Compliance BootCamp Highlights Importance of Outreach   

 Reach out to regulators, lawmakers and law enforcement before problems arise.

Reach out to regulators, lawmakers and law enforcement before problems arise.

By Loraine DeBonis, Marketing & Communications Director

This week our CEO Cheryl Slipski and I had the chance to attend the Network Branded Prepaid Card Association’s first Compliance BootCamp in Atlanta. It did not disappoint.

The full text of the CFPB’s final prepaid rule with all the amendments and updated language in one place—thank you Womble Bond & Dickinson LLP!—was alone worth the trip.

The packed agenda dug into everything from the final prepaid rule and expectations on enforcement to the FDIC’s guidance on brokered deposits as well as a compelling look at cybersecurity through the eyes of Nathan Kitchens, Deputy Chief, Cyber & Intellectual Property at the U.S. Attorney’s Office, Northern District of Georgia.

Talk Before Problems Arise

In addition to highlighting the tactics used in the “Top 5 Cybercrimes,” Kitchens called on attendees to engage with law enforcement. Reach out to local FBI and Secret Service offices in advance of any type of security breach, so you know whom to contact if something does happen, he suggested.

Kitchens also emphasized the critical importance of information sharing and timely notification when breaches occur, which he said, directly affects law enforcement’s ability to investigate and bring perpetrators to justice. It also can be helpful to alert law enforcement when you prevent intrusions through the FBI’s Internet Crime Complaint Center (IC3).

Working with the National Cyber-Forensics and Training Alliance is another way to share information and help thwart cybercriminals, according to Kitchens and NBPCA COO Ben Jackson. Established in 2002 as a nonprofit partnership between private industry, law enforcement and academia, the NCFTA focuses on identifying, mitigating and ultimately neutralizing cybercrime threats.

Education Required

In a session on what to do when regulators coming knocking, for example with a civil investigative demand or subpoena, Gerry Sachs, a partner in Venable's government division, who previously worked at the CFPB, FTC and DOJ, echoed the importance of timely response. But he also noted that outreach is important before the regulator is at your door.

One reason is that there’s still confusion and misconceptions about prepaid products despite the tremendous strides the NBPCA has made to educate lawmakers and regulators on how the products do and don’t work. Sachs called on the audience to engage through the association and directly to continue educating policymakers and regulators on the industry.

Upon leaving Atlanta and the beautiful offices of host firm Womble, I was struck by how much the Compliance BootCamp reflected the overall mission of the NBPCA—to educate, advocate, promote and protect the prepaid industry.

It’s a worthy mission, but the association can’t do it alone. It’s up to us all to ensure a positive future for prepaid and the individuals and organizations that rely on prepaid products to make payments every day.

Loraine DeBonis is the marketing and communications director for Ubiquity Compliance Solutions, which specializes in dispute and chargeback management, fraud and identity verification services for the financial services sector. Previously, she spent 10 years writing about prepaid and emerging payments for SourceMedia and Paybefore. She can be reached ldebonis@ubiquitycompliance.com.