Father of Home Banking Behind the Model Legislation

Doug Braun — Technical Architect of the Online Banking Revolution

When drafting Wisconsin’s AB 385, Freedom & Family Action President John Pudner worked closely with longtime colleague Doug Braun, one of the original pioneers of online banking systems in the 1990s.

Who is Doug Braun?

CTO at InteliData, the company that built some of the first internet-banking back-end systems used by BB&T, Compass, BancWest, National City, and others.
Later, the CEO of iPayX, an early online payments company, later acquired by BillingTree.
A national expert on CVV verification, AVS systems, processor behavior, and payment-rail security.

Braun guided the legislative language to ensure it works the way real payment rails actually function, including why verification must be handled by processors—not campaigns.

Key Lessons for Drafting Your State’s Bill

Below are the exact technical clarifications that helped Wisconsin pass the nation’s first model legislation. These are the same fixes your state should adopt.

1. CVV Verification Must Be Required — but Not Collected by Campaigns

Early drafts in Wisconsin accidentally implied campaigns would receive and store CVV numbers.

This was not the intent and was fixed in the substitute bill that passed.

Fix:
Place the responsibility on the processor, not the campaign.
Recommended language:

“The committee, conduit, or political party shall ensure, when establishing any online donation process, that the financial institutions, their agents, or third-party payment processors require and verify the credit-card security code (CVV) at the time the contribution is made. The committee may not accept a contribution processed without such verification.”

Outcome:

Campaigns never store CVVs
Verification happens only at the processor level
The transaction is secure and compliant

2. Penalties Must Apply to Processors, Not Banks

Original Wisconsin phrasing referred only to “financial institutions,” which under statute meant only banks—not the processors who actually control verification settings.

Fix:
Replace “financial institution” with:

“financial institutions, their agents, or third-party payment processors.”

3. Why the Penalty Belongs on Processors — Not Campaigns

Historically, some processors disabled CVV verification at the request of high-volume political clients, the biggest being ActBlue, in order to get the business and push through more transactions.

Processors actually prefer verified transactions—the fees are lower and fraud is reduced—but would waive verification to keep political clients from defecting.

The bill solves this by allowing processors to say:

“We must run verification—state law requires it.”

This closes the old loophole permanently.

4. ETHICS Requested Two Clarifications — Both Easy

Wisconsin’s Ethics Commission asked for two clean fixes (your state should use the same):

Amendment A: Require the processor—not the committee—to verify CVV.
Amendment B: Expand “financial institution” to include processors and agents.

Both were adopted with no controversy.

5. Foundational Research — The 2015 White Paper

This model began with our white paper delivered to every Congressional House and Senate office in 2015, later forming the basis of the federal “Stop Foreign Donations Affecting Our Elections Act.”

Link:
https://docs.google.com/document/d/15nNflwuFtR6KXtmrgZljPcxl7Qjv5wl3gLBZOfZdX90/edit?tab=t.0

One line remains true today:

“Campaigns should want to use these anti-fraud protections… yet nearly half of House and Senate campaigns did not require CVV (in 2015).”

Your state can now close that loophole with a proven model.