ETA SRP Attestation: Acquirers / ISOs Who Underwrite ISOs – ETA

GETTING STARTED

NOTE: This is a lengthy form. We recommend that you allow a minimum of 10 minutes to complete the entire form.

CONTACT INFORMATION

First Name(required)

Last Name(required)

Company(required)

E-Mail Address(required)

GENERAL ISO UNDERWRITING

Do you have a written policy for underwriting, reviewing and monitoring of ISOs and overseeing sales agents?(required)

Yes

Sometimes

N/A

Do you have a signed application / agreement for the ISO?(required)

Yes

Sometimes

N/A

Do you validate the ISO principals’ identities?(required)

Yes

Sometimes

N/A

Do you evaluate the ISO’s financial condition to confirm it is sound and can support the liability or credit risk to you? (required)

Yes

Sometimes

N/A

Do you determine that the ISO’s business model and practices are aligned with your expectations and permissible risk levels?(required)

Yes

Sometimes

N/A

Do you determine that the ISO and its principals have satisfactory credit?(required)

Yes

Sometimes

N/A

Do you determine that the principals do not have a criminal history that would preclude your doing business with them?(required)

Yes

Sometimes

N/A

Do you determine the functions that the ISO will perform?(required)

Yes

Sometimes

N/A

Do you confirm the breadth of knowledge of the ISO’s key management staff?(required)

Yes

Sometimes

N/A

Do you review business continuity and disaster recovery plans, if appropriate?(required)

Yes

Sometimes

N/A

Do you understand the ISO business model and ancillary products and services?(required)

Yes

Sometimes

N/A

Do you determine whether the ISO is performing any ACH movement outside of the processor?(required)

Yes

Sometimes

N/A

Do you assess operational, compliance, credit, legal, strategic, reputation, and concentration risks of working with the ISO?(required)

Yes

Sometimes

N/A

Do you perform background checks of principals looking for prior business involvement, history of consumer complaints, lawsuits filed by or against ISO or principals, and layers of corporation or unnamed owners?(required)

Yes

Sometimes

N/A

Do you perform background checks of individuals, including OFAC, and criminal background, especially financial crimes which might cause rejection?(required)

Yes

Sometimes

N/A

Do you review ISO and principal reputations, including experiences with other sponsoring entities, reference checks with industry associations, history of consumer complaints and lawsuits filed by or against them?(required)

Yes

Sometimes

N/A

Do you perform reverse searches to ensure this is not an attempt to re-brand an existing company with a damaged reputation?(required)

Yes

Sometimes

N/A

Do you investigate any prior businesses owned or operated by ISO principals, specifically history of consumer and / or merchant complaints, reference checks, and lawsuits filed by or against them?(required)

Yes

Sometimes

N/A

Do you review the last three years of financial statements, tax returns, credit and insurance coverage for ISOs and principals?(required)

Yes

Sometimes

N/A

Do you request terms of any existing contracts that the ISO may have with other sponsors, especially for non-competes and merchant relationship ownership?(required)

Yes

Sometimes

N/A

Do you review an existing merchant portfolio for profitability / bad debt, activity statistics, demographics (restricted merchants, MCCs, concentrations in business type, marketing methods and processing methods, and verticals)?(required)

Yes

Sometimes

N/A

Do you review portfolio loss history for the past three years and bad debt practices?(required)

Yes

Sometimes

N/A

Do you perform a portfolio review at the merchant level when the portfolio is moving acquirers or processors?(required)

Yes

Sometimes

N/A

Do you review the ISO’s business plan, marketing effectiveness, products and services, Value Added Resellers, and use of partners or third party agents?(required)

Yes

Sometimes

N/A

Do you review marketing and solicitation materials for compliance with card scheme rules, pricing, and ease of use?(required)

Yes

Sometimes

N/A

Do you review the ISO’s policies and procedures?(required)

Yes

Sometimes

N/A

Do you perform an onsite inspection of current and prospective ISOs?(required)

Yes

Sometimes

N/A

Do you have formal training programs for new ISOs on such topics as credit, risk, and sales policies and procedures as well as system access and controls?(required)

Yes

Sometimes

N/A

Do you perform periodic reviews, at least annually, with more frequent reviews for those portfolios with anomalous conditions and higher risk ISOs?(required)

Yes

Sometimes

N/A

Do you monitor ISOs for daily functions and overall metrics, and monitor sub-ISOs and agents as well, using tools such as shadow underwriting, shadow transaction review, shadow review of terminated merchants, and shadow review of account maintenance?(required)

Yes

Sometimes

N/A

Do you perform shadow reviews of merchant reputation?(required)

Yes

Sometimes

N/A

Does your regular portfolio reporting include underwriting statistics, MCC statistics, merchant annual reviews completed, card scheme registrations or renewals completed, PCI compliance statistics, attrition and assessment of early termination fees?(required)

Yes

Sometimes

N/A

Do you receive regular volume reports on top processing, chargeback and refund statistics?(required)

Yes

Sometimes

N/A

Do you receive regular merchant exception reports on significant events, merchants exceeding approved dollar amount, and decreased activity?(required)

Yes

Sometimes

N/A

Do you have standards for expected refund processing for each ISO and review and report on exceptions to those standards?(required)

Yes

Sometimes

N/A

Do you have standards for expected chargeback activity for each ISO and review and report on exceptions to those standards?(required)

Yes

Sometimes

N/A

Do you have oversight procedures to ensure ISOs are rehabilitating merchants identified under card scheme monitoring programs?(required)

Yes

Sometimes

N/A

Do you require monthly reporting from ISOs on merchant losses and their causes?(required)

Yes

Sometimes

N/A

Do you require regular reporting of significant merchant terminations, circumstances and resulting actions?(required)

Yes

Sometimes

N/A

Do you require regular reporting on merchant reserves collected and released?(required)

Yes

Sometimes

N/A

Do you require regular reporting on secret shopping activity and results?(required)

Yes

Sometimes

N/A

Do you require regular reporting on exceptions generated by restricted merchant types and the resulting review findings?(required)

Yes

Sometimes

N/A

Do you have written procedures for remediation of ISOs who are not adhering to your requirements?(required)

Yes

Sometimes

N/A

Do you utilize tools for remediation like onsite audits, portfolio analysis, reduction in underwriting authorities, increased oversight and / or shadow monitoring of the underwriting process, increased risk mitigation requirements for applicable merchants, and increased detail in monthly reporting?(required)

Yes

Sometimes

N/A

Do you have a schedule of time frames for remediation activities, typically in 3-month intervals, and consider action up to non-renewal or termination if the remediation is taking longer than 6 months?(required)

Yes

Sometimes

N/A

Do you have a written plan for terminating an ISO relationship, including reporting to the card schemes?(required)

Yes

Sometimes

N/A

AGREEMENT

I ("President, Chief Executive Officer, etc.")(required)

of (“Submitting Organization”) (required)

Company Officer First Name(required)

Company Officer Last Name

possess the authority to bind the Submitting Organization and attest to the veracity of the information / documentation submitted as part of the application process in seeking to participate in the ETA’s Self-Regulation Program (hereinafter, “ETA Program”).

Because the Submitting Organization has a greater knowledge about its business and the kinds of information sought by the Electronic Transactions Association (“ETA”) under the ETA Program, and because ETA needs to know this information to determine the Submitting Organization’s eligibility under the ETA Program, ETA depends upon the truthfulness, completeness, and accuracy of the information / documentation submitted. Utmost good faith and complete and total honesty are required with all material facts to be revealed.

With this authority and understanding, I warrant that the information/documents disclosed and/or submitted by the Submitting Organization are fully responsive to the ETA Program requests and are truthful, accurate, and complete to the best of my knowledge.

I acknowledge that any inaccuracies included, or material omissions, as part of the Submitting Organization’s application under the ETA Program would constitute a breach of this attestation and the warranties contained herein. A breach may result in ETA, in its sole discretion, taking any and all actions deemed appropriate and corrective including, but not limited to, terminating/invalidating any certification of the Submitting Organization under the ETA Program.

I also represent that any material change in the information/documentation of the Submitting Organization which occurs after this application is made to ETA shall be immediately disclosed to the ETA. Failure to do so also constitutes a breach of this attestation.

Finally, notwithstanding the specific information sought by the ETA pursuant to the ETA Program, I warrant that the Submitting Organization is not in material violation of any laws, rules, or regulations which apply to the conduct of its business.

The undersigned, on behalf of the Submitting Organization, hereby RELEASE, WAIVE, DISCHARGE AND COVENANT NOT TO SUE the ETA and its officers, directors, from and for any liability resulting from any action, inaction, decisions, procedural challenges however caused, arising from, or in any way related to, the ETA Program and Submitting Organization’s application, involvement and participation.

Your Agreement(required)

Yes, I Agree

QUESTIONS / COMMENTS

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Industry Affairs

Acquirers/ISOs That Underwrite ISOs

QUESTIONS?

REQUIRED DUE DILIGENCE MATERIALS