Tuesday, June 12, 2012

Acquirer Noncompliance with Common Point of Purchase (CPP) Investigations

MasterCard may assess an acquiring banks for failure to comply with CPP responsibilities. Each failure may be considered a separate violation for assessment purposes. Multiple violations can result from a single CPP investigation request. For example, if an acquiring bank fails to acknowledge receipt of an investigation request and also fails to initiate an investigation, then MasterCard may fine the acquiring bank for two noncompliance violations.

MasterCard also may request additional information from the acquiring bank after the completed investigation date. A due date will be established at the time of the request, based on the content of the requested information. If the acquiring bank fails to acknowledge or respond to the information request, MasterCard may assess a noncompliance fee. Each CPP will be reviewed on an individual basis.

With each incident of noncompliance, a certified or registered letter, fax, or email with confirmation will be sent to the acquiring bank's Security Contact, Principal Contact, and Merchant Acquirer Contact.

In cases of acquirer noncompliance, the following assessments apply:
  • First violation - no assessment.
  • Second violation. MasterCard may subject the acquiring bank to a Level 3 RAMP review ($10,000), and may impose an assessment of up to $15,000.
  • Third violation. MasterCard may assess the acquiring bank up to $20,000, and may refer the incident to the Audit Committee of the MasterCard Global Board of Directors for review and recommendation.
  • Fourth and all further violations. MasterCard may assess the acquiring bank up to $25,000, and refer the incident to the Audit Committee of the MasterCard Global Board of Directors for review and recommendation.

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