IPA Submits Comment on RFI Addressing Paper Check Fraud

The Innovative Payments Association (IPA) submitted a formal comment in response to the June 20, 2025, Request for Information (RFI) from the prudential banking regulators (the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board) regarding potential actions to address payments fraud, with a focus on paper checks.

Our Point of View

• Prioritize collaboration and education over new rules. Financial institutions already operate under a robust framework governing check processing and fraud resolution. We believe the most effective next steps are stronger public-private collaboration, improved data sharing, and expanded consumer and business education about the risks of check fraud.
• Convene stakeholders to accelerate solutions. We encourage the prudential regulators to host joint meetings with industry participants to coordinate practical anti-fraud measures, citing existing models of public-private cooperation that can be adapted to the check-fraud context. Targeted law-enforcement task forces focused on check fraud could further deter criminal activity.
• Support the transition to safer electronic payments. The most durable way to reduce check fraud is to continue shifting away from paper checks to secure, fully regulated electronic options, including direct deposit to DDAs, mobile wallets, prepaid accounts, and other digital rails governed by Regulation E. This transition is already underway as check usage declines and electronic methods grow.
• Advance inclusion and program efficiency. Electronic disbursements are central to how many public programs deliver benefits today, providing recipients with faster, safer access to funds and an on-ramp to broader financial services. Continued modernization will enhance outcomes for both consumers and administrators.
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We appreciate the agencies' focus on mitigating fraud while supporting an inclusive and efficient payments ecosystem. For details, you can read our filed comment letter.
If members have questions about the filing, please contact Brian Tate at [email protected].

Download the Comment Letter