News and insights from the Ingo team.

For over a decade, I’ve watched the payments industry act like a city transportation department obsessed with building newer, faster train lines. First it was the peer-to-peer express, then the blockchain bullet train – each promising to be the next breakthrough in moving money. But as we look toward 2025, I’m convinced we’ve been focused on the wrong goal. After all, a shiny new train line doesn’t help if you really need to take a bus, grab a taxi, or ride your bike. What people really want isn’t another way to get from point A to point B – they want the freedom to travel anywhere, anytime, using whatever transportation makes sense for their journey. The same is true for money movement. Beyond the Rails: The Real Payment Revolution The numbers tell the story. Heading into 2025, the CFPB will now oversee more than 13 billion annual consumer payment transactions. The average consumer juggles multiple bank accounts, payment apps, and digital wallets. Businesses need to pay out through everything from instant deposit to digital wallets to paper checks. It’s like asking someone to buy separate tickets for every mode of transportation they might need on a trip – inefficient, expensive, and unnecessarily complex. And this complexity isn’t just theoretical. Take for example an insurance company trying to process claims payments. They might need one system for ACH transfers, another for check printing, another for card payments, and yet another for digital wallet transfers. Each system has its own integration requirements, risk management protocols, and regulatory considerations. It’s like running four different transit authorities in the same city, each with their own ticketing systems, safety protocols, and schedules. The operational overhead is enormous, and the potential for things to go wrong multiplies with every new system added. Yet most payment solutions still force consumers and businesses into rigid pathways. Want to deposit a check? Wait three days at the station. Need to move money between accounts? That’ll be a 24-48 hour layover. Want to receive an insurance payout instantly? Sorry, you’re on the wrong line – please transfer to platform 9¾. This fragmentation isn’t just inconvenient – it’s becoming a regulatory liability. When Ingo first pioneered push-to-debit capabilities over a decade ago, we were solving what seemed like a simple problem: getting money to a consumer’s debit card instantly. But we quickly learned that speed without security creates chaos. It’s like building a high-speed rail system without proper safety signals and crossings – you’re just creating new risks at higher speeds. As payment volumes grow exponentially, regulators are demanding stronger consumer protections and more sophisticated risk management. The old model of treating each payment rail as its own isolated transit system simply won’t cut it anymore. The solution isn’t building more isolated systems, it’s fundamentally rethinking how we connect and secure all forms of money movement. The Rise of Intelligent Money Movement What’s emerging instead is a new paradigm I call “intelligent money movement.” Think of it as a universal transit pass that works across every form of transportation, with built-in safety features and real-time journey planning. This approach focuses on three critical elements that will define successful payment platforms in 2025: First, unified risk management across all transaction types. Whether you’re taking a train, bus, or taxi, you want consistent safety standards. The same goes for money movement – whether it’s a check deposit, card load, or ACH transfer, every transaction needs real-time risk scoring and fraud prevention. Second, instant availability with appropriate controls. Just as modern transit systems can fast-track known commuters while adding extra security checks for unusual journeys, smart payment platforms use real-time data to make funds available instantly when safe while applying additional verification when needed. This intelligent approach to money movement isn’t just about making things faster – it’s about making them smarter. Our experience processing billions in transactions has shown that different payment types carry different risk profiles, just like different types of journeys require different levels of security. A payroll deposit from a known employer is like a daily commuter train – predictable, regular, lower risk. A large check deposit from an unknown source is more like an international flight – it requires additional verification to ensure everything is legitimate. The key is having systems intelligent enough to adapt security protocols based on the type of journey. Third, complete payment freedom for the end user. Your transit pass should work everywhere, and your money should move just as freely. The platform shouldn’t care whether someone wants their insurance payout on a debit card, in their PayPal account, as a paper check, or on a new, instantly issued account. Building for 2025: A New Architecture for Money Movement This vision requires a fundamental rethinking of payment architecture. Instead of building separate stations for every type of transportation, enterprises need unified hubs that can: Handle any payment source or destination through a single integration Apply consistent risk management across all transaction types Provide real-time visibility into money movement Maintain regulatory compliance at scale For enterprises building or expanding payment capabilities, here are the critical considerations for 2025: Audit your money movement infrastructure: Map out every vendor, integration, and system needed to process different payment types. Each connection is a potential point of failure. Assess your risk management consistency: Test whether a $1,000 transaction gets the same level of scrutiny whether it’s coming through ACH, card deposit, or check scanning. Inconsistency creates vulnerability. Evaluate your customer experience: Try to complete common payment journeys through your platform. If customers hit dead ends or forced detours, you’re limiting their financial freedom. My 2025 Prediction The technology to enable this vision already exists. We’re seeing and helping leading enterprises implement unified payment platforms that can process everything from instant digital account funding to disbursements through a single integration. These platforms are proving that with the right architecture and risk management capabilities, you can offer payment freedom without compromising security or compliance. The real challenge ahead isn’t technical innovation – it’s embracing a fundamental shift in how we think about moving money. Just as modern cities succeed by connecting their subways, buses, bikes, and rideshares into one seamless transportation system, tomorrow’s payment leaders will win by unifying all forms of money movement under one intelligent platform. My prediction for 2025 is simple: Just as travelers today expect to get anywhere using any combination of car, plane, or train without hassle, consumers and businesses will expect that same freedom with their money. The companies that succeed won’t be the ones building slightly faster trains – they’ll be the ones creating intelligent networks that can move money as freely and safely as people move through a well-designed city. The future of payments isn’t about rails – it’s about freedom. And that freedom comes from having the intelligence to get money where it needs to go, safely and instantly, by any path necessary.

There’s an old saying in fintech that experience is what you get when you don’t get what you want. After a decade leading sales and strategy for some of the industry’s pioneering embedded finance and banking platforms, I can tell you this: The lessons that stick with you aren’t from the wins – they’re from the moments that made you completely rethink what’s possible. I love sharing those insights with clients because they often mirror the same journey I’ve been on. They’ll come to me excited about launching a new financial product or service, full of ideas about features and user experience. But then we get to the hard questions about risk management, regulatory compliance, and scalability. That’s when the real conversation begins. Here’s what I’ve learned: building innovative financial products isn’t about having the newest technology or the slickest interface. It’s about having the wisdom to know what you don’t know, and the foresight to build for where the industry is going. Not where it’s been. And where we’re going by 2025 will surprise a lot of people. By next year, the embedded finance landscape will be unrecognizable. The patchwork of vendors and APIs that power most financial services today will give way to unified platforms that own 90% of their technology stack. Companies trying to piece together a dozen different providers for basic money movement won’t survive regulatory scrutiny or scale demands. This isn’t speculation – it’s what happens when regulatory oversight meets enterprise reality. The Regulatory Tide Is Rising The Consumer Financial Protection Bureau’s recent expansion of supervision to cover major payment providers is a fundamental shift in how regulators view embedded finance. When tech giants face bank-level scrutiny, the old playbook of moving fast, breaking things, and fixing compliance later simply doesn’t work. I’ve sat across the table from bank examiners. They don’t care about your innovative UX or how quickly you can onboard customers. They care about one thing: risk management and oversight.  And when your platform depends on 8-12 different vendors to process basic transactions, demonstrating effective risk management becomes nearly impossible. Think about what happens when a bank examiner asks to trace the flow of funds across your platform. In a typical embedded banking setup, critical money movement functions are fragmented across multiple vendors – from basic account funding to payment processing to check deposits. Each vendor has their own data format, their own retention policies, and their own security protocols. It’s a nightmare scenario for both the bank and their fintech partners. The Enterprise Wake-Up Call This regulatory evolution is driving a fundamental shift in who succeeds in embedded finance, and recent events have made this crystal clear. When a major Banking-as-a-Service provider recently filed for bankruptcy, we discovered something troubling: around $85 million in customer funds across 100,000 accounts couldn’t be properly traced or accessed. The root cause wasn’t only inadequate ledgering technology – it was a broader failure of infrastructure and controls. Let me break down what enterprises need to understand about modern financial infrastructure. Your ledger is the foundation of trust for every dollar that moves through your platform. When you’re managing multiple banking relationships and serving enterprise clients, you need four critical pillars working in harmony: First, bulletproof ledgering that can track every penny in real-time. This means knowing exactly where money is, who it belongs to, and maintaining a complete audit trail of how it got there. When regulators ask questions, you need answers immediately, not after days of reconciliation. Second, comprehensive third-party risk management. Every vendor, every integration, every partner becomes part of your risk profile. In today’s environment, you’re responsible for the entire chain of custody for customer funds. One weak link can bring down the whole system. Third, bank-grade security and privacy controls. This isn’t simply ‘encrypting data’ and putting a bow on it – it’s about building systems that can prevent commingling of funds, ensure proper segregation of duties, and support immutable audit trails. When you’re handling enterprise-scale money movement, every security decision has million-dollar implications. Fourth, automated compliance that scales. Manual reviews and periodic audits won’t cut it anymore. You need systems that can automatically flag suspicious patterns, enforce regulatory requirements, and adapt as rules change. This is where compliance automation becomes critical – humans in large banking operations can’t keep up with the volume and complexity of modern financial transactions. That’s why my conversations with enterprise prospects have fundamentally changed. I’ve been recently diving deep into questions like: How do you keep separate ledgers for operating funds versus customer deposits? What controls prevent commingling of funds across different programs? Can you provide real-time reconciliation across all banking partners? How do you track and document the full lifecycle of every transaction? What happens if one of your banking partners faces regulatory challenges? These are existential questions that decide whether you can work in a regulated environment. When regulators demand a complete audit trail of all customer funds, you can’t afford to have gaps in your ledger or rely on third parties to piece together the compliance story. You need rock-solid infrastructure that can stand up to scrutiny while supporting the speed enterprises demand. The winners in this space won’t be the ones with the most features or the fastest integrations. They’ll be the ones who’ve built bank-grade infrastructure into their DNA, who can demonstrate complete control and visibility over every dollar that touches their platform. Because in today’s regulatory environment, anything less is a recipe for disaster. Building for Bank-Grade Scale In my view, the solution isn’t about adding more vendors or building more complex integrations. It’s fundamentally rethinking how we deliver embedded finance at enterprise scale. This requires leveraging platforms that: First, own the majority of the value chain. Instead of slapping together 12 different vendors, leading platforms are bringing critical capabilities in-house – from core processing to risk management to compliance monitoring. Second, automate compliance by design. When regulatory requirements are built into your platform architecture rather than bolted on afterward, you can maintain both speed and security. Third, provide bank relationship portability. Your technology shouldn’t lock you into a single bank partnership. Enterprises need the flexibility to work with multiple banks while maintaining consistent technology and compliance frameworks. Implementation in the Real World For enterprises considering embedded finance initiatives, here’s what successful implementation looks like in practice: Start with risk assessment. Map out every money movement touchpoint in your proposed solution and name potential compliance requirements before writing a single line of code. Build for examination. Design your data architecture assuming regulators will want to see everything. This means consistent formatting, comprehensive audit trails, and real-time access to critical information. Plan for scale. The compliance frameworks that work for 100 transactions won’t work for 100 million. Build automated controls that can scale with your business. The 2025 Vision By 2025, the embedded finance market will be unrecognizable from today. The successful platforms won’t only connect APIs: they’ll own most of the value chain and more, eliminate third–party risk, and deliver bank–grade compliance at fintech speed. This transformation won’t be driven by new technology or innovative features. It will be driven by enterprise demands for reliability, security, and compliance at scale. The winners will be the platforms that understand both banking and technology – that can move at fintech speed while supporting bank-grade controls. For enterprises exploring embedded finance, the message is clear: partner with platforms that have lived through the compliance evolution, not just the technology revolution. Because in embedded finance, experience isn’t just what you get when things go wrong – it’s what prevents things from going wrong in the first place. The future of finance belongs to the enterprises. And the platforms that succeed will be the ones built for enterprise scale from day one.

In today’s highly competitive financial landscape, acquiring new customers is no longer the only hurdle for account issuers. The real challenge lies in making newly opened accounts useful and accessible from the moment of acquisition.   While customer onboarding is often instantaneous, funding remains a bottleneck, with slow and risky methods like checks and ACH causing days-long delays in funds availability. As a result, a large percentage of accounts are opened but never funded, significantly driving up acquisition costs without delivering value. This disconnect between account creation and funding leaves issuers struggling to activate and engage new customers, ultimately missing opportunities to maximize the potential of newly acquired accounts.  However, a broader transformation of account funding is underway. Innovations like digital transfers from bank accounts, debit card transactions, and check deposits are shifting the process from slow and risky to instant and risk-managed, making account funding faster, safer, and more reliable for both issuers and their customers.  Instant Access: Innovations in Digital Account Funding  The modern fintech era has introduced instant account funding, enabling customers to move money into their accounts in real time, using digital payment rails to provide immediate access to deposited funds. Customers can now instantly fund their accounts via digital transfers from bank accounts, cards, or check transactions, making account creation not only fast but immediately useful.   Among the newer innovations is instant card funding using Account Funding Transactions (AFT). These transactions, initiated by the cardholder’s bank via Visa Direct or Mastercard Send, allow customers to pull funds directly from a debit or credit card into a new or existing account. Although AFT is still relatively new, its growing adoption is transforming how funds move between accounts, offering faster, more efficient transfers for both issuers and customers.  The Challenges: Fraud Risks in Digital Account Funding  While digital account funding brings significant benefits, it also comes with risks—most notably fraud. Instant transactions provide less time for issuers to review and mitigate risks, while ACH transfers impose risks due to lengthy return cycles. Types of fraud associated with digital account funding include:  Friendly Fraud: This occurs when a consumer initiates a legitimate transaction to fund their account—such as using a debit or credit card to transfer money into their fintech or bank account—but later disputes the transaction with their card issuer, claiming it was unauthorized or a mistake.  Account Takeover Fraud: Hackers gain access to a consumer’s account and initiate unauthorized transactions.  Card-not-present (CNP) Fraud: In digital card transactions where the physical card isn’t presented, fraudsters use stolen card details to fund accounts instantly.  In the U.S., consumers may have up to 90 days to dispute an unauthorized electronic funds transfer. This consumer protection, while crucial, adds significant risk for issuers. Even after funds have been made available instantly, consumers can file a dispute, forcing issuers to investigate the claim and potentially refund the money. This can lead to losses for account issuers, especially in cases of friendly fraud where the transaction was initially authorized by the consumer.  The Impact of Fraud on Account Issuers  Due to the heightened risk of fraud, many issuers have scaled back or discontinued their offerings of instant funding. The potential for significant losses, coupled with regulatory obligations to address disputes, has made it a risky endeavor. As a result, despite strong consumer demand for fast and accessible funds, some issuers have been cautious in adopting or expanding their instant funding solutions.  Ingo & Sardine’s Risk-Managed Solutions for Instant Card & ACH Funding  To address the challenges posed by account funding fraud, Ingo has partnered with Sardine to offer instant account funding via card and ACH, jointly providing the technology, processing, and protection necessary to drive account usage. This unique offering leverages our collective expertise and databases to manage risk across our network of clients and customers.  Our solution combines the power of Ingo’s and Sardine’s extensive network-wide fraud data and AI-driven analysis to generate real-time risk scores. These scores empower issuers to make fast, informed decisions on funding eligibility, while minimizing exposure to fraudulent transactions. Together, our advanced risk models continuously evaluate transactions for fraud indicators, providing issuers with immediate insights into the risk profile of each transaction.  Additionally, Ingo’s dedicated support team monitors all transactions in real time, adding another layer of protection against instant fraud. This live risk management allows us to catch fraudulent activities as they happen, further safeguarding businesses from potential threats.  By identifying fraud risks, protecting against them, and locking out bad actors, Ingo and Sardine ensure a safer, more efficient account funding process that benefits both issuers and customers.  Zero-Liability Fraud Guarantee  Beyond fraud detection and risk scoring, our offering includes an optional zero-liability fraud guarantee. Account issuers who choose this guarantee option are fully protected from any financial losses caused by fraudulent chargebacks or disputes. This means that if a fraudulent transaction bypasses our detection systems, we take full responsibility for the chargeback, relieving issuers of any liability. This level of protection is rare in the market and offers peace of mind for issuers looking to offer account funding without the risk.  With Ingo Payments and Sardine, account issuers can offer faster, safer, and more secure account funding options. For Fintechs, our solutions mitigate risk while enabling exceptional customer experiences. For traditional banks, they provide seamless onboarding and instant funding, keeping them relevant in the digital landscape. These innovations enhance services and protect issuers’ bottom line in a competitive market. Learn More   Looking for account funding solutions with comprehensive risk management and guaranteed fraud protection across all funding sources—card transfers, bank transfers, and checks? Ingo Payments can help.