Dear Brandon Eley,
The purpose of this e-mail is to advise you of new mandated changes required by the Visa & MasterCard Card Associations. Some of these changes are a fairly substantial departure from previous policy statements and will thus require some immediate changes on any marketing Web site(s) that you operate to promote CDGcommerce.
Specifically, the following items must be addressed immediately:
1. Effective immediately, if you do have a marketing Web page that has information on our services including – but not limited – to pricing and other details, this information will need to be moved and re-linked to a direct page on the CDGcommerce.com domain to ensure full compliance. Information pages about merchant accounts hosted on your own Web site and not a CDGcommerce Web page will no longer be allowed based upon the new Card Association mandates.
The simplest way to accomplish this is to follow the easy set of steps in #2 below. The bottom line is that ALL tabs or links on your Web site that a prospect might click to learn about obtaining a merchant account should be linked directly to your affiliate-encoded CDG Web site link.
The reason why this is now required is that the Member Risk & Compliance program manager at Visa has given us a direct mandate that they feel that unless a Web page is hosted on the actual ISO/MSP’s Web site, there is the potential for customer confusion over who they are obtaining the merchant account through. They are now in the process of sending new documentation to Member Banks about this and are beginning enforcement immediately.
While we realize that this policy is not ideal from a marketing perspective, ultimately Visa make the rules and the penalties for non-compliance on this can be substancial ranging upwards of $10,000-100,000 per infraction. Based upon our conversations with Visa, they are definitely serious about this and will be enforcing this in the weeks and months ahead with numerous ISO/MSP’s in the industry, a vast number of whom are not currently compliant. The end result will likely be millions of dollars in compliance fines assessed to dozens or even hundreds of other merchant processors nationwide and our goal is to ensure that neither CDGcommerce nor any of our valued affiliates are subjected to these penalties.
2. To ensure, please make use of our new Web site – which fully tracks and logs all affiliate referrals – by re-linking your existing pages and links regarding obtaining a merchant account with CDGcommerce to one of these pages: (this should be done as a link to open a new window OR link into the existing window – internally linking via frames is not permissible)
For your convenience, we have already inserted your agent ID# in the above links so that you can literally COPY & PASTE them into your Web pages “as is.” (You can also pick another .php page on our Web site and simply add ?R=xxxx to it and that will also create a successful referral link.)
3. Please also remove any footers that disclose “(your name) is an independent agent for CDGcommerce who is a registered ISO/MSP…” as these are no longer necessary due to the manner in which we are shifting the marketing link and this will allow us to handle any compliance disclosures needed on the centralized CDG landing pages.
4. Once you've completed steps 1 - 3, we ask that you login to your Partner Portal account to acknowledge that you have complied with these new regulations. (To ensure maximum compliance with this initiative, release of subsequent residuals will require that you have completed steps #1-4. It only takes a few minutes to do but we can not stress how important this is)
We do realize and appreciate that many of you have built very nice information pages describing CDGcommerce and you followed the rules that you were given previously on compliance. While we feel it is unfortunate that Visa has opted to change their guidelines to us and other ISO/MSP’s, compliance is a necessity of life in this business.
If there are mitigating or unusual circumstances with respect to your Web pages and/or a large amount of traffic is currently visiting your CDGcommerce merchant account page, it may be possible under some situations for our staff to “clone” most or all of your current marketing pages and transfer them to a location one of our CDGcommerce.com servers for you to link to but under all circumstances, the link must go directly to a page on our servers for any material/information about merchant accounts.
Our staff will be available to assist you with any questions or needs that you might have on the above and we look forward to wrapping up this compliance initiative in the next week so that we can all return our focus to building new business together into the New Year!
Chris West, CEO