“Beware the MATCH List” is a common warning. Merchant services providers are known to oft admonish merchants against finding themselves placed on the MATCH list lest they find their MIDs and businesses in grave danger. But questions may persist about what, exactly, the MATCH List is, what makes it so fearsome, and how it can be avoided.
The MATCH List stands for Member Alert To Control High-risk merchants. It is a form of merchant processing blacklist. It lists merchants who have had merchant accounts terminated by their acquiring banks.
Mastercard maintains the MATCH List. But it is the industry standard list and is consulted by all payments processors and other stakeholders in the merchant industry.
Terminated Merchant File (TMF) is a general term for a merchant blacklist such as the MATCH List. The MATCH List is, effectively, the only TMF currently in use. TMF used to be the more common term but, practically speaking, TMF and MATCH List can be used interchangeably.
Most often, acquirers place merchants on the MATCH List by terminating their merchant accounts. Mastercard does make some effort to ensure that merchants who are put on the MATCH List are there for legitimate reasons. Mastercard also sometimes directly puts merchants on the MATCH List.
The most common reason that a merchant is placed on the MATCH List is because they have exceeded the chargeback limits set by their acquirers and the card brands. Usually this means the merchant’s chargeback ratio has exceeded 1% or it is receiving more than 100 chargebacks per month.
There are other reasons that an acquirer may place a merchant on the list. Jimmy Carter’s charitable, house-building organization Habitat for Humanity was once placed on the MATCH List because criminals had gotten access to its MID and used it to process credit card transactions.
Mastercard’s Security Rules and Procedures lists thirteen reasons why an acquirer should report a terminated merchant to the MATCH system:
An occurrence that results, directly or indirectly, in the unauthorized access to or disclosure of Account data.
Account data is stolen at the Merchant and then used for fraudulent purchases at other Merchant locations.
The Merchant was engaged in laundering activity. Laundering means that a 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.
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.
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.
There was a criminal fraud conviction of a principal owner or partner of the Merchant.
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 (refer to section 8.4 of this manual).
The Merchant was unable or is likely to become unable to discharge its financial obligations.
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.
The Merchant participated in fraudulent collusive activity.
The Merchant failed to comply with Payment Card Industry (PCI) Data Security Standard requirements.
The Merchant was engaged in illegal Transactions.
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.
The consequences are severe for merchants who are put on the MATCH List. Financial institutions that work in the merchant business use the MATCH List as a reference about the risk levels of merchants. A merchant on the MATCH List will find difficulty opening any new merchant accounts during the time that they are on the MATCH List. And while it is possible to find processors who specialize in high-risk merchant accounts for MATCH Listed merchants, those accounts often carry high fees, reserve account requirements, and additional stipulations. If a MATCH Listed merchant is unable or unwilling to work with a high-risk provider, they will be unable to process credit or debit card payments entirely.
Once a merchant is placed on the MATCH List, they stay on the list for five years.
In the vast majority of circumstances, the only way to get off of the MATCH List is to wait five years. Mastercard and acquiring banks do not provide any systems for recourse for merchants who wish to be removed from the list. Some attorneys claim to have methods for getting merchants removed from the MATCH List but those claims are difficult to verify.
Being placed on the MATCH List has effectively killed countless merchant businesses. And even those merchants who survive being on the MATCH List have to deal with five years’ worth of additional fees and challenges. It is clearly in the best interest of all merchants to avoid being placed on the MATCH List. For merchants who aren’t engaging in fraudulent or criminal activities, this generally means preventing excessive chargebacks. An effective chargeback prevention program is an essential tool for businesses who wish to avoid the MATCH List.