Payroll Card Position Paper July 2004

Transcription

1 Payroll Card Position Paper July 2004 This document is and remains the proprietary information of CU Cooperative Systems, Inc. It is intended for the use of the recipient s organization only and any distribution outside that organization without the permission of CU Cooperative Systems, Inc. is expressly prohibited.

2 Stored Value Cards as an Emerging Product Stored-value cards are replacements or alternatives for cash, gift certificates and check payments. Monetary value is added to the stored-value account with the value funded directly by the cardholder, or by the employer in payroll applications. These are not smart cards with value held in a chip on the card, but an account established at a processor accessed by a conventional plastic card. Funds are accessed via ATM, PIN POS and Signature POS delivery channels. Recently, there has been a great deal of attention given to stored value cards, their growth potential and the function they will assume within the consumer, retail and financial markets. This visibility has caught the eye of not only issuers, but regulatory, legislative, and consumer groups at both federal and individual state levels. In the past four months, over 105 legislative and regulatory initiatives have been introduced which will define and regulate this emerging payments vehicle. Program definitions are fluid as requirements for issuance, expiration dates, consumer identification, fees, escheatment, abandonment, insurance, reserves, reporting/statementing, and consumer disclosure are being established. The OCC has issued a statement which cautions the financial institution market about the requirements and definitions of stored value cards of all types including gift and payroll cards. The FDIC is proposing an account definition which may define stored value cards as deposit accounts and thereby require depository insurance and reserve requirements in order to protect consumers and ensure safety and soundness. These rapidly changing service and product requirements should signal caution to credit unions thinking of supporting stored value products and services. Stored value providers may be challenged to meet the changing individual federal and state regulatory requirements. The final definition and ongoing management of these cards may impact revenue potential, card deployment, and subsequent growth. CO-OP Network recommends that credit unions evaluate use of their existing member account and card infrastructure as an alternative to third parties to provide payroll card service. Simply stated, CO-OP Network believes that a credit union can easily establish a payroll transaction account with the following attributes: No checks ACH deposits only Card access for ATMs and PIN POS. Assuming additional risk, a Signature POS capability could be added. Optional statements Copyright July 2004 CO-OP Network Page 2

3 Account holder identification in keeping with Patriot Act compliance Responsible fees This service could be offered to any employee through any SEG employer. A credit union product structured in this manner is likely to allow the employer to leverage their existing cost effective ACH payroll infrastructure, provide a better and lower cost service to the employee/member, and increase credit union membership and income. From a regulatory stand-point, this method leverages existing infrastructure with known regulatory requirements. This approach supports the focus of credit unions to economically serve their membership, provide services to the underserved, support their sponsors, and aid the communities in which they reside. Payroll Cards In the last decade, the payroll industry has experienced an increase in costs associated with processing checks. In an effort to save money on paper, printing and distribution costs, many employers are replacing traditional paychecks with pre-paid, re-loadable, stored value cards. With the average cost of issuing a payroll check in the United States at approximately $1.35 (not including mailing expenses), and the average cost to reissue a check at approximately $12, payroll cards are seen as a cost-effective alternative to printing and mailing payroll checks. Today, over 55% of Americans are paid via direct deposit. Many underserved employees are unable to use direct deposit, and choose to use the services of check cashing outlets absorbing the high fees associated with check cashing at merchant outlets. Recent statistics provided by the American Payroll Association supported the shift towards payroll cards. As much as 30% of the U.S. population do not have a financial institution account. More than four million paychecks are lost or stolen each year. Lost paycheck replacement costs are estimated to be $48 million annually. Industry experts claim that companies can save up to $1.25 per payment using electronic disbursement instead of checks ( The chance of having a problem with a check is 20 times greater than with Direct Deposit ( It is estimated that more than 2.3 million payroll cards were issued and remained active last year, and the number of cards in use is projected to almost triple in the next two years, reaching 6.8 million by (Navigating the New Payments Landscape, 2004) Copyright July 2004 CO-OP Network Page 3

4 The Logistics of Payroll Card Distribution through Existing Account Infrastructures Using the existing account infrastructure, a credit union can implement a payroll card solution upon request with minimal setup and cost. Employers simply endorse and refer employees to the credit union using a prepackaged approach to payroll cards. Member disclosures, ATM and debit cards, and checkless accounts which have optional statement capabilities are established for employees choosing to participate. The employer uses ACH to fund the accounts, and the employee has access to their funds using their credit union issued ATM or debit card. Taking this approach has many advantages over a third party payroll card alternative. Time to implement: Credit unions use systems they are familiar with to establish the payroll account type. New card program definitions and setups are not required with new external vendors. National network approvals are not required because the cards are in effect ATM and debit cards simply funded with ACH. Consumer disclosure is accomplished with existing forms and methods. Insurance and reserve requirements are fulfilled because the accounts are defined as normal deposit transaction accounts. Pending regulatory issues for fees are resolved using a defined account type and granting access via the CO-OP Network nationwide surcharge-free ATM network and pinned POS avenues. Reporting and statement requirements are satisfied by using the existing sharedraft account infrastructure. Plastics design and approvals are eliminated unless a custom card is requested by the employer. This reduces setup time, and makes it easy to establish a payroll program. Cards can be personalized, created and distributed within normal time frames. Credit unions with employer affiliations may be able to leverage their unique relationship with the employer and use payroll cards to extend their reach further into the employee base; growing membership and providing service to the underserved. Employer costs are reduced because check handling is eliminated from the payroll process, and cards are easily re-loaded using ACH. Copyright July 2004 CO-OP Network Page 4

5 Membership benefits previously not available to this market demographic are established and the potential for other services like lending, overdraft protection, and investing become inherent in the member relationship as the member establishes a card and history of responsible card usage. CO-OP Network The Value Proposition In the fluid stored value market, CO-OP Network stands firm as a credit union partner by recommending a solution which enables credit unions to quickly and easily participate in the payroll card market. 19,000 Surcharge-Free Nationwide ATMs The heart of the payroll card is providing the underserved with economical, reliable, secure, private access to their funds. Existing Network Connections By using existing connections to deposit accounts for credit unions, there is no host development for online authorization or batch file changes for Authorization Processor configurations. Payments infrastructure Credit unions are free to use existing national network memberships and provide both pinned and signature based access via CO-OP Network to employee funds. Brand Recognition CO-OP Network is a trusted credit union partner. Surcharge-free access and national advertising can be used to stimulate payroll card acceptance and usage. Member Service and Growth Credit unions are positioned to increase membership and service the underserved with an in-house solution that limits fees and provides account access. Time to Market Eliminate costly setup fees, new BINs, and network approvals by using current card programs to support payroll card requests. Low Cost, Low Risk, Compliant Programs Regulation in this space is changing rapidly. Taking this approach allows the credit union to focus on what it does best provide member service with full compliance, and at the same time respond to requests for payroll card programs. New Revenues Responsible account fees and POS interchange can make this service profitable and position the credit union to provide additional services to these new members. This new service can be offered with minimal out-of-pocket costs and program development. Copyright July 2004 CO-OP Network Page 5

6 Summary Payroll card program requirements and regulations are being defined as we speak. The industry is currently dominated by large banks and third parties offering first generation services with extensive fee structures. The potential for program growth, and media focus has drawn the attention of consumer groups and regulators. Consumer demand, employer request, and focused media attention require responsive action by the credit union movement. An opportunity exists for the credit unions to once again provide leadership serving the underserved, increase membership, and responsibly gain new revenues. CO-OP Network encourages credit unions to examine both use of the existing account infrastructure and payroll card products. One size may not fit all, and CO-OP Network will offer a competitive payroll card product as well. With that said, we believe using the account infrastructure will enable credit unions to quickly, securely and economically participate in the growing demand for payroll cards. Perhaps more than any other financial institution provider, payroll cards make sense and fit into the market strategies for member service of credit unions. Controlled risk with full functionality backed by the credit union reputation for member service provides a foundation for participation, member growth, and community service. Copyright July 2004 CO-OP Network Page 6