Wrestling Payments

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Sean Carter, Caitlin Mullins-Smith, and Averee Jimenez dig into where ACH compliance breaks down in practice: origination-side fraud monitoring that nobody set up, web entries treated by label instead of by rule, mishandled written statements that turn into warranty breach exposure, and exposure limits that only look at credit risk.

EPISODE DESCRIPTION
Sean Carter, Caitlin Mullins-Smith, and Averee Jimenez join Joe to work through what institutions are getting wrong, and occasionally right, in ACH compliance and fraud monitoring. The question running under all of it: what does "good enough" actually mean in a live operation, as opposed to on paper.

Caitlin's read is that Nacha's fraud monitoring rule has done something useful almost by accident. It forced institutions to write their monitoring down, and to get operations, fraud, BSA, and compliance talking to each other. Sean and Averee both see the same gap, though: plenty of institutions already monitored receiving-side activity and missed that the rule reaches origination too. And a vendor tool is not compliance. Somebody still has to know what is switched on, what is being watched, and what is not.

The panel is candid about where the rules and the real world diverge, which makes this one useful for banks, credit unions, and their fintech partners.

WHAT THE PANEL COVERS

• Web entries: A2A and P2P are both consumer-to-consumer under Nacha rules, so entry descriptions and internal labels are not a basis for treatment
• The usual web entry mistakes: missing payee names on statements, weak account validation, and treating microdeposits or prenotes as proof of ownership
• Where fintech partnerships break down, when a downstream statement rendering or processing partner does not know the rule detail
• Written statements: unsigned WASDs, items returned before the form is complete, and the wrong return reason code
• Why a mishandled written statement is more than a rule violation, and can open warranty breach exposure for downstream losses
• Return reason codes as a message to the ODFI, not just a field to populate
• The ODFI tension between giving originators useful guidance and overprescribing actions that get blamed back on the bank after a fraud event
• Exposure limits that account for total customer exposure rather than credit risk alone, and why prefunding is not a risk review
• Risk reviews that cover all treasury and payment products instead of ACH in isolation

SIX THINGS TO CHECK WHEN YOU GET BACK TO YOUR DESK

• Review whether your fraud monitoring spans both receiving and origination activity
• Confirm that operations, fraud, BSA, and compliance are actually sharing what they see
• Test statement rendering for web entries, name fields and entry descriptions especially
• Audit written statement workflows for signatures, timing, and return reason codes
• Recheck exposure limits so they reflect total customer risk, not credit risk alone
• Make sure periodic reviews cover all treasury and payment products, not ACH alone

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EPISODE SUMMARY
Joe Casali uses this solo episode to argue that the proposed Stop Payments Fraud Act of 2026 is a useful but limited step against check fraud. He compares today’s check fraud problem to the 1800s, when thousands of banks issued their own currencies and the US eventually solved the issue by standardizing and phasing out the old system. In this episode, Joe explains why he thinks the bill helps investigators but does not go far enough to fix the structural problem. He walks through the history, the current fraud environment, and the broader reforms he believes would actually move the needle.

KEY TOPICS

• Joe introduces HR 9331, the Stop Payments Fraud Act of 2026, and notes its bipartisan 51 to 0 committee vote. Unusual in this political climate
• He connects today’s fraud challenges to the Expedited Funds Availability Act and Reg CC, which still force fast availability of deposited funds
• He compares modern check fraud to the 1800s “wildcat bank” era, when 2,500 institutions issued about 30,000 different currencies
• He highlights how counterfeit currency was once estimated at up to 50 percent of currency in circulation, showing that fraud can become embedded in a payment system
• He says he's been told that the US has never truly retired payment rails in modern times, but history proves it can phase out a dominant instrument when the system changes 
• He notes current fraud indicators, including 63 percent of organizations reporting check fraud in 2024 and B2B check use still at 26 percent of payments 
• He points to the federal government stopping distributing paper checks in 2025 and the Federal Reserve asking for feedback on the future of Fed check services
• He argues that real progress would include standardized check design and security features, better information sharing, stronger detection tools, and broader education
• He emphasizes that positive pay and other existing controls are helpful, but underused and often poorly communicated to business customers

Timestamps
(00:00) Opening the case against modern check fraud
  (01:02) What HR 9331 does and why it matters
  (02:01) Why fast funds availability creates fraud risk
  (03:30) Why this bill is only a partial fix
  (04:00) The US keeps adding payment systems without retiring old ones
  (05:57) The 1800s had 30,000 currencies and huge fraud exposure
  (08:05) How banks and merchants used fraud lists to manage bad currency
  (09:37) Comparing 1857 state bank notes to today’s check fraud
  (10:31) Security features, positive pay, and why “new” ideas are often old ideas
  (12:28) Wildcat banks, float, and how payment delays created profit
  (13:57) Fraud as a built-in feature of the system
  (15:24) Current check fraud stats and suspicious activity reports
  (17:05) The federal government stops issuing paper checks
  (18:04) Check 21 and the collapse from 44 processing locations to 1
  (20:02) What the Stop Payments Fraud Act would actually change
  (22:02) What the bill does not change
  (23:17) How the National Currency Act unified US money
  (26:27) Five levers for a fuller anti-fraud strategy
  (28:43) Using shared fraud intelligence to stop rings earlier
  (30:30) Why education matters for business owners and account holders
  (32:48) Nietzsche’s role in advocacy, tools, training, and measurement
  (34:45) The realistic goal is reducing fraud, not eliminating it overnight
  (36:42) Why the 1860s currency crisis is the better historical comparison
  (38:06) Why political will for structural change is hard to sustain
  (40:26) Closing thoughts and call to share the episode

Key framework

• Baby-step reform versus structural reform 
• Joe’s core argument is that the bill improves enforcement, but a true fix would standardize, reduce, or eventually phase out vulnerable check processes
• The historical analogy
• The 1800s currency problem is used as a model for how a fragmented, fraud-prone payment system can be standardized over time

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Episode Summary 

In this episode of Wrestling Payments, host Joe Casali welcomes David Dwumah, Founder & CEO of OurFiin and faculty member at the WPI Business School, for a conversation about one of the most important questions facing the payments industry today: how do organizations innovate without sacrificing trust?  

As stablecoins, tokenized deposits, real-time payments, and other emerging technologies gain momentum, many organizations are focused on what technology can do. David argues that the more important question is whether institutions have the governance structures necessary to support innovation over the long term. Drawing on experience with the Federal Reserve Bank of Boston, where he spent five years in audit and risk management roles, including during the 2008 financial crisis, along with leadership roles in banking, fintech, and higher education, he explains why technology alone does not create sustainable payment systems.  

Central to the discussion is David's G-STEPP™ framework: Governance, Strategy, Technology, enabled by People and Processes. Through practical examples and historical lessons, David demonstrates why governance should guide strategy long before organizations begin evaluating technologies such as blockchain platforms, stablecoins, tokenized deposits, or real-time payment rails.  

Joe and David explore the evolution of payments infrastructure, the rise of tokenized financial systems, the growing importance of real-time payments, lessons from America's free banking era, and the role regulations will play in shaping future innovation. Throughout the conversation, one theme consistently emerges: 

Technology tells us what is possible. Governance determines what is sustainable. Trust determines what scales. 

For financial institutions evaluating what's next, this episode offers a practical framework for thinking beyond technology and building payment systems designed to endure.  

GUEST-AT-A-GLANCE 

Name: David Dwumah 

What he does: Founder & CEO of OurFiin; payments governance strategist, fintech innovator, and educator 

Company:OurFiin 

Additional Role: Faculty member at the WPI Business School, where he teaches courses focused on digital currencies, cryptocurrency, and financial markets 

Where to find him:David Dwumah on LinkedIn 

KEY INSIGHTS
Governance Must Come Before Technology 

Organizations often become consumed with selecting technologies before clearly identifying the problem they are trying to solve. David argues that institutions should begin with governance and strategy, then evaluate technologies that support those objectives. Whether discussing stablecoins, tokenized deposits, blockchain platforms, or real-time payments, governance should come first.  

The G-STEPP™ Framework Creates a Durable Path Forward 
David's G-STEPP™ model provides a structured approach to innovation. Governance informs strategy. Strategy determines technology choices. Technology is enabled by people and processes. Following this sequence helps organizations build solutions that can scale and endure rather than simply chasing new technology trends.  

Payments Innovation Typically Complements Existing Rails 
History demonstrates that new payment methods rarely eliminate older ones. Checks, ACH, cards, real-time payments, and emerging tokenized systems often coexist. Innovation expands choices and capabilities rather than replacing every system that came before it.  

Customer Needs Should Drive Strategy 
Successful innovation starts with understanding customers. Institutions should focus not only on the needs customers articulate today, but also the needs they may not yet recognize. Technology adoption decisions should stem from customer value, not industry hype.  

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Nanci McKenzie, MLS, JM, AAP, APRP, CAMS, payments expert in Capital One’s commercial bank treasury management group, joins Joe ahead of her session at NEACH’s End User Payments Fraud Symposium. First party fraud is the one where your account holder is not the victim. Nanci walks through how to tell it apart from authorized credit push fraud, what the ODFI and the RDFI each get to see, and the healthcare scheme that surprised even her. Her name for the ACH and wire operations staff carrying this load: true crime fighters.

IN THIS EPISODE

 | 0:00 | Meet Nanci McKenzie, payments expert at Capital One
| 1:34 | First party fraud vs. authorized credit push fraud, and why intent is the dividing line
| 3:56 | Where money mule recruiting and first party fraud overlap
| 5:08 | From friendly fraud to the no-receipt return: how the schemes evolved
| 7:56 | Bust-out fraud on loans and credit lines
| 11:07 | The March and June rules put fraud monitoring on the RDFI
| 12:02 | What the ODFI sees, what the RDFI sees, and the behavior changes to watch
| 15:37 | Synthetic ID, the 30 to 60 day window fraudsters wait out, and an $850,000 romance scam
| 23:51 | Healthcare fraud: 455 charged, $6.5 billion, three schemes
| 28:16 | Red flags an RDFI can actually look for, and how investigators are using AI on SARs
| 30:06 | A shoutout to the ops teams Nanci calls the real crime fighters
| 33:38 | Last word: review your fraud monitoring, and join Nanci at the symposium

LINKS INCLUDED

Guest: Nanci McKenzie on LinkedIn, https://www.linkedin.com/in/nancimckenzie/
Mentioned: NEACH End User Payments Fraud Symposium, September 22 and 23, virtual
Show: More from NEACH, NEACH > Podcasts > Wrestling Payments

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One Employee, Five Branches: The Wire Room Reality

SHORT SUMMARY

NPG surveyed roughly 45 banks about how they actually run wires and found almost no consensus. Sean Carter walks through the numbers, including the 32 percent that train annually on their wire policy and the wire rooms covering more than five branches per employee.

EPISODE DESCRIPTION

Sean Carter, President and CEO of NEACH and NPG, brings back the findings from an NPG project reviewing one regional bank’s wire operation, plus a survey of roughly 45 community and regional institutions. He went in looking for the 80 percent answer, the thing most banks do the same way. He did not find one. In the same week, Sean had to send a wire himself as a business customer, which turned a set of survey results into a very concrete 45 minutes at a branch counter.

IN THIS EPISODE

 | 0:00 | The NPG wire operations project and a 45-institution survey
| 1:10 | A wire Sean had to send himself, and eight versions of the same question
| 2:20 | Wire rooms, Monday peaks, and the staffing math
| 3:30 | What the bank asked for: fewer exceptions, less delay, no added risk
| 5:00 | Looking for an 80 percent answer and not finding one
| 6:20 | Only 46 percent let consumers send wires digitally
| 7:22 | Would being set up in advance have saved any time?
| 9:32 | Why FedNow and RTP are not a like-for-like swap
| 10:50 | 61 percent are unsure about moving volume to instant payments
| 11:44 | Rules vs. regulator expectations on instant vetting
| 13:37 | Reg E remittance rules, and the opening that leaves for Western Union
| 14:58 | Everyone has a wire policy, 32 percent train on it annually
| 16:20 | 35 percent turn new branch staff loose in under a month
| 18:08 | More than five branches per wire employee
| 21:52 | The Fedwire address change, now delayed
| 23:16 | Irrevocability, 93 percent OFAC confidence, and the fear of hitting the button
| 25:19 | Wrap: the survey results, and an open invitation to a wire room

LINKS INCLUDED

Mentioned: The full NPG wire survey results, with the questions included so listeners can self-answer and compare. Link to be added before publication.

Show: More from NEACH, https://www.neach.org

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Jordan Bennett, AAP, APRP (Senior Director, ACH Network Risk Management at Nacha) joins Joe ahead of NEACH's End User Fraud Symposium to break down the new ACH rules targeting social engineering fraud — and for the first time, they put real obligations on originators, not just financial institutions.

Jordan Bennett

Key topics
Jordan Bennett introduces himself as Senior Director of ACH Network Risk Management and explains how his work now includes helping originators adapt to newer ACH rules.

• The symposium format is explained - one day for financial institutions, one day for end users and companies so both sides can talk through fraud from their own perspective.
• The new ACH rules are aimed at social engineering schemes, not just traditional unauthorized debit fraud that the industry has gotten much better at managing.
• Vendor impersonation is a major risk: a fraudster pretends to be a supplier, claims banking details changed, and tricks a company into sending money to the wrong account.
• Simple controls can block many scams, especially dual approval and callback procedures using a trusted internal contact list instead of the email sender’s phone number or reply contact.
• Urgency is a major red flag. If someone says a payment must go out right now and there is no way to verify it, Jordan says to slow down and treat it as suspicious.
• Real estate has been ahead of the curve for years because wire fraud during closings can derail the whole transaction, not just steal the funds.
• Account takeover and phone-based fraud are still active, including scams where someone impersonates a bank’s fraud department and asks for one-time codes or login credentials.
• If fraud is suspected, speed matters. Call the financial institution immediately, get the receiving bank involved, and move fast before the money disappears.
• Businesses face different protections than consumers, so companies need to understand their own responsibility and not assume consumer-style safeguards will apply.
• The same fraud prevention mindset should apply across payment methods, including ACH, wires, and checks.
• Check fraud comes up as a major industry issue, with both the Federal Reserve and payment organizations trying to reduce exposure.
• Jordan also mentions first party fraud as an upcoming topic, especially as banks and originators wrestle with customers disputing transactions they originally authorized.

More from NEACH: neach.org

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How can community banks compete with the largest financial institutions in an AI-driven world?

In this episode of Wrestling Payments, host Joe Casali sits down with Sean Carter, President & CEO of NEACH, and Toli Amare, co-founder of Predium.ai, to discuss how artificial intelligence, decision intelligence, and data analytics are transforming banking.

From fragmented data and outdated reporting processes to real-time scenario modeling and fraud detection, this conversation explores how financial institutions can leverage AI to make faster, smarter, and more confident decisions—without needing a team of data scientists.

Whether you're a community banker, fintech leader, executive, or payments professional, you'll gain practical insights into how better data leads to better decisions, stronger profitability, and a competitive edge.

In This Episode
Why data quality is the foundation of effective AI
The hidden costs of fragmented banking systems
How Decision Intelligence helps executives make smarter business decisions
Real-time scenario modeling for mergers, pricing, and strategic planning
Using AI to identify profitable customers and products
Fraud detection through continuous data monitoring
Why community banks can compete with larger institutions using modern analytics
The role of financial expertise alongside AI technology
Practical examples of merger analysis, profitability modeling, and risk management
The future of AI in banking and continuous decision optimization

Key Takeaways
✔ Turn disconnected banking data into actionable insights
✔ Test strategic decisions before committing capital
✔ Improve profitability with customer and product-level analytics
✔ Detect operational risks and fraud in real time
✔ Make faster, more confident executive decisions using AI

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Understanding the Future of Fintech Regulation: The Cage Match BeginsIn this episode of Wrestling Payments, Joe Casali dives into the recent executive order that aims to overhaul fintech regulation. As the landscape shifts, understanding how regulation affects fintech firms, banking partnerships, and consumer protections becomes critical for industry participants and observers alike.

In this episode:

• The core aspects of the May 19th executive order titled "Integrating Financial Technology Innovation into Regulatory Frameworks"
• The current fragmented regulatory environment and the gaps fintechs face
• How executive orders influence regulatory change and the potential scenarios that could unfold
• The implications of direct access to Federal Reserve accounts for non-banks
• The disparities across states in regulating fintechs and their consumer protections
• The potential impacts of the new framework on bank partnerships and the overall payment infrastructure
• Key questions for the industry moving forward: participant categories, due diligence, dispute resolution, and failure protocols

Resources & Links:

• Federal Reserve, Executive Order on Financial Technology
• NACHA Operating Rules
• The Geniuses Act
• OCC Fintech Charter Initiatives
• PACE Act Overview
• White House Executive Order

Connect with Joe Casali:

• LinkedIn

Stay tuned for future episodes as the regulatory landscape continues to evolve, shaping the future of fintech and payments.

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Episode Description

The Federal Reserve just proposed changes to Regulation J that would allow FedNow participants to designate intermediary banks — opening the door for cross-border payments over FedNow for the first time.

Joe Casali breaks down what the rule actually changes, how the domestic and international legs of a cross-border FedNow payment would work, and why this might be the moment ISO 20022 finally proves its value. He covers the competitive implications for Fedwire, the BSA/AML screening challenges of real-time international transactions within a 20-second timeout window, and what community banks and credit unions on FedNow should be thinking about right now.

The 60-day comment period begins April 10, 2026. If your institution has a perspective on this proposed rulemaking, now is the time to make your voice heard.

References: Federal Reserve Proposed Rulemaking — Docket No. R-1891, RIN 7100-AH23 | Regulation J, Subpart C — 12 CFR Part 210 | Submit comments at federalreserve.gov/apps/proposals | FedNow Operating Procedures v3.5 (February 2026)

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Episode Summary
In this episode of Wrestling Payments, host Joe Casali sits down with Phil Robin, SVP of Strategy at The Clearing House. They explore how financial institutions are approaching the challenges of modernizing payment operations, with a focus on risk, governance, and the rapid pace of change in new technologies.

Phil shares his perspective on the importance of building strong governance around artificial intelligence, noting that a clear framework helps institutions manage both cultural and operational risks as they introduce new tools. He highlights the varied approaches that banks take, shaped by their unique priorities and use cases, and stresses that inaction is often the greater risk as AI becomes more integrated into payment processes.

The conversation moves to emerging topics like stablecoin, tokenized deposits, and the steady growth of real-time payments (RTP). Phil explains how shifting regulatory clarity and evolving customer needs are driving experimentation, especially in areas like business-to-business and consumer-to-business payments. He points to the ongoing expansion of RTP and the need for broad acceptance to reach true scale, encouraging payment leaders to keep their eyes on both innovation and fundamentals.

💡 Name: Phil Robin
💡 What he does: SVP, Strategy
💡 Company: The Clearing House
💡 Noteworthy: Guides strategy projects focused on payments innovation, governance, and risk, with deep expertise in real-time payments and industry modernization.
💡 Where to find him:https://www.linkedin.com/in/philrobin1/

Key Insights
Focus on Governance First When Adopting AI

Strong governance is the foundation of responsible AI adoption in payments. Before diving into the promise of artificial intelligence, organizations must set clear rules and accountability. This means building frameworks around data security, transparency, and risk appetite to ensure any AI use aligns with institutional priorities. When banks and payment providers define the “rules of the road” early, they give staff and leadership confidence to experiment and scale new tools. Governance also helps ease cultural resistance by making the organization’s approach to AI visible and consistent. With guardrails in place, teams can better focus on the practical benefits of AI—like automating manual tasks or unlocking growth opportunities—without losing sight of the risks. The key takeaway: don’t treat governance as an afterthought or a compliance hurdle. Make it the starting point for any serious AI strategy in payments.

Instant Payments Will Scale Through Use Case Diversity
Real-time payments (RTP) have moved from concept to reality, but true growth hinges on solving a wide range of business needs. Volume keeps hitting new records, yet the next wave of adoption will depend on how RTP addresses complex problems, especially in areas like business-to-business and healthcare payments. Each segment brings unique challenges around data, timing, and control. For example, B2B payments often involve detailed invoices and reconciliation, while brokerage transfers demand speed and confirmation. As more financial institutions explore RTP for these distinct cases, the network’s value and reach will expand. Building for use case diversity ensures that RTP is not just a faster way to pay, but a flexible tool that adapts to industry-specific workflows. Payment professionals should keep looking for unmet needs—these are where RTP can deliver the most impact and drive long-term adoption.

Stablecoin and Tokenization: Navigating Fast-Moving Terrain
The landscape for stablecoin and tokenized deposits is evolving quickly, creating both urgency and uncertainty for banks. Regulatory changes, like recent national trust charter approvals, h