Back in July 2023, I wrote a post about financial remote onboarding which included a section entitled “Three changes in banking over the last fifty years.” The first change I addressed was locational change.
The first crack in the whole idea of “going to the bank” was the ability to bank without entering the door of the bank…and being able to bank on Sunday at midnight if you felt like it. Yes, I’m talking about Automated Teller Machines (ATMs), where the “teller,” instead of being a person, was a bunch of metal and a TV screen.
But when I was recently reading a Bluesky post from mclevin that stated (correctly) that the decline in tellers didn’t start with artificial intelligence, but automated teller machines, it occurred to me that even the once-revolutionary ATM is itself outdated in financial terms.
Think about it.
What are the two most important functions of an ATM?
To deposit paper checks.
To obtain physical cash.
I think you see where this is going.
While the ATM still fulfills these functions today, how often do we receive paper checks? And even if we do, why go to a distant ATM to deposit the check when you can often perform the same function using your mobile phone?
And how often do we use cash to pay for things? Often we use a card…or a mobile phone.
I asked my good buddy Google Gemini to describe the court arguments against FinCEN beneficial ownership reporting (which as of this hour is on a court-mandated hold pending a possible Supreme Court stay). Two of the items identified by Gemini are Bill of Rights related.
“Some argue the reporting requirements force businesses to disclose information about their owners, which they consider a form of compelled speech. The First Amendment protects freedom of expression, and this argument suggests the government is overstepping its bounds.”
“Critics argue that the collection of beneficial ownership information constitutes a search under the Fourth Amendment. They contend that this collection is overly broad and lacks sufficient justification to meet the constitutional standard of reasonableness.”
So the big boys are still subject to KYC, KYB, and AML regulations, while the little boys (sole proprietors) aren’t. The ones in the middle who would have been subject to the Corporate Transparency Act remain in a state of limbo.
Of course, if an anonymous entity claimed that BOI opponents are Putin lovers who want to hide terrorist activities, those same opponents would want to know who is saying that about them. What’s good for me isn’t good for thee…
Two days later, December 26, my December 24 blog post was already outdated.
“On December 26, 2024, a different panel from the Fifth Circuit issued an order that vacated the court’s prior December 23 order granting a stay of the preliminary injunction. As a result, the injunction issued in Texas Top Cop Shop remains in effect nationwide and reporting companies are currently not required to file beneficial ownership information with FinCEN.”
It all started with “Know Your Customer,” a shorthand phrase used by financial institutions and related entities who need to know who their customers are.
But then various governments, industries, and entities got into the act with their own variants, such as “Know Your Business.”
I was curious about how many of these “know your” variants I’ve discussed in the Bredemarket blog. Here’s what I found:
Beneficial Ownership Information alert. From Proskauer:
“On December 23, 2024, the Fifth Circuit of the United States Court of Appeals (the “Fifth Circuit”) issued an order that has the effect of reinstituting the deadlines under the Corporate Transparency Act (the (“CTA”)….
“The CTA requires a range of entities, primarily smaller, otherwise unregulated companies, to file a report with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) identifying the entities’ beneficial owners—the persons who ultimately own or control the company—and provide similar identifying information about the persons who formed the entity.
“FinCEN has recognized that the timing of the order lifting the injunction may be particularly burdensome and has extended the reporting deadlines. Accordingly, reporting companies created prior to January 1, 2024, that are not eligible for an exemption, are required to file beneficial ownership reports by January 13, 2025 (and not January 1, 2025).”
If you look at the evidence, it may appear that financial fraud is being committed by kids. But that’s not accurate; it’s being committed by fraudsters who are impersonating kids, according to the National News.
“”Fraudsters are targeting children’s identities because they can exploit the information for an extended period,” said Rob Woods, director of fraud and identity for LexisNexis Risk Solutions….
“With criminals well aware of the likelihood of the child’s identity theft going undetected, Mr Woods said LexisNexis is seeing criminals opening bank accounts, applying for loans and even committing other financial crimes with the fake identity.”
So perhaps you had better check Junior’s credit rating.
Healthcare is complicated. When most of us receive prescriptions from our doctor, either the doctor gives us a physical slip of paper with the prescription, or the doctor electronically sends the prescription to your pharmacy of choice. After that, you deal with the pharmacy yourself. Normally it goes smoothly. Sometimes it doesn’t.
Maybe the patient’s insurance company doesn’t cover the prescription, or charges an exorbitant price for it.
Maybe the patient never picks the prescription up. (The industry term is “adherence.”)
There are a lot of companies that want to help drug companies, physicians, and others make this process more seamless and less costly (for example, by maximizing gross-to-net, or GTN).
How many companies want to help? One afternoon I estimated that 30 companies are in this market. Based upon past experience in the identity verification industry (namely, all those battlecards my team created), this means that there are probably really more than 100 companies in the market.
While the companies obviously have to please the patients who need the prescriptions, they’re not critically important because the patients (usually) don’t pay the companies for the improved service.
So the companies have to sell others on their services.
Alto Technologies: “Alto Technologies’ configurable platform integrates hub and dispensing capabilities into an automated and seamless single service provider solution that improves patient experience and reduces administrative burden.”
Medisafe: “Patient support begins with onboarding and continues throughout treatment, with intuitive guidance throughout every encounter. From initial prescription to benefits investigation and authorization to shipment tracking, patients receive streamlined support with educational information and real-time updates.”
Phil: “Streamline medication access for your patients and providers. Our digital hub platform empowers retail and specialty-lite manufacturers with an alternative channel solution…”
Truepill: “Whether you’re an established brand looking to reach your patients directly, or an emerging company planning your go-to-market strategy, Virtual Pharmacy is the digital pharmacy solution built to scale.”
I refrained from discussing this for a couple of days, but I was recently a victim of attempted financial identity fraud.
Well, SORT OF attempted identity fraud. I don’t know if this really counts, since I don’t know if the fraudster had my identity.
But the issue was resolved in less than 48 hours.
By the way, I have purposely changed the names of two of the companies I mention, to protect my PII. Which is a shame, because “Wildebeest Bank” went above and beyond in correcting the issue.
That doesn’t look right
Among its other services, Wildebeest Bank (not its real name) sends me an email whenever a purchase is made on my card, but my card is not present.
This is a fairly common occurrence. Among other things, my website, my business insurance, my business address, and my accounting software are all billed to my card.
But less than 48 hours ago, at 3:30 pm on Wednesday afternoon, I received an unexpected notice.
Your card was not present during a recent purchase
Your card was used to make a purchase at enron*publications us
We noticed your check card ending in 1234 was used to make a $8.48 purchase at enron*publications us today. The card wasn’t present at the time the purchase was made.
If you did not make this purchase, please call the nuber listed on the back of your card.
Log in to your account to review this transaction.
I didn’t recall making any $8.48 purchase, and once I looked up enron*publications us (not its real name), I realized that I definitely DIDN’T purchase anything from that company.
Before calling the bank, I double checked my account and found NO transaction for $8.48, even in a “pending” state.
So I called Wildebeest Bank
I called the number on the back of my card and connected with a woman in a call center who investigated why I got an email for a transaction that didn’t appear.
This is obviously not the Wildebeest Bank call center woman who helped me. But I’m sure she had a computer. By Earl Andrew at English Wikipedia – Own work, Public Domain, https://commons.wikimedia.org/w/index.php?curid=17793658
After accessing several internal systems, the woman discovered that the purchase was attempted, but declined. The fraudster had my card account number, but didn’t have the correct expiration date.
Frankly, I’m not even sure if the fraudster had my name. Did the fraudster just punch in 16 digits and hope they would work?
Anyway, after this conversation, the woman from Wildebeest Bank transferred me to the fraud department.
The Fraud Department
So my call was transferred to the Fraud Department.
The man at the Fraud Department advised me to cancel the card and get a new one.
I was wondering how long this would take, since one of bills was going to be charged to my card in the next two weeks, and I didn’t want any hiccup from a denied card purchase.
Anti-Fraud Man explained that if I could go to a Wildebeest Bank branch by the next day (Thursday), I could get a new card immediately.
“Could I go today?” I asked.
“Sure,” he replied.
It was about 3:50 pm by that time, or 20 minutes since I received the initial email.
So I drove to the bank
I hopped in my car, drove to a local bank branch, and went to a desk.
You may recall that I started Bredemarket in the fall of 2020, right in the middle of COVID. When I opened my account, the bank WOULDN’T let me go to my local bank branch and I had to open the account remotely. Since then I’ve been in the bank branch several times; it’s a nice place.
Anyway, the fraud department had already cancelled my compromised card, so the man at the bank branch only had to issue me a temporary card and guide me through its activation. This temporary card would last me until the new card arrived in the mail. It had the same card number as the new card so I could temporarily use it for purchases, but the permanent card would have a different expiration date and security code.
I could have provided the temporary card’s number, expiration date, and security code to the company that was going to bill me in two weeks, but I preferred to wait until I received the permanent card. I asked the man at the bank branch how long that would take.
“I can expedite it,” he said.
I get a present at Box 259
Less than 48 hours later, on Friday morning, I was notified that I had a package at my business address.
Bredemarket’s mailing address is 1030 N Mountain Ave #259, Ontario CA 91762-2114.
As I guessed, it was the permanent card, which I immediately activated and provided to the companies that auto-bill me via my card.
Here’s the short version:
My bank (“Wildebeest Bank”) notified me of a questionable “card not present” purchase (from “enron*publications us”) at 3:30 pm on Wednesday.
By 3:50 pm (20 minutes later), the bank told me that the attempted purchase was declined, but cancelled the bank card anyway.
By 4:15 pm (45 minutes later), I had a new temporary bank card.
By Friday at noon (less than 48 hours later), I had my permanent bank card.
So everyone be sure to bank at Wildebeest Bank. No confusion when you bank with them!
Checking the purported identity against private databases, such as credit records.
Checking the person’s driver’s license or other government document to ensure it’s real and not a fake.
Checking the purported identity against government databases, such as driver’s license databases. (What if the person presents a real driver’s license, but that license was subsequently revoked?)
Perform a “who you are” biometric test against the purported identity.
If you conduct all four tests, then you have used multiple factors of authentication to confirm that the person is who they say they are. If the identity is synthetic, chances are the purported person will fail at least one of these tests.
Do you fight synthetic identity fraud?
If you fight synthetic identity fraud, you should let people know about your solution.
Whether you’re an employee or a sole proprietor, at some point you’re going to have to play well with others to get things done.
Bredemarket has performed this (fancy phrase: “cross-functional collaboration”), both as part of Bredemarket’s services and outside of it.
As an employee, I’ve managed SaaS proposal projects and other projects that needed the input of many.
Within Bredemarket, I’ve managed proposal and other projects of similar complexity.
Even though I’m not formally certified to do this, I do it anyway.
Pre-Bredemarket: I get SaaSy
Long before I started Bredemarket, I was managing products and proposals associated with an on-premise technology solution.
This solution had a long sales cycle (longer than Cloudflare’s, for example) and a long implementation time. After contract signature, it might take a year or more to lock down the requirements, procure the hardware and third-party software, configure the solution, perform a factory acceptance test, deliver the solution to the customer’s premises, perform one or more rounds of on-site testing, and obtain final acceptance.
But my employer wasn’t lacking in revenue during implementation, because it received partial payments as it passed various milestones. Perhaps a small percentage of the total price would be paid upon requirements completion. Another percentage at delivery. Additional percentages at different points in the implementation, with the final large payment upon acceptance.
But then I was the proposal manager for a prospect desiring a SaaS implementation.
The Request for Proposal (RFP) made it very clear that the prospect would not pay a dime to the successful bidder until AFTER the system was accepted and in productive use. Because that’s how SaaS implementations work.
This would have a major financial impact on my employer, since it would take a much longer time to recoup the initial costs of the implementation.
Without going into details…we didn’t, um, “win” the bid.
Several years later, the, um, SITUATION had changed, and my employer was more willing to accept the financial risks associated with SaaS implementations. I was still a proposal manager at the time and was able to work on my employer’s first successful SaaS bids. But that assumption of risk wasn’t the only barrier to success, because I had to work with a lot of different cross-functional collaborators to get those bids out.
The salespeople who wants to sell the SaaS systems to their prospects.
The engineers who had to do the heavy lifting to transition our on-premise solution to a SaaS solution.
The program managers who had to keep an eye on the costs of the implementation to ensure that our employer’s financial risk was minimized.
The customer support people who had to manage the system after final acceptance, even though much of the system was in a cloud center somewhere instead of at the customer’s site.
The finance and pricing people who had to adjust to this new way of doing business.
The legal people who had to develop a brand new contract that encompassed the new reality.
Finally, the executives who were willing to take the risk to enter the SaaS market and who wanted to succeed without losing money.
I think this is when I made my observation about managers of large proposals. In a large project, the proposal manager is the only one who spends 100% of their time on the project. The salespeople are selling other deals, the engineers are engineering other stuff, and so forth. Therefore, it was up to me to ensure that everything continued to move forward, because while these bids were important to the others, they were critically important to me.
Anyway, these later bids had a much happier ending, the employer successfully entered the SaaS market, and as more customers moved from on-premise to SaaS models, thus evening out my employer’s income stream, the financial risk from SaaS proposals was reduced significantly.
That cross-functional collaboration experience, exercised on these bids and in many other instances over the years, would be put to the test a few years later when I started Bredemarket.
It’s one thing for a company employee to manage a project with a ton of people, none of whom report to you and most of whom outrank you.
It’s another thing when an outside contractor has to manage a project of inside employees.
One of my Bredemarket projects, which happened to be another proposal project, required me to do just that. While the proposal was much simpler than the bids constructed at my former employer, the effort still required a lot of shepherding to get all the pieces put together, obtain all the approvals, and get someone to submit the final proposal since I, as a non-employee, couldn’t do it myself.
Everything worked out, and the employees were great, but there were times when it seemed like I was the only one to keep an eye on all the tasks.
Something that I had never been formally trained to do.
Today’s acronym is PMP
Eventually I (temporarily) stopped working on finger/face projects for Bredemarket because I was employed by a finger/face company. And I found myself managing projects of similar complexity (the 80+ battlecard project, for example).
And that’s when I realized that I was a de facto project manager.
Even though I didn’t have the fancy certification to attest to this.
I toyed around with the idea of starting the certification progression in 2023, and even though my employer didn’t have the rigorous annual goal-setting processes that larger organizations have, I set a personal goal in one of my employer’s Asana projects to advance to CAPM by the end of 2023.
And then…things happened.
Perhaps at some point I’ll get the official piece of paper that I can flash around, but until then I’ll learn on my own, both by coursework and by…well…actual managing projects.
Bredemarket 