Match

Chances are, if you are reading this, you have already been placed on MATCH. If you have already been placed on MATCH, what do you do now? Unfortunately, being placed on MATCH is very often a death sentence for a merchant. Reeve Basnett PLLC assists merchants in educating them about the MATCH list and in some circumstances, assists merchants in their efforts to be removed from the MATCH list.

What is the MATCH list?

The MATCH list, formerly known as the Terminated Merchant File (TMF), was created by MasterCard to assist acquiring banks in identifying enhanced or incremental risk information of merchants prior to entering into an agreement with a merchant. MATCH stands for Mastercard Alert to Control High-risk. MATCH is a mandatory system for Mastercard acquiring banks. Acquiring banks are required to add information about a merchant that is terminated by the acquiring bank due to specific circumstances set forth by Mastercard. Further, Mastercard acquiring banks are required to search for a merchant in the MATCH system prior to entering into a merchant agreement with the merchant to determine if that merchant has been placed on the MATCH list.

While it appears that the original intent of the MATCH list was to simply provide acquiring banks with information about merchants to help determine if the acquirer should enter into an agreement with a merchant, it ultimately has become a black list system. If a merchant is on the MATCH list, most acquirers will not enter into a merchant agreement with the merchant regardless of the reason. If an acquirer does enter into a merchant agreement with a merchant on the MATCH list, the terms of the merchant agreement are adjusted to account for the perceived greater risk of that merchant.

What information is on the MATCH listing?

Relatively very little information is actually placed on the MATCH listing. The MATCH list contains specifics concerning the merchant (including but not limited to the merchant name, merchant ID, business address) and the principal (including but not limited to the name, address and phone number); however, the only information concerning why a merchant is placed on MATCH is the MATCH Reason Code.

What are the reason codes for a MATCH listing?

Mastercard has set forth 14 reason codes for placing a merchant on MATCH. The reason codes are as follows:

When is a merchant placed on MATCH?

The Mastercard Rules manual provides that an acquirer must place a merchant on MATCH if i) either the acquirer or the merchant takes action to terminate the acquiring relationship and at the time of such act; and ii) the acquirer has reason to believe that a condition described in the reason codes listed above exists. The acquirer must then add the required information into the MATCH system within 5 calendar days of the earlier of: i) a decision by the acquirer to terminate the acquiring relationship, regardless of the effective date of termination; or ii) receipt by the acquirer of notice by or on behalf of the merchant of a decision to terminate the acquiring relationship, regardless of the effective date of the termination.

How long does a MATCH listing last?

A MATCH listing expires after five (5) years. If a MATCH listing is as a result of Reason Code 12 (PCI Data Security Standard Noncompliance) the merchant can be removed from MATCH before the fie (5) year period upon becoming PCI compliant.

How can a merchant be removed from MATCH?

With the exception of a merchant listing for reason code 12 (Payment Card Industry Data Security Standard Noncompliance), the only way that a merchant can be removed from MATCH is if the acquirer reports to Mastercard that the acquirer added the merchant to MATCH in error.

What should I do if I am placed on MATCH?

Most merchants try to contact the acquirer that places them on MATCH to dispute such placement. This often time yields little to no response. Merchants placed on MATCH should contact an industry professional, preferably an attorney in the industry. An industry attorney likely has contacts that can result in negotiations about placement on MATCH. An industry attorney may be able to make compelling arguments to the acquirer as to the error. Further, in the event that you cannot be removed from MATCH, an industry attorney can assist you in negotiating a fair relationship with a new acquirer.

Is the MATCH system fair?

No! The MATCH system is one sided. The acquirer can place a merchant on MATCH with no prior notice to the merchant. There are no true checks and balances to determine whether an acquirer is rightfully placing a merchant on MATCH. While a merchant can appeal placement directly with MasterCard, the appeal process is also done behind closed doors between MasterCard and the acquirer. The MATCH system also faults merchants who are themselves victims. Specifically, MATCH Reason Code 14 is for a merchant that is the victim of identity theft. Despite the fact that the merchant is the victim, the merchant will be “blacklisted” in the same way that a merchant that has excessive chargebacks or a merchant that violated industry standards.