Typically, acquiring banks and processors have processes in place to ensure that rule changes are identified and the appropriate changes made, they note in an unpublished article. Confusion over whether the new rules were indeed rules or just ‘best practices’ has caught many in the industry off-guard. As a result, many processors may already be unknowingly in breach of the new rules.
One rule is that payment processors must now create a fee disclosure schedule to include with merchant applications and agreements. That includes fees such as the merchant discount rate, pass-through rates, interchange plus mark-up rates, bundled pricing plans, and fees for tiered, qualified, mid-qualified, and non-qualified rates, along with authorization and settlement fees.
While many processors might believe their current applications are in compliance with this rule, they likely are not, the attorneys note. The problem is that the fee disclosure must clearly and conspicuously detail the methodology …
