The U.S. Chamber of Commerce (“Chamber”) Center for Capital Markets Competitiveness submits these comments in response to the joint request for information from the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (“Agencies”) entitled Potential Actions to Address Payments Fraud (“Proposal”).
The Chamber is committed to protecting consumers and businesses from fraud and scams. Preserving the integrity of the payment ecosystem is essential to maintaining public trust, ensuring financial stability, and fostering long-term economic growth.
Payment fraud and scams, driven by illegal acts perpetrated by bad actors, present an escalating threat to consumers, national security, and the broader economy. These crimes erode trust in financial systems, disrupt legitimate commerce, and impose disproportionate costs on consumers, businesses, and financial institutions. The Chamber strongly supports the Agencies’ efforts to develop a strategic and coordinated framework to deter criminal behavior while fostering innovation and efficiency across payment channels.
To effectively combat payments fraud and scams, a unified national strategy is essential. This strategy must mobilize the expertise and resources of banks, payment processors, technology providers, communications platforms, federal/state/local law enforcement, regulators, and consumer advocates. Given the increasing prevalence of criminal activity, there is no single sector that can combat fraud and scams alone. By fostering a cross-sector, whole-of-ecosystem approach, policymakers and stakeholders can strengthen defenses, protect consumers, and preserve trust in the U.S. payments system. Such sustained and structured collaboration will ensure the payments ecosystem stays ahead of evolving threats while maintaining the speed, convenience, and innovation that consumers and businesses expect in the digital economy.
This initiative must remain focused on combating the unlawful actions of bad actors, rather than imposing additional regulatory burdens or liability on the financial sector, who are heavily invested in helping consumers protect themselves and their investments. Financial institutions, on behalf of their customers and consumers nationwide, are actively engaged in efforts to protect the integrity of the payment ecosystem. A successful framework must prioritize enforcement against criminals and support wholistic collaborative solutions that strengthen defenses earlier in the chain of illicit activity, before harmful consumer financial transactions may even occur.
