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               of protected consumer financial information to third parties (like   Street Journal, Equifax spent over $1
               marketing partners) and consumer rights to opt out of such transfers.  million last year lobbying against
            •  Impose strict data security requirements for credit reporting agencies,   several federal legislative initiatives
               and require the FTC to approve those security plans.                that would impact the company,
                                                                                   including those related to data
            •  Have the FTC and CFPB study the need for any new rules necessary to   security and breach notifications.
               protect financial information maintained by credit reporting agencies
               and other businesses.                                               A Congress that lacks the conviction
                                                                                   to take on complex and controversial
        It will be interesting to see how Equifax reacts should Congress muster the   issues like health care, the federal
        will to take on data breach legislation. According to a Sept. 11 report in the Wall   budget and tax reform, however,
                                                                                   may also lack the gumption to take
                                                                                   on the task of legislating federal data
                                                                                   security standards and procedures.
                                                                                   It  is also  worth  noting  that Sen.
                                                                                   Menendez is currently fighting
                                                                                   corruption charges in federal court,
                                                                                   so he may not be in a position to
                                                                                   push the legislation.

                                                                                   Implications for card payments
                                                                                   Everyone in the electronic payments
                                                                                   space should be concerned about this
                                                                                   situation because, as we know all too
                                                                                   well, breaches of private consumer
                                                                                   financial information are a leading
                                                                                   contributor to payment fraud.

                                                                                   Consumers understand this. Among
                                                                                   those participating in a recent
                                                                                   survey sponsored by the  ATM
                                                                                   company Cardtronics, 84 percent
                                                                                   said they are worried about data
                                                                                   security. That's one reason why
                                                                                   many use cash. Ninety-one percent
                                                                                   of those surveyed reported they had
                                                                                   made cash payments in the previous
                                                                                   six months; debit cards were used
                                                                                   by 72 percent, and credit cards
                                                                                   by  68  percent  of  those  consumers
                                                                                   surveyed.

                                                                                   Cash charts especially high usage
                                                                                   among consumers when they make
                                                                                   small-dollar purchases, said Brian
                                                                                   Bailey,   Cardtronics   Managing
                                                                                   Director for North America. Fifty-
                                                                                   five percent of those surveyed prefer
                                                                                   cash for purchases under $20.

                                                                                   Bailey isn't convinced incidents like
                                                                                   the Equifax breach will spur greater
                                                                                   cash usage at the expense of cards.
                                                                                   "There's an innate security risk with
                                                                                   any payment method," he said. I
                                                                                   suspect, however, it may render more
                                                                                   difficult initiatives for migrating
                                                                                   small-dollar cash purchases to cards
                                                                                   and other electronic options.

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