Mastercard SPME §8.4.2 · May 2023 → Sep 2023

Mastercard Commencement of an Investigation

substantive
⚠ Extraction warning — review against source PDF. One side of the Mastercard SPME text below appears to contain only the page-running header, not body content. This usually means the section heading fell on a page boundary and the body was attributed to a neighbouring section in the source PDF. The AI summary and proposed edit below may be misleading. Verify in: May 2023 · page 86 ↗ · Sep 2023 · page 80 ↗.

The updated section specifies procedures for Issuers to notify Mastercard via a web-based form if a Merchant is deemed questionable, detailing required information to be provided. It also introduces the possibility of a filing fee for Issuer notifications and requires Acquirers to promptly notify Mastercard if acquiring for a Questionable Merchant.

Sources Mastercard SPME · May 2023 · page 86 PDF Mastercard SPME · Sep 2023 · page 80 PDF BRAM Response current
Also in §8.x this release breaking §8.6.7 Franchise Management Program (FMP) Questionnaire-based Review substantive §8.3.4 Additional ECM and HECM Requirements substantive §8.4 Questionable Merchant Audit Program (QMAP) substantive §8.4.1 QMAP Definitions substantive §8.4.4 Mastercard Notification to Acquirers substantive §8.4.6 Mastercard Determination substantive §8.4.7 Chargeback Responsibility substantive §8.6.2 Investigation Process substantive §8.6.6 MATCH Reporting substantive §8.7.3 Mastercard Notification to Acquirers substantive §8.7.4 Mastercard Determination substantive §8.7.5 Assessments, Recovery Amounts, and Fees
Why these edits? The updated Mastercard SPME section 8.4.2 introduces new Issuer and Acquirer notification procedures for Questionable Merchants, including detailed information requirements and possible filing fees, which aligns with and impacts the BRAM Investigation Response obligations.
Mastercard SPME §8.4.2
This section was substantively restructured between versions (6% text overlap). Compare the texts directly below.
Before · May 2023 · page 86

Security Rules and Procedures—Merchant Edition • 7 February 2023

After · Sep 2023 · page 80

Security Rules and Procedures—Merchant Edition • 1 August 2023

The QMAP Issuer Referral Form, completed by the Issuer, is available on Mastercard Connect > Support > Form. Transactions that occurred during the Case Scope Period may qualify as eligible for recovery under the QMAP. Effective 1 January 2022, if an Issuer has reason to believe that a Merchant may be a Questionable Merchant, the Issuer may notify Mastercard by web-based form at https:// form.mastercard.com/jfe/form/SV_01AtAPzF9FXjzrD. Transactions that occurred during the Case Scope Period may qualify as eligible for recovery under the QMAP. In the notification, the Issuer must provide the basis for the Issuer’s reason to believe that the Merchant may be a Questionable Merchant, and must provide all of the following information:

  1. Issuer name and Member ID;
  2. Acquirer name and Member ID;
  3. Merchant name and address (city, state or province, and country);
  4. Total number of Transactions conducted at the Questionable Merchant by the Issuer’s Cardholders;
  5. Total dollar volume of Issuer losses at the Questionable Merchant;
  6. Percentage of Transactions attributed to Cardholder bust-out accounts, if applicable; and
  7. Details of each Issuer-confirmed fraudulent Transaction, including Cardholder account number, Transaction date and time, and Transaction amount in U.S. dollars. Mastercard may charge the Issuer a filing fee for each Merchant notification at the commencement of a QMAP investigation as described in section 8.4.9 of this manual. If an Acquirer becomes aware that it is acquiring for a Questionable Merchant, the Acquirer must notify Mastercard promptly by email message at qmap@mastercard.com.
Halyard Pay · 2 files
program: BRAM
- authority: Mastercard SPME §8.6.2, §10.2
+ authority: Mastercard SPME §8.4.2, §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
+ - police_report # Mandatory for coercion claims as per updated SPME §8.6.2
+ - issuer_notification_details # Added to capture required Issuer notification info under SPME §8.4.2
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.
+ # Updated to reflect the extended discretionary investigation period, mandatory police report inclusion for coercion claims (SPME §8.6.2),
+ # and new detailed notification and filing fee requirements for Questionable Merchants reporting by Issuers and Acquirers (SPME §8.4.2).

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.

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

4. If the merchant is suspected of being a Questionable Merchant, ensure prompt notification to Mastercard via qmap@mastercard.com.

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.

## Notification for Questionable Merchants

Per Mastercard SPME §8.4.2, if an issuer suspects a merchant to be questionable, they may notify

Mastercard through the web-based form provided. The notification must include comprehensive details

such as issuer and acquirer information, merchant details, transaction volumes, and specifics on confirmed

fraudulent transactions. Acquirers learning they are acquiring for a Questionable Merchant must notify

Mastercard promptly by email at qmap@mastercard.com. Mastercard may charge a filing fee upon

commencement of a QMAP investigation.

Source authority: Mastercard SPME §8.6.2, §8.4.2, §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.

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

4. If the merchant is suspected of being a Questionable Merchant, ensure prompt notification to Mastercard via qmap@mastercard.com.

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.

## Notification for Questionable Merchants

Per Mastercard SPME §8.4.2, if an issuer suspects a merchant to be questionable, they may notify

Mastercard through the web-based form provided. The notification must include comprehensive details

such as issuer and acquirer information, merchant details, transaction volumes, and specifics on confirmed

fraudulent transactions. Acquirers learning they are acquiring for a Questionable Merchant must notify

Mastercard promptly by email at qmap@mastercard.com. Mastercard may charge a filing fee upon

commencement of a QMAP investigation.

Source authority: Mastercard SPME §8.6.2, §8.4.2, §10.2.

Source authority: Mastercard SPME §8.4.2.

--- a/policies/bram_response/rules.yaml
+++ b/policies/bram_response/rules.yaml
@@ -1,13 +1,15 @@
 program: BRAM
-authority: Mastercard SPME §8.6.2, §10.2
+authority: Mastercard SPME §8.4.2, §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
+  - police_report  # Mandatory for coercion claims as per updated SPME §8.6.2
+  - issuer_notification_details  # Added to capture required Issuer notification info under SPME §8.4.2
 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.+# Updated to reflect the extended discretionary investigation period, mandatory police report inclusion for coercion claims (SPME §8.6.2),
+# and new detailed notification and filing fee requirements for Questionable Merchants reporting by Issuers and Acquirers (SPME §8.4.2).
--- a/policies/bram_response/policy.md
+++ b/policies/bram_response/policy.md
@@ -13,6 +13,7 @@
    - 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.
+4. If the merchant is suspected of being a Questionable Merchant, ensure prompt notification to Mastercard via qmap@mastercard.com.
 
 ## Additional Considerations for Coercion Claims
 
@@ -22,4 +23,13 @@
 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.
+## Notification for Questionable Merchants
+
+Per Mastercard SPME §8.4.2, if an issuer suspects a merchant to be questionable, they may notify
+Mastercard through the web-based form provided. The notification must include comprehensive details
+such as issuer and acquirer information, merchant details, transaction volumes, and specifics on confirmed
+fraudulent transactions. Acquirers learning they are acquiring for a Questionable Merchant must notify
+Mastercard promptly by email at qmap@mastercard.com. Mastercard may charge a filing fee upon
+commencement of a QMAP investigation.
+
+Source authority: Mastercard SPME §8.6.2, §8.4.2, §10.2.