Banking on Fraudology

Holds, Hopes, and Holes: Why Funds Availability Rules Are Failing Fraud Teams


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Banking on Fraudology is part of the Fraudology Podcast Network.

In this compact but powerful episode of Banking on Fraudology, Hailey Windham tackles a topic that's causing major headaches for fraud teams across the country: the limitations of funds availability rules. Windham expertly breaks down how Regulation CC, created in 1987, is struggling to keep pace with the sophisticated fraud schemes of the digital age. She paints a vivid picture of the challenges facing financial institutions, from the rapid availability requirements for treasury checks to the inadequate hold periods for detecting complex fraud.

Windham's expertise shines as she dissects the "doubtful collectability" clause and explains why the current 10-day exception hold often falls short in today's fraud landscape. She addresses the difficult position fraud teams find themselves in - caught between compliance requirements, operational pressures, and their own instincts about risky transactions. But this episode isn't just about identifying problems; Windham offers a wealth of practical solutions.


Listeners will gain valuable insights into maximizing their use of exception holds, enhancing frontline staff training, leveraging new verification tools, and strategically using account structures to mitigate risks. Windham's call for breaking down silos between fraud, compliance, and operations teams is particularly poignant. The episode concludes with a rallying cry for industry-wide change and a handy "cheat sheet" of Reg CC reminders. Whether you're a fraud fighter, compliance officer, or financial institution leader, this episode is a must-listen. Tune in to arm yourself with knowledge, strategies, and inspiration to better protect your institution in the face of outdated regulations.


About Hailey Windham:

As a 2023 CU Rockstar Recipient, Hailey Windham, CFCS (Certified Financial Crimes Specialist) demonstrated unbounding passion for educating her community, organization and credit union membership on scams in the market and best practices to avoid them. She has implemented several programs within her previous organizations that aim at holistically learning about how to prevent and detect fraud targeted at membership and employees.

Windham’s initiatives to build strong relationships and partnerships throughout the credit union community and industry experts have led to countless success stories. Her applied knowledge of payments system programs combined with her experience in fraud investigations offers practical concepts that are transferable, no matter the organization’s size.

Connect with Hailey on LinkedIn: https://www.linkedin.com/in/hailey-windham/

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Banking on FraudologyBy Hailey Windham

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