Data Foundation responds to RFI on Potential Actions to Address Payments Fraud

The Data Foundation submitted the following comments in response to an RFI from the Federal Reserve, Federal Deposit Insurance Corporation, and the Comptroller of the Currency regarding payments fraud. 

September 18, 2025

Ann E. Misback 
Secretary  
Board of Governors of the Federal Reserve System 
20th Street and Constitution Avenue NW  
Washington, DC 20551

Jennifer M. Jones  
Deputy Executive Secretary  
Federal Deposit Insurance Corporation 
550 17th Street NW  
Washington, DC 20429

Chief Counsel 
Office of the Comptroller of the Currency 
Department of the Treasury 
400 7th Street SW Suite 3E-218  
Washington, DC 20219 

Washington, DC 20219 Re: Request for Information on Potential Actions to Address Payments Fraud  
(OCC Docket ID OCC-2025-0009 | Federal Reserve Board Docket No. OP-1866 | FDIC RIN 3064-ZA49 )

To Whom It May Concern – The Data Foundation appreciates the opportunity to provide input on the multi-agency Request for Information on Potential Actions to Address Payments Fraud, in particular as it relates to collecting and sharing payments fraud data. As a non-partisan, non-profit organization we conduct research, collaborative thought leadership, and advocacy programs that advance practical policies for the creation and use of accessible, trustworthy data.  

Over the past few years, the Data Foundation and our partners have explored governance models for secure data sharing, supported the implementation of the Financial Data Transparency Act, and advocated broadly for the use of data to improve society. We have also conducted extensive work on the value of data literacy in contemporaneous society. Our recent work focuses on access to and use of administrative data sources to strengthen program integrity and reduce improper payments, including fraud, in the federal government.  

[Full comment submission available below.]

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