We are in the process of setting up Card Valet for our customers so they can control when, where and how their debit cards are used on their cell phones. Right now we are in the phase of going thru each committee to get the process approved. I was just curious as to what we can expect from the compliance side of things with this product. Curious if anyone else is using the product or one like it and if so how does it affect compliance and how should we as the compliance department prepare for the product? Any help/information is appreciated.

Thanks,
Lisa

Lisa:
We are also taking a high-level look at the Card Valet product and have not identified any compliance concerns YET. It's still early in our discussions, sop the only issues relating compliance have been on the marketing side with advertisements. The most pressing concern of the moment seems to center around adoption rates and will people actually use it once they've enrolled or downloaded the app. Or will the usage fizzle out as time goes by. Let's stay in touch.

Thank you - I appreciate your reply back. Yes - lets please try to stay in touch. The product was presented to our compliance committee yesterday and is currently on hold until we hear back from our representative at Wolters Kluwer regarding how this may impact us on the compliance side. I agree that marketing the product may be the biggest area relating to compliance. I also agree that there may be a concern of how quickly the usage will fizzle. I can see this happening with many people - as I'm notorious for downloading an app because it's the next great thing - and then never using it again.

From a compliance risk perspective, don't let any member of management get any ideas about trying to increase a cardholder liability for a lost or stolen card for failing to use Card Valet. I still have two business days to notify you of a lost or stolen card even if I have downloaded the app.

I could see someone who is trying to minimize fraud losses try telling a customer that they are liable for transactions over the weekend for failing to turn their card off sooner.

We have had Card Valet since July. We did not identify any compliance issues, as we are utilizing Fiserv's marketing tools and as Brian posted we are not promoting this to shift losses or force our cardholders to download it. While we are trying to promote the use of it when customer's come in to dispute charges, it is mainly to inform them that we have a tool they can use to monitor their usage better. I will say our adoption rate is not that great and actually most of the users are using it to alert themselves instead of setting controls to actually block transactions. Because it is not our actual app we are not marketing it with big blasts of emails or mailings since it is really Fiserv's app.

Do you know if the app interacts with any of the current scoring tools that we are using to predict fraudulent debit use? We are relying on contacting customers to confirm that their card is in their possession, but utilizing an app to contact would appear to be more efficient.

At this time the app does not interact with the current enfact, Tranblocker, and Rule Manager rules or any of the cases created in Case Tracker. In the line of rules and checks Card Valet rules are the last before a transaction is approved. So obviously you have your normal checking for expiration date and CVV values then it checks for enfact scoring, Tranblocker rules, then Rule Manager rules then the last check in a whole line is Card Valet rules. So if you have a rule setup in Rule Manager that denies, it does not even get to the point to check for any rules in Card Valet.