To Whom It May Concern,
The Bank Policy Institute[1] appreciates the opportunity to respond to the Request for Information on Potential Actions to Address Payments Fraud (the RFI).[2] Fraud risk management is an important priority for all financial services providers and a concern for their customers. The Bank Policy Institute, through its technology policy division BITS, has been working with banks and government stakeholders for nearly three decades to help combat fraud. Examples of BPI-led initiatives include hosting executive forums to discuss fraud trends and threats, sharing effective practices for combatting fraud, partnering with the Financial Services Information Sharing and Analysis Center (FS-ISAC) and National Cyber Forensics and Training Alliance (NCFTA) to enhance fraud intelligence services, and engaging directly with other industries to enhance protections.
The fraud threat landscape has shifted in recent years. According to the FBI’s Internet Crime Complaint Center (IC3), Americans reported fraud losses exceeding $16 billion in 2024, more than double the losses reported just three years earlier.[3] Financial institutions and their customers are facing increasingly diverse threats, including check fraud, sophisticated impersonations, authorized payment scams, account takeovers, and synthetic identity fraud.
Banks continue to invest in advanced fraud prevention technologies, including machine learning and artificial intelligence, to detect and disrupt these attacks. Yet the same emerging technologies are being weaponized by criminals to automate phishing campaigns, spoof communications, generate deepfake audio and video, forge documents, and mimic identities to bypass verification. These factors combined with the widespread availability of stolen personal and financial data are further fueling scams, account takeovers, fake account creation, and identity theft.
This rapidly changing environment demands flexible supervisory and policy frameworks that allow institutions to respond to real world threats as they evolve. Banks need the ability to deploy real-time, risk based interventions; obtain and share data across industries; and adapt to new fraud typologies without being constrained by outdated regulatory requirements or rigid compliance models. The regulatory framework should be updated to enable financial institutions to proactively protect consumers, focusing on the prevention of fraud schemes.
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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.
[2] Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System; and Federal Deposit Insurance Corporation, Request for Information on Potential Actions to Address Payments Fraud Request for Information Related to the Executive Order, “Modernizing Payments To and From America’s Bank, 90 FR 26293 (June 18, 2025).
[3] 2024 FBI Internet Crime Complaint Center, Internet Crime Report, Annual Reports – Internet Crime Complaint Center (IC3).
