The FTC released a report outlining concerns about mobile payments, focusing on dispute resolution, data security, and privacy. Regarding dispute resolution, protections vary based on payment method and additional protections may be needed. Mobile carrier billing is a particular concern, and carriers should enable blocking of third-party charges and establish dispute processes. For data security, strong security measures are needed but not all companies are using available technology. Regarding privacy, the growing number of companies involved raises concerns, and companies should implement privacy by design, simplified choices, and transparency.
The DASHBOARD Act would impose several data-disclosure requirements on large companies that monetize online user data. The Act assumes a market failure of information asymmetry, where consumers undervalue their personal data. However, the evidence for this claim is indeterminate, and a lack of clarity on data property rights and liability could make corresponding rules difficult to enforce.
Presentation on mobile payments and mobile money at the June 2013 SmarterCommerce Global Summit in Monaco. Includes description of relevant IBM product families that support mobile money and mobile payments.
Mobile Wars: Fintech vs. Banks... and Big Tech in AmbushKatia Bazzocchi
Pure mobile banks gain users daily, as they benefit from accessible smartphone technology. Millenials are the principal users of mobile banks, and will soon be followed by Generation Z. As consumer expectations continue to be shaped by new technology and innovative consumer affairs, a full mobile strategy is key for traditional banks to maintain market share.
The DASHBOARD Act would impose several data-disclosure requirements on large companies that monetize online user data. The Act assumes a market failure of information asymmetry, where consumers undervalue their personal data. However, the evidence for this claim is indeterminate, and a lack of clarity on data property rights and liability could make corresponding rules difficult to enforce.
Presentation on mobile payments and mobile money at the June 2013 SmarterCommerce Global Summit in Monaco. Includes description of relevant IBM product families that support mobile money and mobile payments.
Mobile Wars: Fintech vs. Banks... and Big Tech in AmbushKatia Bazzocchi
Pure mobile banks gain users daily, as they benefit from accessible smartphone technology. Millenials are the principal users of mobile banks, and will soon be followed by Generation Z. As consumer expectations continue to be shaped by new technology and innovative consumer affairs, a full mobile strategy is key for traditional banks to maintain market share.
Joint ad trade letter to ag becerra re ccpa 1.31.2019Greg Sterling
We strongly support the objectives of the California Consumer Privacy Act (CCPA), but we have notable concerns around the likely negative impact on California consumers and businesses from some of the specific language in the law. We provide this initial comment to provide you with information about the significant importance of a data-driven and ad-supported online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your attention to several areas that can be addressed and improved through the rulemaking process. We will provide more detailed comments over the coming weeks.
The emergence of m commerce promises great benefits, but also poses significa...Keith Adams
Paper discussing the emergence of mobile commerce in the United States and comparing development in the US with more advanced adopters of the technology across the globe.
Grant Proposal of the Association for Consumer EffectivenessJoel Drotts
This is the current grant proposal under submission to several large corporate and private foundations and donors, by the Association for Consumer Effectiveness. The Association has become the premier consumer perspective and consumer protection organization, in the field and industry of Data Brokers. Data Brokers are the large data hungry companies that trample consumer privacy on a greater scale every day in America. The Association has been charged with the duty and mission to help prevent this from occurring even further, and if possible reverse the damage already caused to the privacy of the American Consumer Public.
The market report spans the overall structure of the mobile money market and provides premium insights that can help mobile money service providers such as MNOs, banks, payment processing agents, payment platform providers, and budding and independent mobile payment solution providers to identify the needs of the customers and mobile subscribers.
Technology-driven change has become a constant for merchants,
financial institutions, and processors. That reality has created a shifting
landscape of new capabilities, new competitors, new rules, and new
customer expectations. It can all be complicated and confusing, but an
assessment of that landscape indicates several clear trends affecting
the industry. For more info: www.nafcu.org/vantiv
The Internet of Things: A Prime Opportunity for Merchant AcquirersCognizant
For merchants, the Internet of Things’ vast connectivity makes it easy for consumers to purchase within an environment that is intuitive, familiar and comfortable. For acquirers, there is the opportunity to provide various interfaces for accepting payments from all connected touchpoints -- creating an omnichannel experience for customers.
ANALYSIS OF MOBILE PAYMENT INFLUENCING FACTORScscpconf
With the exponential proliferation of mobile devices in the consumer market, wireless e-business
is emerging as a key area to revolutionise industries. In the past few years, industry has
witnessed an increase in the adoption of mobile payment and billing methods that leverage on
wireless technologies. Yet, the success of mobile payments in businesses much depends on
many factors such as, type of wireless technologies used, security options available, the players
involved and their influencing m-business models. This paper examines mobile payments in
both technical as well as business perspectives. It identifies and analyses the influencing factors
from multi-dimensions that would be useful for adopting mobile payments.
Joint ad trade letter to ag becerra re ccpa 1.31.2019Greg Sterling
We strongly support the objectives of the California Consumer Privacy Act (CCPA), but we have notable concerns around the likely negative impact on California consumers and businesses from some of the specific language in the law. We provide this initial comment to provide you with information about the significant importance of a data-driven and ad-supported online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your attention to several areas that can be addressed and improved through the rulemaking process. We will provide more detailed comments over the coming weeks.
The emergence of m commerce promises great benefits, but also poses significa...Keith Adams
Paper discussing the emergence of mobile commerce in the United States and comparing development in the US with more advanced adopters of the technology across the globe.
Grant Proposal of the Association for Consumer EffectivenessJoel Drotts
This is the current grant proposal under submission to several large corporate and private foundations and donors, by the Association for Consumer Effectiveness. The Association has become the premier consumer perspective and consumer protection organization, in the field and industry of Data Brokers. Data Brokers are the large data hungry companies that trample consumer privacy on a greater scale every day in America. The Association has been charged with the duty and mission to help prevent this from occurring even further, and if possible reverse the damage already caused to the privacy of the American Consumer Public.
The market report spans the overall structure of the mobile money market and provides premium insights that can help mobile money service providers such as MNOs, banks, payment processing agents, payment platform providers, and budding and independent mobile payment solution providers to identify the needs of the customers and mobile subscribers.
Technology-driven change has become a constant for merchants,
financial institutions, and processors. That reality has created a shifting
landscape of new capabilities, new competitors, new rules, and new
customer expectations. It can all be complicated and confusing, but an
assessment of that landscape indicates several clear trends affecting
the industry. For more info: www.nafcu.org/vantiv
The Internet of Things: A Prime Opportunity for Merchant AcquirersCognizant
For merchants, the Internet of Things’ vast connectivity makes it easy for consumers to purchase within an environment that is intuitive, familiar and comfortable. For acquirers, there is the opportunity to provide various interfaces for accepting payments from all connected touchpoints -- creating an omnichannel experience for customers.
ANALYSIS OF MOBILE PAYMENT INFLUENCING FACTORScscpconf
With the exponential proliferation of mobile devices in the consumer market, wireless e-business
is emerging as a key area to revolutionise industries. In the past few years, industry has
witnessed an increase in the adoption of mobile payment and billing methods that leverage on
wireless technologies. Yet, the success of mobile payments in businesses much depends on
many factors such as, type of wireless technologies used, security options available, the players
involved and their influencing m-business models. This paper examines mobile payments in
both technical as well as business perspectives. It identifies and analyses the influencing factors
from multi-dimensions that would be useful for adopting mobile payments.
The FDA’s role in the approval and subsequent review of Vioxx, a.docxmehek4
The FDA’s role in the approval and subsequent review of Vioxx, a pain medication with- drawn from the market by its manufacturer after it was associated with heart attacks and strokes, is discussed in a case at the end of this textbook.
In 2010, Congress established, as part of the Dodd-Frank Act (also discussed in Chapters 8 and 14), a new consumer regulatory body, called the Consumer Financial Pro- tection Bureau. The purposes and actions of this agency are described in Exhibit 15.B. The debate over whether government should become involved in protecting consumer privacy is discussed in the next section of this chapter.
All seven government regulatory agencies shown in Figure 15.2 are authorized by law to intervene directly into the very center of free market activities, if that is considered nec- essary to protect consumers. In other words, consumer protection laws and agencies substi- tute government-mandated standards and the decisions of government officials for decision making by private buyers and sellers.
Consumer Privacy in the Digital Age
In the early 21st century, rapidly evolving information technologies have given new ur- gency to the broad issue of consumer privacy. Shoppers have always been concerned that information they reveal in the course of a sales transaction—for example, their credit card or driver’s license numbers—might be misused. But in recent years, fast-changing tech- nologies have increasingly enabled businesses to collect, buy, sell, and use vast amounts of personal data about their customers and potential customers. The danger is not only that this information might rarely be used fraudulently, but also that its collection represents a violation of privacy and might lead to unanticipated harms.
Individuals are often unaware of how much information about themselves they reveal to others as they shop, interact with friends, play games, or look for information online. A variety of technologies make this possible. Many websites place cookies—or more power- ful Flash cookies—on a computer hard drive, to identify the user during each subsequent visit and to build profiles of their behavior over time. Web beacons embedded in e-mails and websites retrieve information about the viewer. In deep packet inspection, third parties access and analyze digital packets of information sent over the Internet, such as pieces of e-mails or Skype calls, to infer characteristics of the sender. Not just retailers, but also Internet service providers such as Comcast, search engine operators such as Google, and informational services such as Dictionary.com, also track their users. So-called data aggregators purchase and combine data about individuals collected from various sources and compile them into highly detailed portraits to be sold to retailers, service providers, and advertisers.15
An example of a data aggregator is Acxiom Corporation, based in Conway, Arkansas. Acxiom, called the “quiet giant” of the industry, has built the larg ...
1Running head CYBERLAW CONSUMER PROTECTION IN CYBERSECURITY .docxaulasnilda
1
Running head: CYBERLAW CONSUMER PROTECTION IN CYBERSECURITY
Cyber-law; Consumer Protection in Cybersecurity
STUDENT’S NAME:
INSTRUCTOR’S NAME
CORSE:
DATE:
Abstract
The law has been interested in ensuring that necessary it protects people under it not just physically but just in terms of their connectivity. This is the purpose that is served by cyber law. There are many topics under cyber law, all of which seem to encourage observance of safety by providers of cyber services and consumers of such services. Cybersecurity is growing in volume due to increased interconnectivity among devices all over the world. This has made it possible for cyber-attacks to perform various cybercrimes to anyone in the cloud irrespective of where they are located on a global basis. To ensure consumers of cyber services are protected, the law comes in and intervenes on how consumers relate with their cloud services providers. In this case, the cyber law intervenes security at the cloud through legislative of consumer protection. This is an act that is developed and captured by the legal system pertaining protection of the consumer of cloud service by their providers. This paper sheds light on the legislation of consumer protection by assessing different parameters and areas of interest of cyber law in consumer protection at the cloud. Therefore, the paper discusses what has been achieved under the legislation of consumer protection in the enhancement of cybersecurity, what is yet to be done, and how it should be done.
Introduction
Consumer protection at the cloud is a business functionality whose complexity is growing day by day. Big businesses that are associated with cloud connectivity are being closely watched by the law to ascertain if they have appropriate policies in place to assure the protection of their customers in cyberspace. Majorly, the legal system is determined to ensure that consumer's digital identities are protected by businesses that operate in the cloud, and their financial details are not leaked at any given instance (Howells, G., & Weatherill, 2017).
Attackers at the cyberspace are majorly interested in compromising financial information r digital documentation of cloud users. This is because they can enrich themselves massively when they successfully breach consumer’s financial documentation in the cloud. Therefore, consumers have been changing their pattern on how they consumer cyber services. In this case, consumers have been willing to as much as they can afford provided that they get to enjoy the benefits. This implies that consumers in modern times do not hesitate to pay more to service providers who can protect consumer’s financial details.
Governmental bodies have been set in place to screen companies that operate in the cloud space to ascertain how much they protect any identify that is associated with their customers. Federal Communications Commission has been responsible for the assessment of companies that have a vi ...
A STRATEGIC FRAMEWORK FOR MOBILE PAYMENTSIJMIT JOURNAL
With the exponential proliferation of mobile devices, smart phones and apps in the consumer market,
mobile payment is emerging as a key area to revolutionise the everyday financial life of both consumers
and merchants. The past few years have witnessed an increase in the adoption of digital payments and
online billing methods that leverage on wireless technologies and the Internet. However, the success or
failure of mobile payments in businesses is a hot topic today due to the multi-faceted factors such as, type
of wireless technologies used, security and privacy, the players involved and their influencing business
models, including consumer factors relating to interoperability, flexibility, ease-of-use and social
marketing. This paper examines mobile payments in all perspectives: technical, social as well as business
viewpoints and provides a strategic framework for a successful mobile payment adoption.
Strategic framework for mobile paymentsIJMIT JOURNAL
With the exponential proliferation of mobile devices, smart phones and apps in the consumer market, mobile payment is emerging as a key area to revolutionise the everyday financial life of both consumers and merchants. The past few years have witnessed an increase in the adoption of digital payments and
online billing methods that leverage on wireless technologies and the Internet. However, the success or failure of mobile payments in businesses is a hot topic today due to the multi-faceted factors such as, type of wireless technologies used, security and privacy, the players involved and their influencing business models, including consumer factors relating to interoperability, flexibility, ease-of-use and social
marketing. This paper examines mobile payments in all perspectives: technical, social as well as business
viewpoints and provides a strategic framework for a successful mobile payment adoption.
A presentation I made in June 2014 as starting point for discussions at the ISACA Belgium open forum on mobile payments risks, security and assurance issues.
This presentation explores what future of commerce may look like given the current trends in mobile devices, digital payments, social commerce and security including tokenization and new forms of identity verification
The study we present aims to explore several factors pertaining to Consumer Acceptance of business technology as it related to Blockchain. Identifying and developing the relevant measures is of importance to business technology managers and software development managers today. We ask the important question of “what measures best represent the established constructs of the technology acceptance model?” In order to address this issue, it is important to identify the key measurements that help us to understand the proposed constructs as they relate to blockchain technology as well as confirm their validity in isolation and in combination with each other. In this study, the factors we explore are perceived reputation, risk, and usefulness and transaction intentions. A survey was used whereby the methodology adapted previous measurements from related works and new measurements pertaining to usefulness and risk were developed in order to adhere to blockchain’s consumer acceptance framework. 268 students completed the questionnaire and an exploratory factor analysis was used in order to analyze the constructs and their measurements. Through the results we were able to identify and validate the relevant measurements as well as the proposed constructs.
Similar to FTC Releases Report Outlining Mobile Payment Concerns (20)
American University International Law Review Annual Symposium: Managing the G...Patton Boggs LLP
DC Partner Frank Samolis will address participants during a symposium hosted by American University’s Washington College of Law on February 18, 2014. The event will examine issues around international trade and the environment through dialogue on the Trans-Pacific Partnership and Transatlantic Trade and Investment Partnership negotiations, the state of Article XX of the General Agreement on Tariffs and Trade, enforcement mechanisms under regional trade agreements, and potential future means of protecting the environment through International Trade Law Society. Mr. Samolis will serve as a panelist during a discussion on TTP talks and TTIP negotiations at 12:45 p.m. during the symposium.
With increasing demand on limited public resources, national and local governments are recognizing the need for a new approach to social services that emphasizes the identification of effective, innovative ideas. However, a lack of available funding and the reluctance to take on the risk that a promising, but unproven, idea might fail have created obstacles to this new approach. The social impact bond model is designed to eliminate these obstacles.
U.S. Securities and Exchange Commission Proposes New Rule on Pay Disclosure
FTC Releases Report Outlining Mobile Payment Concerns
1. MARCH 12, 2013 TECHCOMM/FINANCIAL SERVICES CLIENT ALERT
This Alert provides only general
information and should not be
relied upon as legal advice. This
FTC RELEASES REPORT OUTLINING
Alert may be considered attorney
advertising under court and bar MOBILE PAYMENT CONCERNS
rules in certain jurisdictions.
On March 8, 2013, the Federal Trade Commission (FTC) released a staff report,
entitled “Paper, Plastic…or Mobile? An FTC Workshop on Mobile Payments,”
For more information, contact your addressing its consumer protection concerns in the mobile payments area. The
Patton Boggs LLP attorney or the FTC’s preliminary review is a follow-up to the Board of Governors of the Federal
authors listed below. Reserve System report, entitled “Consumers and Mobile Financial Services,” that
focused on the growth of mobile payments and banking.
Paul C. Besozzi
pbesozzi@pattonboggs.com
The FTC staff report, available here, examines mobile payments as a proven new
Deborah M. Lodge technology which consumers are expected to adopt widely in the next few years.
dlodge@pattonboggs.com Thus, the FTC emphasized “its mandate to protect consumers in the commercial
marketplace” and “broad jurisdiction over many of the companies that participate
Michael Drobac
in the mobile payments ecosystem.” These include hardware manufacturers,
mdrobac@pattonboggs.com
operating system and application developers, data brokers, coupon and loyalty
Carol R. Van Cleef program administrators, payment card networks, advertising companies, retailers
cvancleef@pattonboggs.com and other merchants and in certain cases telecommunications carriers.
Monica S. Desai
The report’s analysis includes technologies and products to facilitate mobile
mdesai@pattonboggs.com
payments using various funding sources (e.g., credit card, debit card, bank and
mobile phone accounts), such as Near Field Communications (NFC), mobile
apps, online checkout wallets and mobile carrier billing
ABU DHABI
The report underscores the FTC’s ongoing interest in the mobile payments area.
ANCHORAGE
While the agency shares enforcement powers with the Federal Communications
DALLAS
DENVER Commission and Consumer Financial Protection Bureau (CFPB) over some
DOHA mobile payment methods, the FTC clearly intends to ensure that consumers have
NEW JERSEY adequate protections and information they need to make informed choices
NEW YORK regarding mobile payments. As a result, the report commits the agency to
RIYADH continued evaluation of the mobile payment marketplace as new services and
WASHINGTON DC products are developed.
PattonBoggs.com Client Alert 1
2. CONSUMER PROTECTION CONCERNS
The FTC staff identifies three primary areas of focus relating to mobile payments: (a) dispute resolution, particularly
with mobile carrier billing, (b) data security, and (c) privacy. The report addresses each, provides suggestions and
outlines the FTC’s primary concerns in each area.
DISPUTE RESOLUTION IN THE MOBILE PAYMENTS CONTEXT: EXTENDED PROTECTIONS
A most significant concern is the resolution of disputes in the case of fraudulent or unauthorized charges. The FTC
staff notes that mobile payment users may not recognize that protections against such charges can vary based on the
underlying funding source. For example, transactions involving credit and debit cards are afforded statutory liability
protections (e.g., credit card cap liability for unauthorized use at $50) that do not apply to other payment methods
(e.g., general purpose reloadable card (GPR), also known as a prepaid debit card).
The general protections of the FTC Act do apply; and some companies have filled the gap with contractual
protections in the event of payment disputes involving GPRs. The report cites the FTC’s support for the CFPB
possibly extending legal protections to GPRs to (a) limit liability, (b) require disclosure for fees and expiration dates,
(c) establish error resolution procedures, and (d) set authorization standards for recurrent payments (the CFPB issued
an advanced notice of proposed rulemaking last year to extend Regulation E to GPRs in 2012 although final action is
not expected until at least 2014).
The report’s message is clear: Companies should “develop clear policies regarding fraudulent and unauthorized
charges and clearly convey these policies to consumers” so that consumers can understand their rights and protections
when deciding whether to pay with a particular mobile device and particular funding mechanism.
MOBILE CARRIER BILLING: A PARTICULAR CONCERN
The FTC staff expresses a special concern about mobile carrier billing (i.e., charging payments directly to a mobile
phone bill). As a result, the report calls for carriers to:
(a) enable consumers to block all third party charges on their mobile accounts;
(b) “clearly and prominently” inform customers about possible third-party charges and how to block them; and
(c) establish a clear and consistent process for consumers who wish to dispute such charges and obtain
reimbursements.
The report outlines other potential approaches, including standardizing and highlighting third-party billing
descriptions, providing notifications to consumers, imposing contractual obligations regarding maintenance and
access to customer authorization records, implementing standard dispute policies and allowing consumers to delay
PattonBoggs.com Client Alert 2
3. payment in good faith dispute situations, without penalty. In the staff’s view, additional protections, such as those
already mandated for credit cards, are needed to protect consumers in the mobile payments field.
Interestingly, the report does not address state money transmitter licensing issues that may be raised by mobile carrier
billing. However, the FTC staff is organizing a separate roundtable on mobile carrier billing issues for May, 2013.
CONSUMER DATA SECURITY IN MOBILE PAYMENTS
The report finds that a key concern for consumers when making mobile payments is the security of their sensitive
financial information. The FTC staff concludes that although the technology to provide enhanced security in the
mobile payments market is available (e.g., end-to-end encryption, dynamic data authentication), “it is not clear that all
companies are employing it.”
The report recommends that mobile payment providers should “increase data security” and “encourage adoption of
strong security measures by all companies in the mobile payments chain.” The FTC staff notes that many federal and
state laws also impose data security requirements on businesses that collect and use financial information and other
sensitive data. Finally, the report outlines practical steps that consumers themselves can take to secure their sensitive
data in the mobile payments marketplace (e.g., password protections, particularly for any payment apps).
PRIVACY
The FTC staff finds that mobile payments raise significant privacy concerns, due to the growing number of
companies involved in the transactions and their access to detailed consumer data. The report expresses concern
about “multiple players within the mobile payments ecosystem” who gather, consolidate and purchase data in a way
not possible under traditional payments regimes.
As a result the FTC staff encourages companies in the mobile payments marketplace to implement the three basic
principles put forth in the agency’s March 2012 report on “Protecting Privacy in an Era of Rapid Change,” available
here:
(a) Privacy by design: companies should consider and address privacy at every stage of product development;
(b) Simplified choices: consumers should be given specific, clear choices about data collection and use in the
mobile payments arena; and
(c) Transparency: Companies in the mobile payments field should be transparent about their data collection and
use, to increase consumer trust in this growing marketplace. This topic was a key focus of an earlier FTC staff
report, released in February, on mobile privacy disclosures, available here.
PattonBoggs.com Client Alert 3
4. The world is “going mobile” – a movement that includes making payments through mobile devices and apps. The
focus of the Commerce Department’s National Telecommunications and Information Administration on mobile
privacy in its multi-stakeholder approach to mobile privacy is likely to include mobile payment companies as they
draft principles for industry to adopt. This effort, combined with the Worldwide Web Consortium’s (W3C) Tracking
Protection Working Group, and the Digital Advertising Alliance signal a broad focus on data security, privacy and
new legal and self-regulatory regimes to address advancements in technology and exciting new innovations, including
mobile payments.
The rapid adoption of such new innovations, notably in the mobile payments industry, will lead to ease in commerce
but will undoubtedly raise additional questions about whether the government or third party groups must create
mechanisms to protect consumers. This latest FTC staff report is further evidence that the agency will continue to be
vigilant in protecting consumers using mobile payment methods.
PattonBoggs.com Client Alert 4