Q: Is an EFT from a consumer’s account initiated by a fraudster through a non-bank P2P payment provider considered an unauthorized EFT?
A: Yes. Because the EFT was initiated by a person other than the consumer without actual authority to initiate the transfer – i.e., the fraudster – and the consumer received no benefit from the transfer, the EFT is an unauthorized EFT. 12 CFR 1005.2(m). This is true even if the consumer does not have a relationship with, or does not recognize, the non-bank P2P payment provider.