Practice Area
Mastercard MATCH List Removal
A Mastercard MATCH entry can make it difficult for a merchant to obtain or maintain payment processing. Many acquiring programs will not approve a merchant with a confirmed MATCH result, although the system does not itself prohibit approval. A listing can also affect other businesses associated with the merchant’s owners.
Rome LLP represents merchants and principals seeking to correct or remove unsupported MATCH entries. We focus on the assigned reason code, the facts known when the merchant relationship ended, and whether the acquiring bank and its registered service providers followed Mastercard’s reporting requirements.
The firm has obtained removal of unsupported MATCH entries involving excessive chargebacks, excessive fraud, violations of standards, illegal transactions, and identity theft.
How MATCH Pro Works
MATCH Pro is a risk database used in merchant underwriting. Mastercard requires an acquiring bank to query MATCH Pro before signing a merchant agreement or enabling the merchant to accept transactions. A possible match does not decide the application. The result must be reviewed to determine whether it relates to the applicant and whether the merchant can be accepted under the applicable credit policy.
The acquiring bank is responsible for ensuring that the inquiry occurs, but it may delegate day-to-day underwriting to a registered service provider. In many sponsored programs, the service provider reviews the application and makes approval decisions under credit policies established or approved by the bank. The bank may require escalation of a possible MATCH result and retain final authority over whether the merchant can be approved.
A merchant must be added to MATCH if the acquiring relationship ends while the acquiring bank has reason to believe that a defined MATCH condition exists. The obligation may arise whether the merchant account is terminated by the bank or its registered service provider or the merchant closes it voluntarily. The entry must be made within five calendar days after the relevant termination decision, merchant notice, or later discovery of a qualifying issue.
A registered service provider may make or implement the termination decision, select or recommend the reason code, and initiate the submission under the acquiring bank’s ICA. The bank remains responsible to Mastercard for the accuracy of the entry.
Termination alone does not justify a listing. A contractual right to terminate the account is not a substitute for a factual basis supporting the selected reason code.
The acquiring bank must provide the merchant with the assigned reason code and the ICA under which the entry was made. It must answer questions about the listing within seven calendar days and respond to a removal request within 30 calendar days.
The MATCH record may identify only the acquiring bank even when a registered service provider made or implemented the underlying decision. A correction or removal request may therefore need to reach both the bank responsible for the entry and the service provider that selected the reason code or initiated the listing.
Grounds for Challenging a MATCH Entry
A challenge begins with the assigned reason code. The facts known when the merchant relationship ended must support that code. It is not enough that the merchant was considered risky or that the account could be terminated.
A merchant may be added to MATCH for excessive chargebacks only when, over the preceding three months, its aggregate Mastercard chargebacks exceed 1.5 percent of its Mastercard sales transactions and total at least $5,000. Chargebacks alone, or placement in a monitoring program, do not satisfy the standard. Both thresholds must be met.
Other reason codes require different factual showings. A generalized concern about risk does not by itself support a MATCH listing.
Materials bearing on the listing may include the termination notice, merchant agreement, chargeback and fraud data, card-brand communications, underwriting records, account settings, and communications between the acquiring bank and its registered service providers. Those materials should show who made the termination and listing decisions, what information was considered, and why the selected reason code was believed to apply.
When Removal May Be Available
MATCH entries remain in the system for five years. Removal generally requires the Authorized User that made the entry to report that the merchant was added in error. Mastercard also permits removal of certain PCI-related entries after the merchant establishes compliance.
Mastercard does not adjudicate the assigned reason code through a merchant-facing appeal process. A removal request should be directed to the reporting acquiring bank and, when applicable, the registered service provider that selected the reason code or initiated the submission.
Removal may turn on objective criteria. Rome LLP has obtained removal of MATCH entries for excessive chargebacks and excessive fraud where the merchant’s chargeback or fraud data did not meet the applicable thresholds.
Other matters require a closer review of how the conduct was characterized. Rome LLP has obtained removal of violations-of-standards listings based on descriptor settings approved by the ISO and gateway, as well as listings that attributed an operational error by the acquiring bank or its service provider to the merchant. The firm has also obtained removal of fraud listings arising from terminations based only on reputational concerns. In each matter, the question is whether the contemporaneous facts supported the reason code assigned.
Effects on Owners and Related Businesses
MATCH Pro includes information about the merchant and its principal owners. A listing may therefore appear when an owner applies for processing through another company. Shared addresses, websites, contact information, tax information, or common ownership can also produce a possible match.
The effects may continue after a merchant is initially approved. MATCH Pro can generate a retroactive alert if another acquiring bank later reports the merchant or principal within 365 days after the original inquiry. The alert is displayed for 30 days and can prompt review of an existing account.
A possible MATCH result does not automatically bar approval. Depending on the program, a registered service provider may evaluate the result under the bank’s credit policy, or the application may require direct bank approval. Many acquiring banks nevertheless decline merchants with confirmed MATCH entries. Merchants approved despite a confirmed MATCH entry may also face higher processing costs, larger reserves, or other enhanced risk controls.
When a MATCH entry follows termination of the merchant account, related reserve and settlement-fund issues may also require attention.
MATCH Removal Representation
Rome LLP evaluates the assigned reason code against Mastercard’s standard and the record existing when the merchant relationship ended. We identify who made or implemented the listing decision and direct correction and removal requests to the reporting acquiring bank and any registered service provider involved.
The representation may also address related companies, principals, pending merchant applications, and existing processing relationships affected by the entry.
