A Recurly blog article “How Recurly is Supporting Visa’s Stored Credential Framework” has some misinformation. The cited dates are incorrect and merchant responsibilities are understated. Why is that important? Most payment gateways and technology solution providers are not keeping up with the rapid pace of rules and compliance changes, impacting merchant profits and risk. Therefore, payment technology vendor selection, including payment gateway selection, is critical.
Recurly, like others in the cloud solutions space, is partially dependent on their partners to keep their clients in compliance with a myriad of rules. When should technology partners alert their integrated solutions partners about industry changes affecting their mutual clients? Solutions providers and merchants are getting inaccurate advice, or none at all, from trusted advisors, technology providers, and consultants of all sizes and sources.
“Visa Core Rules and Visa Product and Service Rules rules, citing changes coming in April and October 2017. On April 27, 2017 Visa published further information for merchants via the Stored Credential Framework document, which also references prior articles published on the subject dating back to 2016.” The real dates were much earlier than cited. Visa typically announces at least one year in advance of due dates for any significant change, which this update is. Updates were in the October 2016
For most merchants, the mandate went into effect October 14, 2017, not April 2018, however, Visa did announce a delay in compliance action to April 2018.
From Recurly, “There is no action needed from our customers.” While technology solutions and payment gateways manage technical aspects for compliance, there’s much that’s left to merchants. Here’s an excerpt from the Stored Credential Framework document:
Merchants and their third-party agents, payment facilitators, or stored digital wallet operators that offer cardholders the opportunity to store their credentials on file must:
• Disclose to cardholders how those credentials will be used.
• Obtain cardholders’ consent to store the credentials.
• Inform the issuer via a transaction that payment credentials are now stored on file.
• Identify transactions with appropriate indicators when using stored credentials.
I strongly recommend reading Visa Core Rules Table 5-20: Requirements for Prepayments and Transactions Using Stored Credentials and Disclosure to Cardholder and Cardholder Consent. For example, how will you provide proof of cardholder consent (think time and date stamp) upon request? Are you providing the required receipt with proper format for zero dollars when storing a card without running a transaction?
Note: This article is not a review, endorsement or complaint about the quality of Recurly services which I have never used. It is simply identifying errors and omissions related to the stored credential mandate that may impact merchant profits, risk and decision making. I would have written in their blog comments, but it wasn’t available. When choosing a payment gateway, consider how agile they’ve been in meeting deadlines for changes, and how they’ll help reduce compliance burden, among other factors.
Christine Speedy, CenPOS Authorized Reseller, 954-942-0483 is a PCI Council QIR certified professional based out of South Florida, near Fort Lauderdale, and Rochester, NY, with extensive payment gateway experience. Christine can uniquely help merchants and technology providers navigate the complexities of PCI, acquirer, and card brand compliance rules.