I'll see you in your inbox, Fraud Fighters. ]
So, Jeni Branter, you are with Royal Credit Union.
Could you tell um the audience since this is your first
time on the podcast, uh what your role is there and
uh you know what it does it look like day-to-day?
Oh man, that's a great question.
So, I am the senior vice president of
payments and digital experiences.
But I've only been the vice president uh or senior
vice president in that role since April. So, every day is different.
Um, there's a many things.
It's the first time this role has existed at Royal Credit Union.
So, I am writing the future.
I have no idea what it looks like, but I'm going to take each
day, grab it by the horns, and do what I need to do.
And what's exciting about that is there's no limit, right?
I can I can build the future the way I think it needs to look,
which means there's no roof that I can't break through.
That is probably one of the best like innovative,
inspiring responses I've ever heard.
Um, and one that gets me really pumped
and jazzed for this conversation.
Because I'll be honest with you, when I was a fraud practitioner at
a credit union, one of my favorite people was the payments leader.
And it was because I was able to go to her, we spoke, I was able
to sit with like her team for the digital check deposit team.
Um we talked through some of their uh processes, things
that they weren't comfortable with as far as like fraud
prevention, went through updated parameters, and by doing
that, she and I then just became like a force.
And working directly with her, it's just one of those
things that like there is there is common ground
between innovation and risk prevention.
And as long as you're working together, magic can happen.
I mean, you can you can be pretty innovative.
Absolutely. You just if you can dream it, you can do it.
You just have to dream it within some level of reality.
So I love to dream the future, give it to my team members,
and then let that let them put the reality around it and say,
"Well, we can do that, but we got to trade off here. " Great.
I don't care. Change my dream. I'm just here to inspire ideas.
I love that. My dream changes all the time.
We were even saying that there's something I could say on
a podcast 3 months ago that I don't agree with anymore.
My mind can change. Change my mind. I'd love that.
That new perspective, it helps you grow.
It helps you learn and it helps you be
a better person in the long run.
Love that. Okay, so I want to dive right on in.
Um, you cover both payments and digital experience.
How do those two seats come together, you know, on fraud?
Yeah, I think that's a great question and and if if we're being
honest, there's a lot of things that happen in the payments arena.
The economy, the industry, it's always changing.
If you don't have someone watching the emerging
tech and payments, you're already behind.
And by doing that, it's easy to understand that the complexity
that continues to grow is all happening in digital.
So, they have to be partners.
And if they aren't partnering, then you're missing the point
of that's where you can interdict and stop your membership,
stop your client from harm before it happens.
Recovery is so much worse.
I've I've also been told that uh the the dollar prevented is uh
you know much less expensive than than the dollar recovered.
It is. In, not just in in words, in theory.
Um but it's also your reputation.
So true. So true. I love being on the the prevention side.
You know, it's easier to explain uh that my my very
good friend Jeff Taylor at Region's Bank.
Says, "It's easier to explain a five minute phone
call than it is a million-dollar loss. "
And it's their financial health and well-being,
and that's what we're here for.
So, what scams are members most likely
to run into in digital banking?
Yeah. So, we have a couple of them that we see.
Um, and it's it's may not originate in digital banking,
but it's carried out in digital banking.
And unfortunately, it's the romance scams.
It is heartbreaking to watch how in love
they are, and they truly believe it.
And the other thing that we have seen is the human interaction.
So the phone call or the text followed by a phone
call claiming to be a representative of a royal.
And our members unfortunately sometimes fall for it.
Yeah. Yeah. I I hate when that happens.
We've had several conversations uh with other practitioners
that are in the the space, and we also do a uh monthly
fraud call with uh credit unions and community banks.
Where that is one of the things that are the most prevalent
right now, is the uh bank impersonation scams.
Where literally we had one instance where someone came into the
branch because they were told they needed to do an investigation on
a teller that they assumed was stealing money or something like that.
And so as thinking that they were helping the financial
institution because of a call that was prompted from the
scammer, they then withdrew $20,000 out of their account
and then put it in a bag and put it in a parked car
in the parking lot of the financial institution.
And and it was all because, again it wasn't one of
those things that necessarily happened on digital,
but those scams are so prolific right now.
And it's really hard to get in front of when when we're not,
you know, we're so focused on that member experience, but
we're forgetting about what the aftermath looks like.
What's that experience like for the member?
It's so much worse to have to try to help them recover because they
were already vulnerable and they then they're embarrassed.
I've had people come into the office,
look at me, and they're in tears.
Uh because they just can't believe they
were that vulnerable and fell for it.
That is so much harder to recover from than maybe
making them a little uncomfortable up front.
So in our survey that we just recently launched uh it was a broad
uh benchmarking report for community banks and credit unions uh 50.
6% uh named that account takeover was a top threat.
And digital banking is what fraud teams support most.
We had 86% of fraud teams say that they support digital banking.
Yes, I think all of that is true first of all.
So I want to validate the outcomes that you're looking at.
Um, I think that's accurate.
And there's a couple of different ways you need to to look at that.
There's analytics after the fact where you're looking
for, yeah, I think something might have happened.
We better get involved now.
But really, if you're not looking at propensity in the front and
you're not educating along the way, you're not talking to your
business members and knowing them really well, you are missing an
opportunity to make sure that we have some gateways in place.
And and I, this is going to sound a little
difficult, a little painful.
But when you're working with businesses that are potential
for account takeover, it can it can sink a business.
So, make sure you have contracts that require
them to also have security in place.
It is not one-sided when it comes to that. They can't use Gmail
And never change their password and make it not secure and
expect that other people are gonna cover that for them.
So you have to have airtight security.
You have to require them to be secure.
And then hold them to it, unfortunately.
And it sounds it sounds a little difficult but it's the
right thing to do because when they suffer those losses
it's on the back of everyone else that banks.
I'll tell you, um I I always love to, uh relate and give practical
advice or or put it back into real world experiences.
And I think it just goes just it's just like with our children.
That tough love is for a reason.
It is like I know you don't want to listen to me.
I know you don't want me to have life 360 on your phone and
all these things, these apps that I'm blocking from your phone
that all the other friends get to have, like Snapchat you're
never going to have till you move out of my house.
Um, but I do that for a reason and it's to protect
you, to make you not be a statistic.
And one day you will appreciate it.
It may not be today, but it's a it's a hard tough love conversation
that I'm okay having with you, because I want to protect you.
And I think that we've got to move to that role.
No, I don't think that we need to treat our members like children.
But I do think that we need to respect
them enough to explain the why.
And and let them know that, hey, this
is this is why we're doing it.
Here's why we think that it's important to do this way.
And if you're welcome to tell us why you disagree with us,
but in the end, we have to make that decision of we will
not knowingly participate in fraudulent activity.
We have to have protocols and we have to then provide them the tools
to self-service some of that um so that they are the master of their
own destiny and so that is that is some of our focus and a lot
of we actually do some joint educational things for that.
Yeah, I was actually just about to ask that.
You know, uh again, another stat is that 67.
7% name scams as the most pressing threat for any fraud program.
Um how do you help your members spot them?
Yeah, I think that is a great question and um I don't
know that anybody's doing it amazingly well, but I think
we're taking Yeah, I think we're taking stride.
We are, but you know, you can't um you can't
protect people from themselves sometimes.
So all we can do is invite them to the table.
So our fraud team has started doing some joint um educational
sessions and and things where they invite our business teams, our
business members, our business clients in to learn about fraud with them.
They talk about it openly. It's a forum.
It's a free forum where they can come and just have a discussion with
the people that can help teach them what they need to know.
Um so that's one thing that we do.
But I think that and I already talked a little about
contracting but then it's having the tools.
So it's extending the olive branch enough that we have
given them ample opportunity to help themselves.
Um because that's ultimately what most people want.
They don't want you to have to do it for
them, especially if they're smaller.
Yeah. No. So true. So true.
And I love that you brought up the the solution or tool piece.
Um you know, when extra funding is available, 60.
4% uh choose technology first.
Um and member education was a priority
for very few in the in the survey.
How do you weigh technology against like education or resources
that can can help with that prevention side?
I think that it is there is a balance and you have to
strike it and it's not always going to be equal.
Um, and it might depend on what's happening at the time, but I
think that realistically, unless the technology is going to be
trans or excuse me, going to be invisible to your membership
or your client, you can't do technology without education.
So, you need to have at least an equal
amount of effort if not investment.
And um, some of that's just helping them
understand this is what we do. This is what we offer.
It's maybe it's not that they have to do something, but now
they have awareness of what we're using to protect them.
After all, they choose their financial
institution to be a trusted adviser.
They're not coming to me and giving me money
because they think I'm going to lose it.
They are expecting and trusting me to do what's right for them.
So why wouldn't I tell them what it is?
So I don't always think that dollars is the investment.
It might be human resource that's the investment.
And that's where we choose to use it.
Um, also comes with the the people helping
people mindset of credit unions.
I also have to uh point back to core values.
Look at what your organization says is a core value.
And whenever you notice that it's putting that person first,
that's that's all the ammunition you need to to go to your
executives and say, Look, there's more that can be done.
I'm not asking for more dollars, but I am asking
for for additional time that that I can dedicate
to doing this one particular function.
Um, and if there's something that we need to move
within a department until, you know, we get that
additional coverage, let's let's do that.
Let's help make sure that we're prioritizing based
on what we said are our core missions.
And I think, you know, some of what we've done is we've we've
implemented self-service education opportunities as well.
Let them serve themselves when it's important to them to serve
themselves, but have it available and easy to find.
Um, so yeah, I I'm with you.
And that is 100% the heart of what we do as a credit union is making
sure that we've enabled people's financial health and well-being.
Um, uh, how do you tell the story, uh, of a digital
experience that's both easy and safe?
Oh, that's difficult, but let's talk about it.
So, a digital experience that's both easy and safe.
I think there is a lot of invisible work happening.
Invisible hands, let's call them, happening behind
the scenes that are doing a lot of verifications. Right.
There's probably some AI intelligence that's
out there looking at is this accurate? Does it is it uh real?
I've learned so much today at this uh at Money 20/20 for the
companies that are doing things that I'm not there yet.
And I'm thinking, "Oh my gosh, that's a great idea.
" But it's that invisible validation because what
you want to do, I don't promote no friction,
I promote intentional friction.
So, as long as those underlying technologies and invisible
technologies can do validation well and feel confident, number
one, that there's a propensity to not be a bad actor, to not fall
behind, not be fall for a scam, whatever the case may be.
And they are who they say they are.
Let let it flow where it needs to flow.
And when we get to the point where it's like, well, I'm
not I'm starting to question this as a relationship.
And you can't just look at digital banking, by the way.
You better be looking across your entire relationship.
And when it starts to flag that, oh, there's a signal
here that doesn't match with this other one.
Introduce intentional friction.
I would much rather, as you said earlier, have that moment
of explaining why I introduced that and made them jump through
a hoop, than help them recover their money later.
I I think one of my uh favorite experiences as a fraud
practitioner was uh we were onboarding a new product or
we were talking about the member-tomember transfers uh
that happen in uh digital banking or online banking and
which I'll tell you that's a big hole for some.
Uh you know because it's like oh there's we don't
need any uh any thresholds there because they're
just transferring to another member.
And it's like uh we need us some um and I remember you know we had
an operating officer who was like oh So like we don't need a
threshold like if they're going member to member we already know
that this is a valid member they've got to have the member number
and the share number and if they have all that like surely they must know.
Well in you know next meeting we had our CEO go, I have a question.
I was paying someone uh a contractor for a service that
they did you know corn concrete or something.
And he said and I went to do a member transfer for $15,000.
Why didn't I get a step up question, why did that happen so easily?
And I was like, I think that's a very valid question.
Meanwhile, you know, my the product team was like, uh, that's
what we were told, like member to member, no issues.
And so being able to prove that like no, some friction is okay.
Like because also it lets people know like,
hey, we're watching your finances for you.
Like we're not watching every single transaction you do.
We're not looking at you as a person, but we are looking
at the the transaction that come through.
We've got our alert systems.
We've got our, you know, transaction monitoring, things like that
that are going to let us know when there are some, you know,
an some different behavior that we haven't seen before.
And so when we see those, we should require a step up.
Or we should require some additional form of authentication
that says, are you sure that this is you and
that you know where the funds are going?
Like you are so sure that it's your, you know, uh, the
person who you're paying the contractor service to.
Or is it somebody that you know in sent text message,
hey, new phone, this is where I need you to send it.
You you don't know those things.
So, making sure 100% that we have the best interest
of our members in in place first.
And then know that there is a way to be
innovative while still protecting.
And I know like to get to the heart of what you're speaking of,
I know we're working towards and we have some of it accomplished,
but there's still so much to do and it'll never be done.
Um working towards kind of looking at that relationship and
saying, you know, do they qualify for this service?
And if they do, how much do they qualify for?
And if they qualify for a limit, how fast will I let them move it?
And and that's the model we're employing so that you might not get
the same limit as I might get, but it's based off of a risk risk model.
Um and it's it's logical, right?
And it's repeatable and it's testable.
I love that. I also totally agree.
I mean, if your average account balance is sitting at less than
$1,000, why in the world do you have a daily limit of $25,000?
You can't cover that. Don't do that. Totally agree.
Uh, I have a final question for you and then I promise I'll let you
go because I know that we're just so busy here at Money 20/20.
What is one thing a credit union can do this
year to protect members in digital banking?
Oh, one thing they can do this year is to stop, and be intentional
about how they orchestrate things, about who they allow
into things, and about how they move the money, how
they transfer the money, how they remit it.
So think about least cost, least risk, right?
The member cares about just in time delivery.
They don't care about I used a wire, I used a P2P.
There are time and a place for all of that.
But be intentional so that you are covering your
risk because there we're all imperfect.
Members are going to make mistakes and you know what? We are too.
And technology doesn't catch everything. So be intentional.
That's the biggest message I have.
Jeni, thank you so much for joining me on the podcast.
I I hope that this is not the last time that we interact.
I look forward to, you know, continuing
to uh collaborate with you hopefully.
Um and again, just thank you so much for
taking the time out of your day.
Yeah, thank you for inviting me.
Before uh you know, we dive in, I'd love it if you
just give a quick uh intro to uh the audience.
You know, this is your first time, like you said, on the podcast,
but I want them to know kind of the magic behind the man.
All right. So, uh my name is Aaron Frye.
I am the founder CEO of Lucid Point Consulting.
Uh we specialize in fraud risk management related consulting services.
Um we also offer sales related consulting for
solution providers of anti-fraud tools.
So I come from the industry experience.
Uh worked in fraud risk at G Capital Sunrust
Bank before they were Truest.
BBVA USA PNC Bank and a payment processor called Swivel.
I've seen a lot and I wanted to take a leap of faith to
launch a honest uh consulting firm in fraud risk.
Um glad that we've gotten to uh meet several times and had uh those
good candid conversations that you know happen at conferences.
Um but now we're going to bring some of that uh to the audience. So
Um you actually came to me with this idea at
the last conver conference that we were at.
Um and it was about the foundation of the unknown.
Or like fighting fraud on a foundation of unknown.
And so I'd love to know what does that mean to you?
Well, to me it's kind of like the the the name
of this podcast around Fraud Forward.
Um, from the industry experience, everyone
wants to always look to the future. What do we want to stop next?
What I noticed was there's a huge gap in actually understanding
what were the gaps we had before we try to move forward.
You know, always trying to build without fixing first.
And so again, I just recognize there's an opportunity to really
communicate in this industry that sometimes you need to take a moment
to really fix what you have to make sure when you do move forward,
you're actually going forward with the right foundation and
not with the continued gaps or issues we have today.
I think you and I are drinking the same Kool-Aid.
Um, we just released the fraud benchmark report for credit
unions and community banks and I'll tell you that's one
of the things that I I've taken away is truly we cannot
think, oh, the next thing we have to do is buy a piece
of tech and it's going to fix all our problems.
No, you need to first understand like your infrastructure,
what works around your own organization.
Don't just think about a fraud process, but think about the
overall process, how something works, and then look to, you
know, you've got process efficiencies that that can happen,
but also making sure that like the vendors are are doing
what they promised they would do, holding up their end.
I mean, go back and read an agreement that you have on a vendor.
You'd be surprised what they're not doing.
I mean, essentially looking at vendor agreements,
what's not there enough is legit accountability.
Usually the service level agreement type information and saying that
we'll respond by a certain time and system uptime requirements.
That is the basic check marks of having a quote unquote good
vendor from a third party vendor management perspective.
How do we make sure they're actually delivering on what was
promised on that proof of concept or that proof of value.
Um those should be strong questions that should be
there and also most importantly understanding that
fourth party risk within the third party vendor.
What is being utilized and what's touching your customers?
Is it their homegrown solution or is it another contract
or service that's not outlined in the contract?
I think too many times financial institutions
have been bit by that exact uh scenario.
So it's super important to make sure that you are looking
at those and again just go back to the basics, right.
Of trying to understand why why did we
get this vendor in the first place? Why did we get this solution?
Why did we turn on this payment uh service?
And then when you understand that and understand
what it was supposed to be in the dream world
whenever you uh launched it, did it meet it?
Did it meet what you thought it would?
And if not, let's let's go back to the drawing
board or at least try to fix it.
I mean, essentially what you're talking about is what was
that governance and expectations to be documented before we
made this decision that's supposed to impact our first line
of defense from a strategy operations perspective.
Uh there's so much there in that second line of
defense, what fraud governance should be.
And from my industry experience, uh the stronger the second line of
defense, the less chaos there is in the first line of defense.
So some of the stats from our uh recent
benchmark report are that uh 52. 4% use a hybrid model and 42.
7 have a fully centralized fraud program.
Um and that structure alone, you know, what we found is that
structure alone doesn't tell whether a program works.
So, I'd like to ask, you know, when nobody owns a fraud risk in
the first line, what does that look like in a real incident?
What does it look like when no one owns fraud in the first line?
Um, it turns into a lot of fingerpointing internally.
Um, someone wants to say, oh, that's operations fault or no,
that was AML's fault or that was cyber security's fault.
Uh, so, you know, it's it no one wants to
be able to say and own up to fraud risk.
And honestly, fraud risk is by far, I might be a little
biased, but it's the most complicated risk to manage.
Because there's literally no blueprint
for success on the structure of it.
Every other adjacent cyber security, AML, there's some type of
guidance and regulation structure to have you be successful.
Um, so when you start to have such a free-for-all,
a lot of people don't even want to own the risk.
It's why fraud risk is always being transferred from leader
to leader like every 3 to 5 years at some organizations.
It'll be under cyber security this year, operations the next year,
maybe AML the next year, uh maybe legal sometimes or or audit
will own it depending on the size of your organization.
And that's why fraud is so inconsistently managed.
Is how you can tell a lot of people do not own
it or understand who should own it or why.
I'm so glad that you just brought that up.
Um and so we we talk about um you know,
second line and is it missing? Is it not enough?
Um, and so the question I have for you is what
should a second line actually do for fraud and
what does we have one on paper look like?
Okay, so roles and responsibilities for the second line of defense.
Let's start off with at minimum they should
be managing policies and procedures.
They should be performing the gap assessments to say hey is the
first line of defense doing this properly from a strategy perspective,
rules change perspective, operations as well.
Um how do we determine is this a good vendor or not to want to take
time to measure to say hey are we getting the ROI analysis using
these vendors the right way right um those just the beginning I mean
having the change management most importantly building out the
requirements uh needed from other adjacent functions from customer
experience, your line your product uh your product owners line
of business leaders as well to say hey if we're going to make
changes in a fraud strategy what's that impact going to be.
They should be documenting what's required from
vendors to come in even do an RFP process.
They should be able to say did they do a
demo with the right end users involved. Where's the proof of value?
Did it make sense or proof of concept? Did that make sense?
Um, and importantly too, are we changing this out just based off cost?
If you're looking at cost, then you should understand that you're
actually doing a one for one change in the rules and configurations.
Like what are you actually swapping out outside of the cost?
That's just the beginning of what the second
line of defense should be doing.
It would look great on paper, but most importantly able to have
consistent communication with the first line of defense, some kind
of cadence as well to report out to other adjacent functions.
Um from operations, from cyber security, from AML.
How are you making sure that the fraud group is in
communication with them um at the right time.
Because they should be separate in my opinion, but they
should work together consistently at the same time.
I think that that's one of the things that
we we forget is a is a superpower.
Doesn't cost any extra money to build that internal relationship
to to make sure that that you have this consistent approach.
And even just a a friendly person to bounce ideas off of in
that other department where it's like you know Nyla Cortes
and I were talking about that earlier where you know as the
BSA person they have their roles and responsibility as far
as like when something happens when they're alerted to something
and fraud's responsibilities look completely different
when they are alerted on the same transaction.
But how do you make sure that one you're not doing double work
and two that what you're doing it it complies with the regs,
it follows policy, it follows protocol and the procedures and
is being applied consistently across the organization.
Um so my question to you is like what um how do you challenge a
fraud program if you don't outright own it in an organization?
Well, one you got to build a relationship with the person to say like
hey we care about fraud as well even though we don't own you.
Um I think that establishment has to be there first just internally.
Uh second, you're going to be able to say, "Hey, you know, like
is there anything else that you feel like you're missing?
" Like asking the honest question and hopefully the leadership has
the humility to admit what they feel like they don't know.
Um and being able to document that in some type of like self-identified
issued manner to be able to say, "Hey, like what do you need
and what can we do to partner with you to close these gaps?
Um whether sometimes sometimes funding is just the biggest gap where
like, hey, I don't own fraud, but fraud doesn't have a great budget.
59:17 Is there anything that we can do to help our
business grow if we help protect the fraud group?
" You know, understanding that commonality of like,
hey, my line of business wants to grow.
Fraud's going to technically slow us down, but they're
going to help us slow down with integrity.
And are you achieving the same goals?
And that's how you get the challenge, but become
a partner at the same time, I think.
Thinking about the overall organization, not just a one
new pattern or or payment method, but being able to say,
Hey, yeah, no, let's make sure we're protecting it.
Bring them on early enough that if they don't put up the the
blocks or the the holds and like we're supposed to go live on
Monday but you tell them on Thursday the week before it's not
going to work out and they are going to be the bad guy.
Tell them what you're wanting and again become
a partner versus um you know an enemy.
And again at the end of the day fraud group is just literally trying
to help you grow with integrity and reduce the amount of chargebacks
amount of the money movement going back and forth.
It's going to save you a lot of money operationally as well
when fraud is able to do their job well most importantly.
So um I'm going to give some more stats
uh from the benchmark report.
So most teams run several tools uh you know 73.
2 have enterprise fraud program.
72% Have core card processor tools. 64.
6 Have corebased monitoring. 62. 2 Have case management.
84% Are satisfied with their technology. Yet 62.
3% site false positives and 45% site poor core integration
and we also have the issue of tracking those false
positives versus reporting on those false.
Um but why do you think teams um shop for a replacement
before mapping what the old tools were doing?
Uh I think what always happens is that you know you need a change.
And someone just thinks well to change we need something new.
And the only thought process is go find something new.
And also it's efficient to just go look for someone new.
It doesn't mean it's accurate or the best way to do it.
Um and it takes time to go and also do you have the right
resources and the right capacity to take time to look
back and say hey what is wrong what we have today to set
that foundation before we go find the right one.
I mean, I think one of the biggest challenges uh that
continues to happen in the industry is not building
requirements before you go select a vendor.
That always happens. Everyone's like, All right, we need a new vendor.
Let's bring up three or four of them, see what they can do, what's
their pricing look like, what's the volume going to potentially
be, but you haven't built out the requirements yet.
And also, a lot of vendors are not in a position to help pull out the
right requirements out of their clients in advance because you're
expecting your client to understand what their requirements should be.
Um, so I think companies just do not for some reason do want
to take the time and be a little bit patient to build out
the requirements in advance and then go to the market
and see who's out there from a vendor perspective.
I love the idea of building a non-negotiable list.
Of this is what we will not budge on. It has to do XYZ.
It must not do XYZ and it must meet this whatever
you know thresholds we put in place. I think that's great.
So we're going to build out a list of requirements.
They can be our non-negotiables.
And from that, don't don't deviate.
Stick to it. You know what you want.
There are providers that can do it.
Don't settle because someone looks like the shiny new toy.
Yeah. Um, how do you um inventory gap?
So, when you're running multiple um anti-fraud tools?
Oh, this this this is a fun one.
Um just if if if each vendor claims that what they're doing, make
that long list of configurations and attributes of what they
can actually see and detect in their rules oper uh the rules
opportunity and what the scoring looks like in a summary.
If if a which is why more companies need a fraud
vendor management function, a group that is just
focused on just fraud vendors for your fraud.
You cannot rely on vendor management functions
because they don't know fraud.
So, you need someone in the fraud strategy or fraud governance,
however you want to layer it, but put them in a fraud
uh organization and say, Hey, how are we going to
evaluate each vendor side by side we have today?
That way, um you're able to say from a waterfall effect, if
you do hit the next vendor in this process or within your model,
what is the open gap that they're still not covering, especially
if you want to change out that vendor as well.
I love that you brought that up, bringing in that third
party, someone that can help if or if it's an internal
team that is your fraud um uh vendor management.
What I experienced in my time as a you know community banker and
credit union practitioner was we often times we had the C suite
level executives, hey, here's our top three vendors that we chose.
Here's what we want and then we demo them.
We go through that whole process.
But I can remember being again the lone wolf
fraud fighter going, Wait, wait, wait.
They're not even offering a fraud solution.
Like, Yeah, we're we're trying to update our our
processor, but you've got one that is offering
fraud monitoring on top of the processing. This one's not.
What are we're not comparing apples to
apples here like I don't understand.
So, that was a struggle for me and knowing that I was the only
one advocating for that or the only one that noticed it.
Like imagine I'd have been out that day or sick that day,
you know, and and then there was nobody that that would
have seen that or would have called that out.
So, I think it's super important to have someone like that
that if you are looking to have payments updated or a
fraud solution, bring in somebody that knows it, that
can ask the questions of, Hey, I've been there.
I've I've seen where these agreements,
they look really nice and shiny.
So, there's a little teeny tiny, you know, writing down there, but
you need to make sure you understand that whenever, you know,
they allow a certain payment, the liability shifts to you.
Have you read that fully?
Like just because they're just because they're a solution
provider doesn't mean they're going to accept the risk.
And especially having those type of like um accountability
performance checks like they have in that.
I mean, not I I I did this once and you know, sadly, it was a
fourth party vendor that we did not know was a part of the solution
that was touching our customers at a FI worked at.
They literally had all of our customers fall through the funnel
during a marketing campaign for a lending product.
And all of a sudden, all they said was, “Oh, sorry.
That fourth party vendor made a mistake. They've corrected it.
Now, we we refund you the inquiries. Have a nice day.
" Now, you have a very upset product owner that's
like, "Hey, I just lost all these applications.
Where's my potential revenue loss fee of some sort?
" So like adding in that tough language uh to redline your contracts
or adding it to new ones, it will help hold vendors really accountable
and understand like hey this tool better be on point.
Not just for that customer but for all of our customers as a whole.
Which overall helps the vendor's reputational risk as a whole as well.
To be able to be that flexible and work with your legal group to be
okay with that kind of language that's not too common to find.
Yeah. Oh so true. I love it.
Like I feel like I'm the practitioner again.
I'm like I need my notebook because I got to write that down.
Um you know if you had you know thinking of everything we've just
talked about, if you had one week um to audit your own program.
Fraud governance function I would say do we have first
of all do we do we have a fraud governance function
does it actually sit in the fraud function.
Because sometimes I've seen fraud governance groups sit outside of
the actual fraud function and I'm like there's no way a governance
group can manage fraud fraud, AML, ops, risk, all in one.
That's impossible to do well. So, do you have a fraud?
I love that you just said that. Impossible to do well. Correct.
You can do it, but it won't. There's no way if your focus is not fraud.
If your title doesn't start with fraud, there's
no way your focus is only on fraud.
So, do we have a fraud governance function?
Are they in our fraud actual governance function,
our fraud strategy group as a whole?
And then, what are they doing to really hold people accountable?
And is there a documented some form of self-identified issue list
that they've already developed to to have proof that they're evaluating
and finding gaps and improvements in the first line?
That's what I would do first is like, hey, where's where's that
self-identified issues list that came from our second line of defense?
That would be one of the first things I’d do first in our program.
And that's if you're auditing your program
that you've had established.
Now, I'm going to flip it and say, um, you know, what would
you do in your first 30 days walking into a program?
Um, in which role? First line, second line.
First 30 days is where's my rep repository of policies procedures?
Um do we have updates on how often they've been refreshed?
And also what's our policy look like as a whole?
Like the overall program fraud policy.
Are we including internal fraud in that policy as well?
Um and are we able to classify what's deemed um high critical risk
anti-fraud vendor as well in our policy and how they're evaluated
differently than the day-to-day regular vendors within the fraud strategy.
Um those are the things I would look for first the first 30 days.
Um cuz it's going to answer a lot of other questions.
And then the other aspect within fraud governance is
uh what is our fraud risk appetite if we have one?
And then how is it measured and is it telling the right story?
For the record, everyone should go and ask themselves
what is our fraud risk appetite.
Um and if you don't have one, if it's
not documented, I this is your sign. Go do that.
And when you do it, ask yourself, is it telling the right story?
And most importantly, what audience is seeing the
results of this risk risk appetite reporting.
Well, now I'm curious though, what would you
do in your first 30 days for First Line?
From First Line, I would take a inventory of our anti-fraud
vendors and each each process they're in. Hopefully, it's documented.
Um, and then I would just ask the end users from operation leader
and strategy and say, "Hey, how do you like this vendor?
Um, I think you'd be surprised how many answers are
sitting with the end user from a fraud ops perspective
or fraud strategy perspective for analytics.
They they have all the answers about do they like this tool or not.
Sometimes they've been stuck with a tool longer than expected.
And they're just on BAU like hey I've been told to use
this tool and they didn't want to change it or they
didn't have budget for a new vendor at the time.
I would sit with them to really understand
what are all the issues you have today.
That's that's making your life harder or
not helping us do better at our jobs.
So, our takeaways are before buying a tool, answer who
owns the risk, who challenges it, uh what the current
tools actually cover, and what you're measuring.
Um, and and I love that because it it also kind of matches
a little bit of uh what the report says, which is
don't automatically add another platform, right?
Look and see what you have.
Make sure that it's working the way you thought it would.
And if it's not, let's document. Let's make some changes.
Let's make a plan. Prioritize with your leadership.
Um and and then go from there.
Exactly. Just getting a a strategic phased approach.
And also know like if a fraud ring pops up in the middle of your
phased approach, how do you pivot and also get back on track?
Cuz usually when you have a phased approach, something goes wrong.
Oh, you're going to get derailed.
Yeah. No fraud, no fraud program can ever operate comfortably.
It's literally No good deed goes unpunished. Okay.
Thank you so much for joining me uh today on the podcast.
I definitely want to have you back because I want to
talk a little bit more about strategy with you.
You've got my you've got my gears turning.
I've just done uh two presentations recently on fraud risk
assessments and I kind of want to dive into it with you.
So, I think this is either going to
be a webinar or another podcast.
That sounds like a plan to me and there's
a lot we can talk about in fraud. That's for sure.
I'm excited for the next one.
Well, thank you again so much for joining me
and for, you know, attending Money 20/20. It's kind of big here.
Absolutely. Thank you for having me.
It's It's been a long time coming, so
I'm glad we got to finally do this.
Thanks for listening to Fraud Forward.
Remember, every conversation, every connection, and every insight
moves our industry one step closer to stronger fraud defenses.
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it with your team or tag me on LinkedIn.
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Until next time, stay curious, stay resilient,
keep moving fraud forward.