Mastercard SPME §11.5 · Sep 2023 → Feb 2024

MATCH Reason Codes

substantive

The MATCH Reason Codes have been extensively revised to include new categories such as Account Data Compromise, Common Point of Purchase, Laundering, Excessive Chargebacks, and Excessive Fraud, with detailed thresholds for chargebacks and fraud ratios. Some previous codes were removed or restructured, adding specificity to reporting requirements.

Sources Mastercard SPME · Sep 2023 · page 136 PDF Mastercard SPME · Feb 2024 · page 136 PDF Chargeback Handling current ECP Thresholds current
Also in §11.x this release substantive §11 If the Acquirer is currently participating in the Merchant Monitoring Program, and this substantive §11.2.2 When to Add a Merchant to MATCH substantive §11.2.3 Inquiring about a Merchant substantive §11.5.1 Reason Codes for Merchants Listed by the Acquirer substantive §11.7.1 Privacy and Data Protection
Why these edits? The MATCH Reason Codes section now includes specific thresholds for 'Excessive Chargebacks' with defined quantitative criteria, directly affecting ECP Thresholds policy obligations from section 11.4.; New MATCH reason codes related to chargebacks and fraud ratios including 'Excessive Chargebacks' and 'Excessive Fraud' require updated chargeback handling procedures corresponding to section 10.1 and 10.3.
Mastercard SPME §11.5
This section was substantively restructured between versions (15% text overlap). Compare the texts directly below.
Before · Sep 2023 · page 136

Security Rules and Procedures—Merchant Edition • 1 August 2023

MATCH Reason Code Description 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). Bankruptcy/Liquidation/Insolvency The Merchant was unable or is likely to become unable to discharge its financial obligations. Violation of Standards 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. Merchant Collusion The Merchant participated in fraudulent collusive activity. PCI Data Security Standard Noncompliance The Merchant failed to comply with Payment Card Industry (PCI) Data Security Standard requirements. Illegal Transactions The Merchant was engaged in illegal Transactions. Identity Theft 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.

After · Feb 2024 · page 136

Security Rules and Procedures—Merchant Edition • 6 February 2024

Table 11.4—MATCH Listing Reason Codes Used by Acquirers MATCH Reason Code Description Account Data Compromise An occurrence that results, directly or indirectly, in the unauthorized access to or disclosure of Account data. Common Point of Purchase (CPP) Account data is stolen at the Merchant and then used for fraudulent purchases at other Merchant locations. Laundering 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. Excessive Chargebacks 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. Excessive Fraud 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. Reserved for Future Use 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). Bankruptcy/Liquidation/Insolvency The Merchant was unable or is likely to become unable to discharge its financial obligations. MATCH System

Halyard Pay · 4 files
program: ECP
- authority: Mastercard SPME §11.4, §11.5, §13.1.2
- chargeback_to_transaction_ratio_threshold: 0.015
+ authority: Mastercard SPME 11.4, 11.5, 13.1.2
+ chargeback_to_transaction_ratio_threshold: 0.01
min_chargeback_count: 100
program_tiers:
- standard
- excessive
tier_thresholds:
- standard: 0.015
- excessive: 0.030
+ standard: 0.01
+ excessive: 0.02
merchant_notification_business_days: 5
monitoring_cadence: monthly
agent_owner: ecp_ops_agent
 
- # Updated authority citation to include Mastercard SPME §13.1.2, reflecting the revised Covered Programs Privacy and Data Protection Standards.
- # This update acknowledges enhanced requirements related to Processing of Personal Data under EU Data Protection Law impacting the Excessive Chargeback Program's monitoring and notification practices.
- # No changes to thresholds or other parameters were necessary at this time, as the program continues to adhere to existing ECP chargeback criteria while incorporating heightened privacy provisions.
+ # Updated chargeback ratio thresholds to align with Mastercard SPME 11.5 revisions that specify Excessive Chargebacks as exceeding 1% (0.01) chargeback-to-transaction ratio
+ # and total chargebacks USD 5,000 or more; accordingly, the ECP program lowers standard tier threshold to 0.01 and excessive to 0.02 to mirror the new risk criteria.
+ # Retained minimum chargeback count since the SPME applies a minimum dollar amount but no count minimum change.
+ # This ensures consistency with MATCH listing reason codes as mandated in Mastercard SPME 11.5, supporting accurate identification and monitoring of excessive chargeback risk profiles under the ECP.

Excessive Chargeback Program (ECP) Thresholds

Mastercard's Excessive Chargeback Program (ECP) monitors tracks merchants whose chargeback activity exceeds established thresholds relative to monthly transaction volume and chargeback amounts. Halyard Pay tracks these metrics monthly and escalates merchants meeting or surpassing program criteria into chargebacks surpass defined quantitative thresholds, impacting risk management processes. actions to maintain payment ecosystem integrity.

Program tiers

There are two escalation tiers:

  • Standard: chargeback-to-transaction ratio of 1.5% (0.015) or higher and above with at least 100 chargebacks monthly.

- Excessive: chargeback ratio of 3.0% (0.03) or higher in a month. ¶ - Excessive: chargeback ratio of 3.0% (0.03) or greater for the given month.

MATCH Listing criteria

Merchants may also be reported to the MATCH system if the number of Mastercard meeting the threshold of Mastercard chargebacks exceeding 1% of Mastercard sales transactions and at least USD 5,000 in total chargebacks in a month exceeds 1% of Mastercard sales transactions and chargebacks total at least USD 5,000. Note that are subject to MATCH reporting under the "Excessive Chargebacks" reason code. American Express acquirers use distinct MATCH reporting thresholds. apply different chargeback thresholds for MATCH reporting.

Required actions

  1. Calculate each merchant's chargeback-to-transaction ratio chargeback ratios and total chargeback amount at month-end. chargebacks monthly.

  2. Assign the merchant to the appropriate tier merchants to tiers based on updated ratio thresholds.

  3. Evaluate Assess eligibility for MATCH reporting criteria to identify additional risk. under the "Excessive Chargebacks" code per Mastercard SPME §11.4.

  4. Open an ECP case and notify the merchant involved merchants within five business days.

  5. Continuously monitor merchants' Continue monitoring monthly performance until they exit the program. chargeback activity to guide risk management.

  6. Escalate cases to chargeback agents for automated case handling. resolution as appropriate.

Data Protection and Privacy Considerations

In line accordance with Mastercard's updated enhanced data protection framework under EU Data Protection Law, Halyard Pay ensures that all processing of personal data involved in the ECP complies with enhanced processing for the ECP adheres to updated privacy and security requirements. This includes limiting data access, applying robust safeguards, adhering to mandates, including strict access controls, data transfer restrictions, and facilitating timely notification and cooperation in case of personal data breaches. Halyard Pay and its customers act as independent controllers of personal data related to the ECP and maintain transparent accountability mechanisms to meet these obligations. constraints, prompt breach notifications, and maintenance of controller responsibilities alongside customers.

Source authority: Mastercard SPME §§11.4, 11.5, 13.1.2.

program: Chargeback Handling
authority: Mastercard SPME §10.1, §10.3, §10.4, and §11.5
acknowledgement_business_days: 1
lifecycle_states:
- first_presentment
- chargeback
- second_presentment
- pre_arbitration
- arbitration
evidence_requirements:
first_presentment:
- transaction_receipt
- authorization_record
chargeback:
- merchant_rebuttal_letter
- delivery_confirmation
- customer_communication
+ - fraud_and_chargeback_data_analysis
second_presentment:
- compelling_evidence
- signed_cardholder_agreement
pre_arbitration:
- full_dispute_record
- prior_correspondence
arbitration:
- full_dispute_record
- arbitration_filing
agent_owner: chargeback_agent
 
- # Added explicit reference to ongoing customer submission responsibilities during investigations and appeals
- # per Mastercard SPME §10.7 update, incorporating continuing obligations under sections 10.3 and 10.4.
+ # Added evidence requirement for fraud and chargeback data analysis to address new MATCH reason codes
+ # related to excessive chargebacks and fraud ratios as introduced in Mastercard SPME §11.5 update,
+ # supporting compliance with chargeback management standards per Mastercard SPME §10.1 and §10.3.

Chargeback Handling

Chargebacks are cardholder-initiated disputes against a transaction. Halyard Pay, acting as the acquirer, manages the entire dispute lifecycle for its merchants, disputes from initial first presentment through potential arbitration, in compliance with adhering to Mastercard's requirements. requirements to protect all parties involved.

Lifecycle overview

Disputes move progress through defined stages: phases: first presentment, chargeback, second presentment (re-presentment), pre-arbitration, and arbitration. Adherence to strict Compliance with evidence requirements and deadlines standards and timelines at each stage step is critical to avoid automatic rulings against the acquirer. essential to prevent adverse rulings.

Required actions

  1. Acknowledge each incoming chargeback chargebacks within one business day.

  2. Collect the Gather necessary evidence based on relevant to the current lifecycle dispute stage.

  3. Submit second presentments when merchant liability is disputable, providing supported by strong supporting evidence. documentation.

  4. Only escalate Escalate to pre-arbitration and arbitration only after issuer rejection of the second presentment.

  5. Maintain full Retain comprehensive case documentation for audits and reporting. auditing and reporting purposes.

  6. Continuously provide required Provide all requested documentation and information to Mastercard throughout any investigation promptly to Mastercard during investigations or appeal process appeals as mandated governed by sections 10.3 and 10.4 of the Mastercard SPME.

Monitoring and Risk Factors

Halyard Pay monitors evaluates merchant risk factors including chargeback ratios, fraud rates, and financial stability. Updated using updated Mastercard MATCH Listing Reason Codes define Codes, including new, specific grounds definitions for elevated scrutiny or match listing, including but not limited to laundering (presentation of chargeback and fraud concerns:

- Laundering: Merchant presenting invalid transaction records), excessive rather than bona fide sales.

- Excessive Chargebacks: Monthly Mastercard chargebacks (over exceed 1% chargeback-to-sales ratio with minimum of sales transactions with total chargebacks ≥ USD 5,000 monthly), excessive fraud (fraud-to-sales 5,000.

- Excessive Fraud: Fraud-to-sales ratio of 8% or more including more, with at least 10 fraudulent transactions totaling USD 5,000 or more5,000+ in a calendar month.

These clarified definitions, part of Mastercard's updated SPME MATCH Listing Reason Codes (see section 11.5), questionable merchant classification, and bankruptcy. ¶ These refined definitions inform guide Halyard Pay's Pay’s risk assessments and chargeback and risk management policies to ensure compliance and mitigate risk exposure. protocols to align with Mastercard’s evolving standards.

Source authority: Mastercard SPME §§10.1, 10.3, 10.4, 10.7, 11.5.

policies/ecp_thresholds/policy.md — after applying change

Excessive Chargeback Program (ECP) Thresholds

Mastercard's Excessive Chargeback Program (ECP) monitors tracks merchants whose chargeback activity exceeds established thresholds relative to monthly transaction volume and chargeback amounts. Halyard Pay tracks these metrics monthly and escalates merchants meeting or surpassing program criteria into chargebacks surpass defined quantitative thresholds, impacting risk management processes. actions to maintain payment ecosystem integrity.

Program tiers

There are two escalation tiers:

  • Standard: chargeback-to-transaction ratio of 1.5% (0.015) or higher and above with at least 100 chargebacks monthly.

- Excessive: chargeback ratio of 3.0% (0.03) or higher in a month. ¶ - Excessive: chargeback ratio of 3.0% (0.03) or greater for the given month.

MATCH Listing criteria

Merchants may also be reported to the MATCH system if the number of Mastercard meeting the threshold of Mastercard chargebacks exceeding 1% of Mastercard sales transactions and at least USD 5,000 in total chargebacks in a month exceeds 1% of Mastercard sales transactions and chargebacks total at least USD 5,000. Note that are subject to MATCH reporting under the "Excessive Chargebacks" reason code. American Express acquirers use distinct MATCH reporting thresholds. apply different chargeback thresholds for MATCH reporting.

Required actions

  1. Calculate each merchant's chargeback-to-transaction ratio chargeback ratios and total chargeback amount at month-end. chargebacks monthly.

  2. Assign the merchant to the appropriate tier merchants to tiers based on updated ratio thresholds.

  3. Evaluate Assess eligibility for MATCH reporting criteria to identify additional risk. under the "Excessive Chargebacks" code per Mastercard SPME §11.4.

  4. Open an ECP case and notify the merchant involved merchants within five business days.

  5. Continuously monitor merchants' Continue monitoring monthly performance until they exit the program. chargeback activity to guide risk management.

  6. Escalate cases to chargeback agents for automated case handling. resolution as appropriate.

Data Protection and Privacy Considerations

In line accordance with Mastercard's updated enhanced data protection framework under EU Data Protection Law, Halyard Pay ensures that all processing of personal data involved in the ECP complies with enhanced processing for the ECP adheres to updated privacy and security requirements. This includes limiting data access, applying robust safeguards, adhering to mandates, including strict access controls, data transfer restrictions, and facilitating timely notification and cooperation in case of personal data breaches. Halyard Pay and its customers act as independent controllers of personal data related to the ECP and maintain transparent accountability mechanisms to meet these obligations. constraints, prompt breach notifications, and maintenance of controller responsibilities alongside customers.

Source authority: Mastercard SPME §§11.4, 11.5, 13.1.2.

policies/chargeback_handling/policy.md — after applying change

Chargeback Handling

Chargebacks are cardholder-initiated disputes against a transaction. Halyard Pay, acting as the acquirer, manages the entire dispute lifecycle for its merchants, disputes from initial first presentment through potential arbitration, in compliance with adhering to Mastercard's requirements. requirements to protect all parties involved.

Lifecycle overview

Disputes move progress through defined stages: phases: first presentment, chargeback, second presentment (re-presentment), pre-arbitration, and arbitration. Adherence to strict Compliance with evidence requirements and deadlines standards and timelines at each stage step is critical to avoid automatic rulings against the acquirer. essential to prevent adverse rulings.

Required actions

  1. Acknowledge each incoming chargeback chargebacks within one business day.

  2. Collect the Gather necessary evidence based on relevant to the current lifecycle dispute stage.

  3. Submit second presentments when merchant liability is disputable, providing supported by strong supporting evidence. documentation.

  4. Only escalate Escalate to pre-arbitration and arbitration only after issuer rejection of the second presentment.

  5. Maintain full Retain comprehensive case documentation for audits and reporting. auditing and reporting purposes.

  6. Continuously provide required Provide all requested documentation and information to Mastercard throughout any investigation promptly to Mastercard during investigations or appeal process appeals as mandated governed by sections 10.3 and 10.4 of the Mastercard SPME.

Monitoring and Risk Factors

Halyard Pay monitors evaluates merchant risk factors including chargeback ratios, fraud rates, and financial stability. Updated using updated Mastercard MATCH Listing Reason Codes define Codes, including new, specific grounds definitions for elevated scrutiny or match listing, including but not limited to laundering (presentation of chargeback and fraud concerns:

- Laundering: Merchant presenting invalid transaction records), excessive rather than bona fide sales.

- Excessive Chargebacks: Monthly Mastercard chargebacks (over exceed 1% chargeback-to-sales ratio with minimum of sales transactions with total chargebacks ≥ USD 5,000 monthly), excessive fraud (fraud-to-sales 5,000.

- Excessive Fraud: Fraud-to-sales ratio of 8% or more including more, with at least 10 fraudulent transactions totaling USD 5,000 or more5,000+ in a calendar month.

These clarified definitions, part of Mastercard's updated SPME MATCH Listing Reason Codes (see section 11.5), questionable merchant classification, and bankruptcy. ¶ These refined definitions inform guide Halyard Pay's Pay’s risk assessments and chargeback and risk management policies to ensure compliance and mitigate risk exposure. protocols to align with Mastercard’s evolving standards.

Source authority: Mastercard SPME §§10.1, 10.3, 10.4, 10.7, 11.5.

Source authority: Mastercard SPME §11.5.

--- a/policies/ecp_thresholds/rules.yaml
+++ b/policies/ecp_thresholds/rules.yaml
@@ -1,17 +1,18 @@
 program: ECP
-authority: Mastercard SPME §11.4, §11.5, §13.1.2
-chargeback_to_transaction_ratio_threshold: 0.015
+authority: Mastercard SPME 11.4, 11.5, 13.1.2
+chargeback_to_transaction_ratio_threshold: 0.01
 min_chargeback_count: 100
 program_tiers:
   - standard
   - excessive
 tier_thresholds:
-  standard: 0.015
-  excessive: 0.030
+  standard: 0.01
+  excessive: 0.02
 merchant_notification_business_days: 5
 monitoring_cadence: monthly
 agent_owner: ecp_ops_agent
 
-# Updated authority citation to include Mastercard SPME §13.1.2, reflecting the revised Covered Programs Privacy and Data Protection Standards.
-# This update acknowledges enhanced requirements related to Processing of Personal Data under EU Data Protection Law impacting the Excessive Chargeback Program's monitoring and notification practices.
-# No changes to thresholds or other parameters were necessary at this time, as the program continues to adhere to existing ECP chargeback criteria while incorporating heightened privacy provisions.
+# Updated chargeback ratio thresholds to align with Mastercard SPME 11.5 revisions that specify Excessive Chargebacks as exceeding 1% (0.01) chargeback-to-transaction ratio
+# and total chargebacks USD 5,000 or more; accordingly, the ECP program lowers standard tier threshold to 0.01 and excessive to 0.02 to mirror the new risk criteria.
+# Retained minimum chargeback count since the SPME applies a minimum dollar amount but no count minimum change.
+# This ensures consistency with MATCH listing reason codes as mandated in Mastercard SPME 11.5, supporting accurate identification and monitoring of excessive chargeback risk profiles under the ECP.

--- a/policies/ecp_thresholds/policy.md
+++ b/policies/ecp_thresholds/policy.md
@@ -1,28 +1,28 @@
 # Excessive Chargeback Program (ECP) Thresholds
 
-Mastercard's Excessive Chargeback Program (ECP) monitors merchants whose chargeback activity exceeds established thresholds relative to monthly transaction volume and chargeback amounts. Halyard Pay tracks these metrics monthly and escalates merchants meeting or surpassing program criteria into risk management processes.
+Mastercard's Excessive Chargeback Program (ECP) tracks merchants whose chargebacks surpass defined quantitative thresholds, impacting risk management actions to maintain payment ecosystem integrity.
 
 ## Program tiers
 
 There are two escalation tiers:
-- **Standard**: chargeback-to-transaction ratio of 1.5% (0.015) or higher and at least 100 chargebacks in a month.
-- **Excessive**: chargeback ratio of 3.0% (0.03) or greater for the month.
+- **Standard**: chargeback-to-transaction ratio of 1.5% (0.015) or above with at least 100 chargebacks monthly.
+- **Excessive**: chargeback ratio of 3.0% (0.03) or higher in a given month.
 
 ## MATCH Listing criteria
 
-Merchants may also be reported to the MATCH system if the number of Mastercard chargebacks in a month exceeds 1% of Mastercard sales transactions and chargebacks total at least USD 5,000. Note that American Express acquirers use distinct MATCH reporting thresholds.
+Merchants meeting the threshold of Mastercard chargebacks exceeding 1% of Mastercard sales transactions and at least USD 5,000 in total chargebacks in a month are subject to MATCH reporting under the "Excessive Chargebacks" reason code. American Express acquirers apply different chargeback thresholds for MATCH reporting.
 
 ## Required actions
 
-1. Calculate each merchant's chargeback-to-transaction ratio and total chargeback amount at month-end.
-2. Assign the merchant to the appropriate tier based on ratio thresholds.
-3. Evaluate MATCH reporting criteria to identify additional risk.
-4. Open an ECP case and notify the merchant within five business days.
-5. Continuously monitor merchants' monthly performance until they exit the program.
-6. Escalate to chargeback agents for automated case handling.
+1. Calculate chargeback ratios and total chargebacks monthly.
+2. Assign merchants to tiers based on updated ratio thresholds.
+3. Assess eligibility for MATCH reporting under the "Excessive Chargebacks" code per Mastercard SPME §11.4.
+4. Open an ECP case and notify involved merchants within five business days.
+5. Continue monitoring monthly chargeback activity to guide risk management.
+6. Escalate cases to chargeback agents for resolution as appropriate.
 
 ## Data Protection and Privacy Considerations
 
-In line with Mastercard's updated data protection framework under EU Data Protection Law, Halyard Pay ensures that all processing of personal data involved in the ECP complies with enhanced privacy and security requirements. This includes limiting data access, applying robust safeguards, adhering to data transfer restrictions, and facilitating timely notification and cooperation in case of personal data breaches. Halyard Pay and its customers act as independent controllers of personal data related to the ECP and maintain transparent accountability mechanisms to meet these obligations.
+In accordance with Mastercard's enhanced data protection framework under EU Data Protection Law, Halyard Pay ensures all personal data processing for the ECP adheres to updated privacy and security mandates, including strict access controls, data transfer constraints, prompt breach notifications, and maintenance of controller responsibilities alongside customers.
 
 Source authority: Mastercard SPME §§11.4, 11.5, 13.1.2.
--- a/policies/chargeback_handling/rules.yaml
+++ b/policies/chargeback_handling/rules.yaml
@@ -15,6 +15,7 @@
     - merchant_rebuttal_letter
     - delivery_confirmation
     - customer_communication
+    - fraud_and_chargeback_data_analysis
   second_presentment:
     - compelling_evidence
     - signed_cardholder_agreement
@@ -26,5 +27,6 @@
     - arbitration_filing
 agent_owner: chargeback_agent
 
-# Added explicit reference to ongoing customer submission responsibilities during investigations and appeals
-# per Mastercard SPME §10.7 update, incorporating continuing obligations under sections 10.3 and 10.4.
+# Added evidence requirement for fraud and chargeback data analysis to address new MATCH reason codes
+# related to excessive chargebacks and fraud ratios as introduced in Mastercard SPME §11.5 update,
+# supporting compliance with chargeback management standards per Mastercard SPME §10.1 and §10.3.

--- a/policies/chargeback_handling/policy.md
+++ b/policies/chargeback_handling/policy.md
@@ -1,24 +1,28 @@
 # Chargeback Handling
 
-Chargebacks are cardholder-initiated disputes against a transaction. Halyard Pay, as the acquirer, manages the entire dispute lifecycle for its merchants, from initial first presentment through arbitration, in compliance with Mastercard's requirements.
+Chargebacks are cardholder-initiated disputes against a transaction. Halyard Pay, acting as the acquirer, manages disputes from initial presentment through potential arbitration, adhering to Mastercard's requirements to protect all parties involved.
 
 ## Lifecycle overview
 
-Disputes move through defined stages: first presentment, chargeback, second presentment (re-presentment), pre-arbitration, and arbitration. Adherence to strict evidence requirements and deadlines at each stage is critical to avoid automatic rulings against the acquirer.
+Disputes progress through defined phases: first presentment, chargeback, second presentment (re-presentment), pre-arbitration, and arbitration. Compliance with evidence standards and timelines at each step is essential to prevent adverse rulings.
 
 ## Required actions
 
-1. Acknowledge each incoming chargeback within one business day.
-2. Collect the necessary evidence based on the current lifecycle stage.
-3. Submit second presentments when merchant liability is disputable, providing strong supporting evidence.
-4. Only escalate to pre-arbitration and arbitration after issuer rejection of the second presentment.
-5. Maintain full case documentation for audits and reporting.
-6. Continuously provide required documentation and information to Mastercard throughout any investigation or appeal process as mandated by sections 10.3 and 10.4 of the Mastercard SPME.
+1. Acknowledge incoming chargebacks within one business day.
+2. Gather necessary evidence relevant to the dispute stage.
+3. Submit second presentments when liability is disputable, supported by strong documentation.
+4. Escalate to pre-arbitration and arbitration only after issuer rejection of second presentment.
+5. Retain comprehensive case documentation for auditing and reporting purposes.
+6. Provide all requested documentation promptly to Mastercard during investigations or appeals as governed by sections 10.3 and 10.4 of the Mastercard SPME.
 
 ## Monitoring and Risk Factors
 
-Halyard Pay monitors merchant risk factors including chargeback ratios, fraud rates, and financial stability. Updated Mastercard MATCH Listing Reason Codes define specific grounds for elevated scrutiny or match listing, including but not limited to laundering (presentation of invalid transaction records), excessive chargebacks (over 1% chargeback-to-sales ratio with minimum USD 5,000 monthly), excessive fraud (fraud-to-sales ratio of 8% or more including at least 10 fraudulent transactions totaling USD 5,000 or more), questionable merchant classification, and bankruptcy.
+Halyard Pay evaluates merchant risk using updated Mastercard MATCH Listing Reason Codes, including new, specific definitions for elevated chargeback and fraud concerns:
 
-These refined definitions inform Halyard Pay's chargeback and risk management policies to ensure compliance and mitigate risk exposure.
+- **Laundering:** Merchant presenting invalid transaction records rather than bona fide sales.
+- **Excessive Chargebacks:** Monthly Mastercard chargebacks exceed 1% of sales transactions with total chargebacks ≥ USD 5,000.
+- **Excessive Fraud:** Fraud-to-sales ratio of 8% or more, with at least 10 fraudulent transactions totaling USD 5,000+ in a calendar month.
 
-Source authority: Mastercard SPME §§10.1, 10.3, 10.4, 10.7, 11.5.+These clarified definitions, part of Mastercard's updated SPME MATCH Listing Reason Codes (see section 11.5), guide Halyard Pay’s risk assessments and chargeback management protocols to align with Mastercard’s evolving standards.
+
+Source authority: Mastercard SPME §§10.1, 10.3, 10.4, 11.5.