Skip to main content

Regulation E.

Spent the weekend digging into Regulation E., particularly Section 205.11. That’s the part where you try to convince your regional bank that you really didn’t authorize those charges, that you were not ‘card present’ in New York, and you didn’t have homeless people in your house rummaging through your stuff, borrowing your debit card, jetting to the east coast, buying cosmetics and jetting back.

This isn’t unexpected. We’ve kept this debit card attached to a special checking account that we never have more than $400 in at any time, just for this reason. The theory is that transactions will start to fail before the damage gets too expensive. In practice, I’m not sure if the bank will honor the overdraft attempts or not. I’d be un-amused if they had some sort of ‘convenience’ feature that turned the fraud into overdrafts and then into 22% loans. That would be a bad day.

This particular card was only used at a small number of merchants, mostly local and regional grocery chains, so my guess is that either a local/regional merchant or their upstream provider has a leak. The bank had already pulled the card and reissued it a couple days before we saw the bogus transactions.

So now I’m in paranoid mode, or more likely I’m in more-paranoid-than-usual mode. The good news is that I can finally close the loop on what I’ve been saying for years, namely ‘I wouldn’t be paranoid if everyone weren’t out to get me!’.

BofA-AlertsUnfortunately the regional bank doesn’t have anything that helps mitigate something like this other than checking your online statement every day and sending a postal letter to ‘Regulation E Department’ when bad things show up. Bank of America, on the other hand, lets me do a few interesting things. First they let me use my cell phone as a two-factor SMS based proxy when logging in to their web portal with what they call SafePass® (details here).

Second, they allow me to generate single-merchant, limited value card numbers for online transactions with what they call ShopSafe®. With ShopSafe I can spin up a different card numbers with different limits and expiration dates for each online vendor on an ad-hoc or as needed basis. This allows me to approximate single use cards.

Third, they have a reasonably robust SMS alerting system that allows me to set up alerts for routine activity that may or may not be an indicator of irregular activity, such as ‘any charge over $50’ or ‘Transaction outside of US’. BofA-Alerts2They send me the SMS, I decide if it’s irregular. I like the idea of getting an SMS when someone logs into my account, changes my address, charges purchases online, orders checks, etc. Having some information ‘out of band’ can’t hurt. Unfortunately none of this really prevents anything, it just makes detection faster and easier.

The images list the various alerts that are configurable.

The only down side to getting an SMS every time you use your card is that some merchants don’t post transactions at the time of purchase. Occasionally I’ll buy something at noon and get woke up at 4am with an SMS from BofA telling me that I bought something 16 hours ago. Overall though, that’s better than any alternative that I know of, and in this case would have alerted us to the fraud much sooner.

For me, the more SMS’s the better.


Popular posts from this blog

Cargo Cult System Administration

“imitate the superficial exterior of a process or system without having any understanding of the underlying substance” --Wikipedia During and after WWII, some native south pacific islanders erroneously associated the presence of war related technology with the delivery of highly desirable cargo. When the war ended and the cargo stopped showing up, they built crude facsimiles of runways, control towers, and airplanes in the belief that the presence of war technology caused the delivery of desirable cargo. From our point of view, it looks pretty amusing to see people build fake airplanes, runways and control towers  and wait for cargo to fall from the sky.The question is, how amusing are we?We have cargo cult science[1], cargo cult management[2], cargo cult programming[3], how about cargo cult system management?Here’s some common system administration failures that might be ‘cargo cult’:Failing to understand the difference between necessary and sufficient. A daily backup is necessary, b…

Ad-Hoc Verses Structured System Management

Structured system management is a concept that covers the fundamentals of building, securing, deploying, monitoring, logging, alerting, and documenting networks, servers and applications. Structured system management implies that you have those fundamentals in place, you execute them consistently, and you know all cases where you are inconsistent. The converse of structured system management is what I call ad hoc system management, where every system has it own plan, undocumented and inconsistent, and you don't know how inconsistent they are, because you've never looked.

In previous posts (here and here) I implied that structured system management was an integral part of improving system availability. Having inherited several platforms that had, at best, ad hoc system management, and having moved the platforms to something resembling structured system management, I've concluded that implementing basic structure around system management will be the best and fastest path to …

The Cloud – Provider Failure Modes

In The Cloud - Outsourcing Moved up the Stack[1] I compared the outsourcing that we do routinely (wide area networks) with the outsourcing of the higher layers of the application stack (processor, memory, storage). Conceptually they are similar:
In both cases you’ve entrusted your bits to someone else, you’ve shared physical and logical resources with others, you’ve disassociated physical devices (circuits or servers) from logical devices (virtual circuits, virtual severs), and in exchange for what is hopefully better, faster, cheaper service, you give up visibility, manageability and control to a provider. There are differences though. In the case of networking, your cloud provider is only entrusted with your bits for the time it takes for those bits to cross the providers network, and the loss of a few bits is not catastrophic. For providers of higher layer services, the bits are entrusted to the provider for the life of the bits, and the loss of a few bits is a major problem. The…