Halyard Pay · Policy Updates Powered by Carver Agents

Mastercard SPME §8.6.2 · Jun 2022 → May 2023

Investigation Process

substantive

The investigation process for coercion claims now allows Mastercard discretion to extend the 120-day claim period and requires at least one claim to include a police report. Additionally, transactions must be reported with specific fraud codes, though Mastercard may consider others at its discretion. Mastercard will notify issuers with transactions during the inquiry period.

Sources Mastercard SPME · Jun 2022 · page 83 PDF Mastercard SPME · May 2023 · page 91 PDF BRAM Response current
Also in §8.x this release substantive §8 Separation control substantive §8.5 Issuer Monitoring Program (IMP) substantive §8.6 Coercion Program substantive §8.6.1 Issuer Submissions substantive §8.6.5 Chargeback Responsibility substantive §8.7.5 Assessments, Recovery Amounts, and Fees
Why these edits? The updated Mastercard SPME section 8.6.2 introduces additional investigation requirements for coercion claims, including the discretionary extension of the 120-day claim period and the necessity of a police report with at least one claim, which directly affects the BRAM Investigation Response procedures.
Mastercard SPME §8.6.2
Mastercard will investigate a claim of alleged coercion when the following criteria are met: • Within 120 calendar days from an alleged coercive event, Mastercard receives from two or more different issuers separate claims of alleged coerced Transactions performed by two or more unrelated Cardholders at the same Merchant location. The 120 calendar day period is calculated as 60 calendar days prior to and 60 calendar days after the date of the first alleged coerced Transaction. At Mastercard’s sole discretion, the 120 calendar day period may be expanded. • At least one claim of coercion includes a copy of a police report filed by the Cardholder • The Transactions resulting from the alleged coercion were reported to the Fraud and Loss Database using fraud type code 00 (Lost Fraud) or 01 (Stolen Fraud). At Mastercard’s sole discretion, a Transaction reported with a fraud reason code other than 00 or 01 may be included in the investigation. Additionally, Mastercard will notify those Issuers whose Cardholders have performed a Transaction at the Merchant within the 120 calendar day (or longer) period of the alleged coerced event and who have not already submitted a Mastercard Fraud Control Programs
Halyard Pay · 2 files
program: BRAM


- authority: Mastercard SPME §10.2


+ authority: Mastercard SPME §8.6.2, §10.2


response_window_days: 180


required_evidence:


  - transaction_monitoring_records


  - corrective_action_plan


+   - police_report  # Added requirement for police report according to updated SPME §8.6.2


halt_actions:


  - halt_new_merchant_onboarding


internal_notification_hours: 24


agent_owner: bram_response_agent


+ 


+ # Updated to reflect the extended discretionary investigation period and mandatory police report inclusion for at least one coercion claim as specified in Mastercard SPME §8.6.2.

BRAM Investigation Response

When Mastercard issues a Business Risk Assessment and Mitigation (BRAM) investigation

notice for one of our merchants, the acquirer must halt new merchant onboarding

immediately and submit an evidence package within one hundred eighty (180) days

of receipt of the notice.

Required actions

  1. Halt new merchant onboarding for the merchant under investigation.

  2. Compile and submit an evidence package containing:

  • Transaction monitoring records covering the prior 180 days.

  • A written corrective action plan.

- Documentation of any police reports related to alleged coercion claims if applicable.

3. Notify the Halyard Pay Compliance lead within 24 hours of receipt.

## Additional Considerations for Coercion Claims

When allegations of coerced Transactions arise, note that Mastercard may extend the usual 120-day

investigation period at its discretion. At least one claim must include a police report from the Cardholder.

Transactions reported as Lost or Stolen Fraud (fraud type codes 00 or 01) are subject to investigation,

though Mastercard may consider other fraud codes. Mastercard will notify issuers with Transactions at the

merchant within the investigation period to prompt claim submissions.

Source authority: Mastercard SPME §8.6.2, §10.2.

policies/bram_response/policy.md — after applying change

BRAM Investigation Response

When Mastercard issues a Business Risk Assessment and Mitigation (BRAM) investigation

notice for one of our merchants, the acquirer must halt new merchant onboarding

immediately and submit an evidence package within one hundred eighty (180) days

of receipt of the notice.

Required actions

  1. Halt new merchant onboarding for the merchant under investigation.

  2. Compile and submit an evidence package containing:

  • Transaction monitoring records covering the prior 180 days.

  • A written corrective action plan.

- Documentation of any police reports related to alleged coercion claims if applicable.

3. Notify the Halyard Pay Compliance lead within 24 hours of receipt.

## Additional Considerations for Coercion Claims

When allegations of coerced Transactions arise, note that Mastercard may extend the usual 120-day

investigation period at its discretion. At least one claim must include a police report from the Cardholder.

Transactions reported as Lost or Stolen Fraud (fraud type codes 00 or 01) are subject to investigation,

though Mastercard may consider other fraud codes. Mastercard will notify issuers with Transactions at the

merchant within the investigation period to prompt claim submissions.

Source authority: Mastercard SPME §8.6.2, §10.2.

Source authority: Mastercard SPME §8.6.2.

--- a/policies/bram_response/rules.yaml
+++ b/policies/bram_response/rules.yaml
@@ -1,10 +1,13 @@
 program: BRAM
-authority: Mastercard SPME §10.2
+authority: Mastercard SPME §8.6.2, §10.2
 response_window_days: 180
 required_evidence:
   - transaction_monitoring_records
   - corrective_action_plan
+  - police_report  # Added requirement for police report according to updated SPME §8.6.2
 halt_actions:
   - halt_new_merchant_onboarding
 internal_notification_hours: 24
 agent_owner: bram_response_agent
+
+# Updated to reflect the extended discretionary investigation period and mandatory police report inclusion for at least one coercion claim as specified in Mastercard SPME §8.6.2.
--- a/policies/bram_response/policy.md
+++ b/policies/bram_response/policy.md
@@ -11,6 +11,15 @@
 2. Compile and submit an evidence package containing:
    - Transaction monitoring records covering the prior 180 days.
    - A written corrective action plan.
+   - Documentation of any police reports related to alleged coercion claims if applicable.
 3. Notify the Halyard Pay Compliance lead within 24 hours of receipt.
 
-Source authority: Mastercard SPME §10.2.
+## Additional Considerations for Coercion Claims
+
+When allegations of coerced Transactions arise, note that Mastercard may extend the usual 120-day
+investigation period at its discretion. At least one claim must include a police report from the Cardholder.
+Transactions reported as Lost or Stolen Fraud (fraud type codes 00 or 01) are subject to investigation,
+though Mastercard may consider other fraud codes. Mastercard will notify issuers with Transactions at the
+merchant within the investigation period to prompt claim submissions.
+
+Source authority: Mastercard SPME §8.6.2, §10.2.