Payment Company Compliance Issues: What is a match, and how can I get off of it?

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I am often asked, “What is MATCH and how can I get off it?”

As to the first part of the question, “MATCH” (which stands for Member Alert To Control High Risk) is a database of previously terminated merchants (and their principals) maintained by MasterCard Worldwide, and relied upon by all of the payment brands to screen and regulate merchant access to the payments system.

MasterCard Security Rules and Procedures affirmatively require acquirers to report a merchant for listing on MATCH within 5 calendar days of any decision (by the acquirer or the merchant) to terminate the merchant processing relationship if the acquirer has reason to believe that the merchant has suffered a data breach or failed to comply with PCI DSS; engaged in credit card laundering, fraudulent activity or other illegal transactions; violated MasterCard standards or engaged in conduct that threatens the MasterCard brand and reputation; or exceeded monthly chargeback thresholds (by far the most common reason).

Visa requires US acquirers to add a terminated merchant to the MATCH list (also referred to as the Terminated Merchant File in the Visa Rules) no later than close of business on the day following the date the merchant is notified of the intent to terminate the agreement. Reporting is mandatory if the merchant is terminated for credit or debit card fraud, depositing excessive counterfeit or unauthorized transactions, laundering transactions, or generating excessive chargebacks.

To put it simply, any merchant that gets caught engaging in high risk or illegal activity will quickly land on MATCH.

What is the effect of MATCH and why is it so important?

Under both MasterCard and Visa Rules, acquirers must also check the MATCH list before signing any processing agreement with a merchant. Of course, most acquirers regard a MATCH listing as a “scarlet letter” and will flatly reject any merchant that appears on the MATCH list. In the small remainder of cases where more risk-tolerant acquirers may still be willing to extend processing services to MATCH-listed merchants, such merchants should expect to pay much higher discount rates (up to 5% or more), be subject to greater scrutiny and increased monitoring, and post substantial reserves (meaning delayed access to funds).

How do you get off of MATCH?

Typically, MasterCard will remove a merchant from the MATCH list only where the acquirer reports to MasterCard that it added the merchant in error. Yet acquirers face liability to subsequent acquirers for losses caused by any merchant they should have placed on and improperly removed from, the MATCH list. Accordingly, convincing an acquirer to effectuate a merchant’s removal from MATCH is very challenging indeed.

For starters, you will need to establish that you should not have been placed on MATCH in the first place. If that is the case, ask the acquirer for an investigation to demonstrate that you were placed on the list in error. MasterCard, itself, can also remove a person or business merchant. If that doesn’t work, you can always sue them, but it rarely makes sense to do so based on the cost. The good news is, if you can wait five years, you will automatically roll off the list.

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