ETA SRP Attestation: Payment Facilitator – ETA | Electronic Transactions Association

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)

SUB-MERCHANT UNDERWRITING

Do you have a signed application / agreement for the sub-merchant?(required)

Yes

No

Sometimes

N/A

Do you have specific criteria to determine the need for additional review or enhanced due diligence?(required)

Yes

No

Sometimes

N/A

Do you evaluate customer complaints for an applicant sub-merchant?(required)

Yes

No

Sometimes

N/A

Do you validate the sub-merchant’s identity and location(s), including web sites?(required)

Yes

No

Sometimes

N/A

Do you perform MATCH and OFAC checks as standard procedure?(required)

Yes

No

Sometimes

N/A

Do you validate the type of business the sub-merchant conducts (confirm the products and services they are selling)?(required)

Yes

No

Sometimes

N/A

Do you evaluate the sub-merchant’s financial condition to ensure it is acceptable, according to your risk policies?(required)

Yes

No

Sometimes

N/A

Do you assess the extent of risk that a sub-merchant may pose (fraud, credit, financial, compliance, regulatory and / or reputational)?(required)

Yes

No

Sometimes

N/A

Do you ensure the sub-merchant is in the same jurisdiction as the acquirer?(required)

Yes

No

Sometimes

N/A

Do you validate that the sub-merchant is a bona fide business (confirm sub-merchant’s credit and / or bank card processing history, marketing, advertising and sales and distribution practices)?(required)

Yes

No

Sometimes

N/A

Do you conduct due diligence to identify and verify beneficial owners of your customer entities?(required)

Yes

No

Sometimes

N/A

Do you have procedures designed to identify corporate relatedness (situations where sub-merchants may have reason to camouflage beneficial owners or otherwise avoid regulatory scrutiny)?(required)

Yes

No

Sometimes

N/A

Do you determine if the sub-merchant’s background or business methods would preclude the sub-merchant from being a customer?(required)

Yes

No

Sometimes

N/A

Do you have a list of MCCs and descriptions of merchant industries for whom you will (or will not) provide service (consistent with card scheme, sponsor bank, processor and ETA prohibitions)?(required)

Yes

No

Sometimes

N/A

Do you have a list of MCCs and descriptions of merchant industries for whom you will (or will not) provide restricted service (consistent with card scheme, sponsor bank, processor and ETA prohibitions)?(required)

Yes

No

Sometimes

N/A

Does your underwriting policy include a section that delineates approval authorities and parameters clearly?(required)

Yes

No

Sometimes

N/A

Do you document escalations of sub-merchant approval requests and report exceptions regularly?(required)

Yes

No

Sometimes

N/A

Do you prohibit sub-merchants who are sub-merchants of another payment facilitator?(required)

Yes

No

Sometimes

N/A

Do you prohibit aggregators acting as payment facilitators?(required)

Yes

No

Sometimes

N/A

Do you prohibit aggregators acting as marketplaces?(required)

Yes

No

Sometimes

N/A

Do you prohibit sub-merchants engaged in illegal businesses, internet pharmacies or referral sites, outbound telemarketers, sub-merchants selling illegal drugs or supplements, sub-merchants that violate unfair, deceptive or abusive acts or practices, or sub-merchants who have been terminated?(required)

Yes

No

Sometimes

N/A

Do you review sub-merchants on the restricted list with greater scrutiny?(required)

Yes

No

Sometimes

N/A

Do you avoid using frictionless underwriting to board restricted sub-merchants?(required)

Yes

No

Sometimes

N/A

Do you establish sub-merchant risk levels on the basis of transaction volume, card acceptance method and / or risk exposure?(required)

Yes

No

Sometimes

N/A

Do you require increasing information for sub-merchants as they enter higher risk levels (micro / mobile / small; medium; large / graduating)?(required)

Yes

No

Sometimes

N/A

Do you require that the sub-merchant enter into a direct merchant relationship with the acquirer and receive direct funding / settlement from the bank when the sub-merchant exceeds $1,000,000 in card scheme volume in a calendar year?(required)

Yes

No

Sometimes

N/A

Do you perform additional reviews on sub-merchants who were approved under frictionless onboarding after their first transaction is processed?(required)

Yes

No

Sometimes

N/A

Do you have a regular review / monitoring process for sub-merchants classified as restricted?(required)

Yes

No

Sometimes

N/A

Do you review restricted sub-merchants with the criteria one level greater than the sub-merchant’s requested processing level?(required)

Yes

No

Sometimes

N/A

Do you have a policy that ensure merchant reserves, when taken, are being used based on the sub-merchant’s financial condition to mitigate risk rather than for other purposes?(required)

Yes

No

Sometimes

N/A

Do you include financial information, validation of approved sales method / product, reputation reviews, current processing and transaction volumes as part of the periodic (annual) review process? (required)

Yes

No

Sometimes

N/A

Do you conduct periodic (six-month) reviews of sales trends, chargeback rates, and refund activity?(required)

Yes

No

Sometimes

N/A

Do you conduct reviews when sub-merchants make changes to their account information or organization?(required)

Yes

No

Sometimes

N/A

Do you require monthly reporting to management on portfolio statistics, top processing, chargeback and refund volumes, merchant exception monitoring, card scheme excessive chargeback volumes, merchant losses, significant merchant terminations, secret shopping activity, and restricted merchant exception activity?(required)

Yes

No

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.

QUESTIONS / COMMENTS

Please provide any questions or comments here.

Industry Affairs

Payment Facilitators

QUESTIONS?

REQUIRED DUE DILIGENCE MATERIALS