These numbers are “likely to grow as smartphone ownership increases and mobile payments platforms become more widespread,” wrote the FDIC team.

One FDIC prediction: “It is unlikely that any one technology will become dominant” and so the FDIC envisions continued battles amongst Near Field Communications (NFC), cloud-based payments schemes, and image-based schemes (barcode readers).

A key point, per the FDIC: the main mobile payments formats leverage off requirements that users provide bank account information or a prepaid card and thus “the risks associated with mobile payments should be familiar to financial institutions,” wrote the FDIC executives.

A particular challenge with regard to mobile payments, noted the FDIC, is that most schemes involve non-banks (technology companies or wireless carriers, for instance) and, importantly, most transactions also involve multiple players. Noted the FDIC: “Unlike most banking products that allow institutions to control much of the interaction, mobile payments require the coordinated and secure exchange of payment information among several unrelated entities.” A further complication, said the FDIC, is that many of the key players are “entrepreneurial companies” with little familiarity with security expectations for financial institutions.

Warned the FDIC: “Financial institutions should be particularly conscious of the potential and perceived risk of fraud in mobile payments.”

The FDIC observed that there are no federal laws or regulations that govern mobile payments. However, noted the FDIC, most payments piggyback on traditional formats (such as ACH or EFT) and “the laws and regulations that apply to that method also apply to the mobile payment.”