WPF urges the Federal Reserve Board of Governors to ensure quality assurance and control mechanisms for biometric authentication in debit card payment systems 

In comments filed with the Federal Reserve Board of Governors, WPF supported proposed language for Comment 235.7 (A)-1, Scope of Restriction, with the understanding that more needs to be done to determine and set quality assurance measures for debit card payment system authentication methods in general, and for biometric methods in particular. WPF requests that the Board of Governors undertake an analysis of what it could do, or what could be done, to create standards and quality assurance mechanisms in this area to ensure the highest possible quality, efficacy, and fairness of all debit card authentication systems. 

Determining the parameters of what quality assurances should be required in a debit payment system, what the acceptable cut-off levels are for the system, and what consumers should be required to be informed of regarding efficacy, accuracy, safety, among others will be important to both ensure quality of authentication and to ensure consumer trust in the ecosystem. How accurate, exactly, must a biometric system be in this context? This is something that WPF would like to see as part of the discussion. 

Guidance should ensure that authentication technologies are required to produce results that are consistent with existing financial sector regulations, including the protection of vulnerable classes, as described in the Equal Credit Opportunity Act. A biometric system utilized for debit card payment authentication purposes should be able to demonstrate that it operates with provably low to no problems with accuracy or bias, including race, age, gender, and ADA, among other values, such as resilience against fraud. 

Related documents: 

WPF Comments on authentication in debit card payment systems (PDF, 4 pages)