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:
|MATCH Reason Code||Description|
|01||Account Data Compromise – An occurrence that results directly or indirectly, in the unauthorized access to or disclosure of Account data.|
|02||Common Point of Purchase (CPP) – Account data is stolen at the merchant and then used for fraudulent purchases at other merchant locations|
|03||Laundering – The merchant was engaged in laundering activity. Laundering means that the merchant presented to its acquirer transaction records that were not valid transactions for sales of goods or services between that merchant and a bona fide cardholder|
|04||Excessive Chargebacks – With respect to a merchant reported by a Mastercard acquirer, the number of Mastercard chargebacks in any single month exceeded 1% of the number of Mastercard sales transactions in that month, and those chargebacks totaled USD $5,000 or more. With respect to a merchant reported by an American Express acquirer (ICA numbers 102 through 125), the merchant exceeded the chargeback thresholds of American Express, as determined by American Express.|
|05||Excessive Fraud – The merchant effected fraudulent transactions of any type (counterfeit or otherwise) meeting or exceeding the following minimum reporting standard: the merchant’s fraud-to-sales dollar volume ratio was 8% or greater in a calendar month, and the Merchant effected 10 or more fraudulent transactions totaling USD $5,000 or more in that calendar month.|
|06||Reserved for Future Use|
|07||Fraud Conviction – There was a criminal fraud conviction of a principal owner or partner of the merchant.|
|08||Mastercard Questionable Merchant Audit Program – The Merchant was determined to be a Questionable Merchant as per the criteria set forth in the Mastercard Questionable Merchant Audit Program|
|09||Bankruptcy/Liquidation/Insolvency – The merchant was unable or is likely to become unable to discharge its financial obligations.|
|10||Violation of Standards – With respect to a merchant reported by a Mastercard acquirer, the merchant was in violation of one or more standards that describe procedures to be employed by the merchant in transactions in which cards are used, including, by way of example and not limitation, the Standards for honoring all cards, displaying the marks, charges to cardholders, minimum/maximum transaction amount restrictions, and prohibited transactions set forth in Chapter 5 of the Mastercard Rules manual. With respect to a merchant reported by an American Express acquirer (ICA numbers 102 through 125), the merchant was in violation of one or more American Express bylaws, rules, operating regulations, and policies that set forth procedures to be employed by the merchant in transactions in which American Express cards are used.|
|11||Merchant Collusion – The merchant participated in fraudulent collusive activity.|
|12||PCI Data Security Standard Noncompliance – The merchant failed to comply with Payment Card Industry (PCI) Data Security Standard requirements.|
|13||Illegal Transactions – The merchant was engaged in illegal transactions.|
|14||Identity Theft – The acquirer has reason to believe that the identity of the listed merchant or its principal owner(s) was unlawfully assumed for the purpose of unlawfully entering into a merchant agreement.|
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.