Hi All,
I'll share more detail at the top of our next Monthly Meeting, but given the volume we're already seeing since launch of this net-new platform/government program, I wanted to get ahead of it now so we can make the experience smoother for the ~35 million eligible U.S. families. This program is lead by U.S. Treasury, with BNY as the sponsoring bank and Robinhood as platform custodian.
Background
Robinhood is acting as a custodian/provider for Trump Accounts, the federal investment account program for children established under Invest America Act Background and enrollment info:
What this means for fraud ops
Because Robinhood is the custodian, we're seeing a significant engagement and transactions volume with this net new program. There are two specific Card Transactions you will see:
- AFT's Debit Card only Deposits, MCC 6211, Statement Descriptor TRUMP ACCOUNT DEPOSIT
- We will not be support withdrawals
- Debit Card Gifting (external) Checkouts, MCC 6211, Statement Descriptor TRUMP ACCOUNT DEPOSIT
Additional Details:
- There is a limit of deposit contributions of $5K per child, per account.
- We are requiring 3DS at every card transaction if supported
- We will provide complete AFT details as required by the Card Networks i.e. Sender/Receiver details
Based on the initial transaction volume we are seeing some issuers with heavy risk scoring or limiting debit card velocity for this program - specifically:
- Outright declines on these transactions
- Do Not Honor declines after initial deposits
- Velocity flags, since many small, similar-looking contributions in short succession look like structuring even though they're normal program behavior
The ask
We're requesting a increase to velocity thresholds/dollar thresholds and removal of any outright restrictions for these transactions while this new program continues to rollout. Remember this is a government program supporting 35 Million US Families and their future financial wealth.
I'll walk through more details in our next call. In the meantime, if you're seeing a spike in declines/flags that match this pattern and need more details, please feel free to reach out to me directly.
Michael A. Silver, CFE | Cell (650) 313-9610
Robinhood Markets, Inc
CTS Platforms Strategic Partnerships & Detection and Prevention Lead
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Michael Silver
Fraud Detection and Prevention Lead
Robinhood Markets, Inc
Westlake TX
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