Letter to the Agencies on the RFI re: Potential Actions to Address Payments Fraud

The American Bankers Association (ABA) appreciates the opportunity to respond to the Request for Information (RFI) regarding potential actions to address payments fraud. The growing prevalence and sophistication of fraud in today's financial ecosystem underscore the urgency of this inquiry and the need for coordinated efforts between the Office of the Comptroller of the Currency, the U.S. Department of the Treasury, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the "Agencies").

ABA and its member institutions are committed to working collaboratively with the Agencies to advance meaningful solutions that protect consumers, businesses, and financial institutions from fraud across all payment channels—including check, ACH, wire, and instant payments. To that end, we believe the following foundational principles will be critical to achieving this shared goal:

• Formal collaboration between the banking agencies and other authorities, alongside other industry stakeholders through dedicated working groups and advisory forums.
• Establishment of a White House Federal Office of Fraud and Scam Prevention to coordinate a national strategy, promote cross-sector data sharing, and ensure public-private engagement on prevention.
• Clarification and consistent application of regulatory standards to ensure transparency, accountability, and uniform enforcement across all the industries throughout the scam ecosystem.

In support of this RFI, ABA engaged with member banks of varying sizes and operational profiles to gather insights and perspectives on the questions posed by the Agencies. This collaborative effort informed the discussion that follows and reflects both ABA's position and the collective input of its member institutions. The responses aim to provide practical, industry-informed recommendations to help shape effective and sustainable fraud mitigation strategies.

This response to the Request for Information (RFI) provides a series of recommendations designed to strengthen the nation's fraud prevention strategy.

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