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Here’s what you need to know about MATCH and how it limits your ability to take credit cards, how to get off the list, & your best options for accepting payments.
Many people first hear about the Terminated Merchant File (TMF) or MATCH list when they find out they’re on it.
Sadly, you’re not the only merchant who’s been caught off guard. The truth is that most merchants won’t know that they are TMF’d or MATCH’d until they submit an application for a merchant account to a new processor and get declined. By then, it’s too late to avoid getting on the list, and the only thing you can do is try to get off it. Sometimes, even the best high-risk payment processors won’t accept merchants on the MATCH list. What then?
We hope you’re reading this article before you’ve been placed on the MATCH list, but if not, we’ll do our best to explain what it is, how it might affect the way you run your business, and whether there’s anything you can do to get yourself off the list.
Table of Contents
The MATCH list is essentially a blacklist for credit card processing. Businesses on the MATCH list have had merchant accounts terminated previously or deemed a significant risk for payment processors. The MATCH list is the same as the Terminated Merchant File (TMF), an older, more generic term.
The MATCH list is used by acquiring banks to screen potential applicants (particularly to see if that applicant has been terminated in the past). They do this to assess and control the risk associated with credit card processing. Essentially, the MATCH list is used by processors to avoid merchants who have been flagged as especially high risk.
In addition to Mastercard itself, acquiring banks can add/remove merchants to/from the MATCH database when they have the justification to do so. In fact, only the acquiring bank that put you on the list has the power to remove you from the list. Mastercard can also remove merchants from the list, but it rarely deals with merchants directly. This also makes it difficult for merchants to dispute their addition to the list.
Generally, a merchant ends up on the MATCH list because their activities, for one reason or another, create a higher risk for the acquiring bank to do business with them. The specific reasons for being added to the MATCH database can vary. Having too many chargebacks, participating in fraudulent activity, or money laundering are all activities that can get you listed.
In the past, Mastercard made it really easy for acquiring banks to add merchants to the list, but, in recent years, they’ve become stricter with their guidelines. A merchant must have done something specifically forbidden to land on the list. These bad acts are listed in a table in Mastercard’s Security Rules and Procedures (SRP), Section 11.5.
Here’s a table summarizing the reasons, along with their MATCH numerical codes:
Code | Description |
---|---|
01 | Account Data Compromise: The merchant has enabled, intentionally or unintentionally, an unauthorized party to access account data. |
02 | Common Point Of Purchase (CPP): Data stolen from a merchant’s system is used for fraudulent purchases elsewhere |
03 | Laundering: The merchant was engaged in laundering activity. |
04 | Excessive Chargebacks: The merchant’s chargebacks in any single month exceeded 1% of its Mastercard sales Transactions in that month, and those chargebacks totaled USD 5,000 or more. Or the merchant exceeded the chargeback thresholds of American Express, as determined by American Express. |
05 | Excessive Fraud: 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. |
07 | Fraud Conviction: There was a criminal fraud conviction of a principal owner or partner of the merchant. |
08 | Mastercard Questionable Merchant Audit Program: The merchant is flagged as a Questionable Merchant by the criteria established by the Mastercard Questionable Merchant Audit program. This process is started by a card issuer and leads to an investigation by Mastercard of 120 days of account activity. |
09 | Bankruptcy/Liquidation/Insolvency: The merchant was unable or is likely to become unable to discharge its financial obligations. |
10 | Violation of Standards: The merchant has been reported by Mastercard or American Express acquirer for violating rules or procedures of card usage. For example, ignoring minimum/maximum transaction amount restrictions. |
11 | Merchant Collusion: The merchant participated in fraudulent collusive activity. |
12 | PCI Data Security Standard Noncompliance: The merchant failed to comply with Payment Card Industry (PCI) Data Security Standard requirements. |
13 | Illegal Transactions: The merchant was engaged in illegal transactions. |
14 | Identity Theft: The acquirer has determined that the identity of the listed merchant or its principal owner(s) was unlawfully assumed to enter into a merchant agreement illegally. |
Note Code 06 is currently unused but is reserved for future use.
According to Mastercard (SRP, Section 11.2.2), an acquiring bank is required to put a merchant on the MATCH list if the merchant’s account was terminated for any reason on the list, and they must do so within five days of termination. Since the obligation is between the acquiring bank and Mastercard, there’s not much you can do to stop the bank.
If your acquiring bank (through your processor) terminates its business relationship with you for other reasons, then you would/should not be put on the list.
There’s no convenient portal or formal process for checking if you’re on the MATCH list. It is possible, however, to ask a payment processor or bank that is handling your account if you have been placed on the list.
Unfortunately, the most common way to find out is when your merchant account application is denied.
With how easy it is for acquiring banks to place merchants on the MATCH list, it is possible to land on it by accident or with limited evidence of wrongdoing.
Later in this article, we’ll look at what you can do if you believe you’ve accidentally been placed on the MATCH list.
There are only three ways to get off the MATCH list. To be removed from the Mastercard MATCH list, a merchant must:
These are the only reasons you can get off the MATCH list. Let’s look at these reasons in a little bit more detail.
Merchant records remain on the MATCH system for five years. Each month, MATCH automatically purges information that has been in the system for five years. This isn’t an ideal solution for most merchants, but you can at least rest assured that you won’t be on the MATCH list forever.
If you were added to the list by mistake, you must contact the acquiring bank that put you on the list. If you don’t know which bank was your acquiring bank, ask your payment processor. Before attempting this, make sure you have solid evidence you’ve been operating by the book.
Of course, you can do this yourself, but often a high-risk processor can help you. Some of them are experienced in getting people off the MATCH list and, with that experience, probably can tell you right away your odds of getting off the list.
If a high-risk processor can’t help you, a lawyer might be able to; just be aware of their limitation. While they might be able to more forcefully argue for you if you were put on the MATCH list by mistake, they can’t get you off the list if you were listed for actually having violated the items on the MATCH list.
The third and last reason you can be taken off the MATCH list is if you were put on the list because you were not PCI compliant but have since become compliant. Typically, you’ll still have to work through the acquirer who put you on the list, but this is one instance where you can contact Mastercard directly if your former acquirer is unwilling to help.
To get off the list, the most important information you’ll need is a letter or certificate of validation from a Mastercard-certified forensic examiner declaring that you are now PCI compliant. You’ll also need the following:
It’s possible to get a merchant account if you’re on the MATCH list, but it may not be easy.
While acquirers must put you on the MATCH list if they terminate you for MATCH list reasons, they’re not required to refuse to take you as a merchant. The MATCH list indicates the level of risk of doing business with you, and some acquirers and processors have a higher tolerance for risk than others. These high-risk processors have less favorable terms, but they can allow you to continue accepting credit cards. We’ll take a closer look at this option in the next section.
So long as you remain on the MATCH list, you’ll be considered a high-risk merchant even if you wouldn’t otherwise qualify as one. If you’ve been added by mistake or due to PCI non-compliance, remember that you may be able to get off the list.
So, what do you do if you’re on the MATCH list and still need to be able to accept payments? Let’s take a look at your options.
High-risk payment processors specialize in finding merchant accounts for businesses that are hard to place. Be aware, however, that merchants on the MATCH list are particularly hard to place, even for high-risk processors.
For example, Durango Merchant Services can place some MATCH-listed businesses but only if they’ve been placed on the list due to excessive chargebacks (Code 04) and don’t owe money to the processor that placed them on the list. Durango has several advantages for high risk merchants, including support for multiple payment methods. Read our Durango review for a more in-depth look at the company.
Another high-risk processor that might be able to help is eMerchantBroker (EMB). EMB specifically states on its website that it will work with MATCH list merchants. Be sure to check out our in-depth review of EMB.
Working with a high-risk specialist comes with trade-offs. Here are the pros:
And here are the cons:
Aside from security risks and mitigation, cash doesn’t cost anything per transaction, and no one can stop you from using it. Of course, this is only a solution for businesses that do in-person transactions.
Before you go cash-only, make sure you’re aware of your customers’ buying habits. Fewer people are carrying cash these days than ever before.
These are separate methods traditionally suitable for businesses that continue to take check payments. They have rules different from credit card processing rules, and ACH might be suitable if you’re on the MATCH list solely because you have a high chargeback percentage.
ACH and echeck can’t completely fill the niche of credit cards due to being relatively slow and cumbersome but are particularly useful for subscriptions and recurring payments.
Most major mobile wallets, such as Apple Pay, Google Pay, Samsung Pay, Square’s Cash App, and Venmo, can do P2P payments. Typically, you can send a payment request to the payor and have them pay via a single button. Because the money exchange is made between two account holders of the same service, there’s no need to go through an acquiring bank to set up the account, so there’s no reason for anyone to check your business against the MATCH list.
Note this suggestion is limited to P2P payments. If you wish to take credit cards through, say, Apple Pay, you’ll still need a processor, and your business will still be checked against the MATCH list before your account can be approved.
Cryptocurrency proponents will tell you that one of the main arguments in its favor is that users can’t easily be censored by putting them on a centralized blocklist. While adoption is still relatively low, crypto can be used for both online and point of sale transactions.
Crypto transactions are a type of P2P transaction between user wallets. For convenience, however, some companies offer crypto gateway accounts that make it easy to take multiple types of cryptocurrency through a single portal. They can also settle the transaction in dollars if you want to avoid handling crypto yourself.
No, it’s not the end of the world if you land on the MATCH list, but it’s pretty bad. There are many different reasons you could end up on the list. Depending on why you were put on the MATCH list, you might be able to get off it early, but in most cases, you’ll have to wait five years and age off the list.
For instance, if you land on the list due to a mistake by the acquiring bank, you can almost certainly get off the list right away. If excessive chargebacks are the reason, you might have to stay on the list, but you may still be able to get a merchant account to process credit cards through a high-risk processor. But if you were put on the list due to bankruptcy or illegal activity, you’re out of luck.
So the lesson here is that it’s best to avoid getting on the MATCH list in the first place. Understand all the reasons you might be put on the list and do your best to avoid them. Payment cards are increasingly becoming the primary way consumers pay for goods and services; not being able to take payments this way could mean the end of your business. So be careful!
Have you had experience with the MATCH list? We’re interested in hearing from you. Leave us a note below.
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