One thing that’s always been a constant in payments is fraud. For as long as the card networks have existed, they’ve had to manage fraud risk carefully to maintain the integrity of the overall system. Over the years, networks like Visa and Mastercard have developed a range of monitoring programs designed to identify merchants with elevated fraud and dispute activity.

These programs have evolved steadily over the years with different thresholds, different metrics, and different approaches to enforcement. But at their core, they’ve all been trying to answer the same question. When does a merchant, or even an entire portfolio of merchants, pose too much risk to the ecosystem?

As monitoring programs evolve and new models like agentic commerce are beginning to emerge, new questions are raised about how transactions are initiated, how fraud is detected, and how responsibility is assigned across the ecosystem.

In this episode, Chris Uriarte welcomes Keith Briscoe, VP, Advocacy and Education at the Merchant Risk Council, and Allan Shearer, Executive Director, Head of TMT Relationship Management at J.P. Morgan, to focus on the evolution of card network fraud monitoring programs, and in particular, VAMP, Visa’s Acquirer Monitoring Program, which combines fraud and dispute metrics to better manage risk at both merchant and acquirer levels. Listen in as the group discusses industry reactions, data transparency and reporting challenges, and implications for enforcement of new thresholds.

 

 

 

Episode Transcript

Chris Uriarte: Welcome to Payments on Fire. I’m Chris Uriarte, a partner at Glenbrook, and I’m glad to have you with us today. But before we get into today’s episode, I’ve got an important note for our listeners here in the payments industry. On May 19th and May 20th, we’ll be running the virtual version of our Advanced Payments workshop.

It’s a live virtual session that focuses on significant industry trends that are shaping the future of payment. So if you made a commitment to your professional development in 2026, this is a great way to get smart about the payments industry. Just head to our website, glenbrook.com, register before April 19th, and you’re gonna get a 10% discount. So we hope to see you there.

But for today’s episode, we focus back on one thing that’s always been a constant in payments and that is fraud. And for as long as the card networks have existed, they’ve had to manage fraud risk carefully to maintain the integrity of the overall system. Over the years, networks like Visa and Mastercard have developed a range of monitoring programs designed to identify merchants with elevated fraud and dispute activity.

These programs have evolved steadily over the years with different thresholds, different metrics, and different approaches to enforcement. But at their core, they’ve all been trying to answer the same question. When does a merchant, or even an entire portfolio of merchants, pose too much risk to the ecosystem?

Historically, those programs have looked at fraud and disputes separately. Fraud was measured one way, disputes another, each with its own thresholds, remediation processes and consequences. Most recently, we started to see that model evolve. Visa has introduced the Visa Acquirer Monitoring Program, or VAMP. And VAMP brings together some of these concepts in new ways and changes how risk is measured across both merchants and acquirers.

At the same time, Mastercard continues to operate its own set of monitoring programs, while making incremental changes around fraud, chargebacks, and merchant risk across the various programs within its own ecosystem. And all of this is happening as the payments landscape itself continues to evolve.

New models like agentic commerce are beginning to emerge, raising new questions about how transactions are initiated, how fraud is detected, and how responsibility is assigned across the ecosystem. So with that as context, today’s episode focuses on the evolution of card network fraud monitoring programs, and in particular, VAMP, Visa’s Acquirer Monitoring Program.

Joining me today for today’s discussion is Keith Briscoe from MRC, the Merchant Risk Council, and Allan Shearer from JP Morgan. Keith, Allan, welcome to Payments on Fire. Good to see you. How are you guys today?

Allan Shearer: Good to see you, Chris. Excited. Having a great day.

Keith Briscoe: Chris, happy to be here as well.

Chris Uriarte: Well, good to have you here. And before we get into the thick of things, let’s talk a little bit about your specific roles and the organizations that you guys represent.

Keith, let’s start with you first. I think anybody, at least in the major geographies around the world, the MRC is growing its footprint substantially, has been in payments for quite a while, is probably familiar with MRC, but why don’t you give our listeners a little bit of background about what MRC does, the role that it plays in the industry, and a little bit about what you do within the organization.

Keith Briscoe: Sure thing. The MRC is the Merchant Risk Council. We’re a global not-for-profit organization focused on payments and fraud prevention. We are focused on three key pillars, which is advocacy, education, and networking. So we host a number of events globally. I’m sure a lot of folks have been to some of those events. Virtual summits, we have a very rich catalog of educational programs now as well.

And we have something called the CPFPP, the Certified Payments and Fraud Prevention Professional Certification, which is something we’ve had for about the last couple of years. And so I think globally we have about 250 people with that certification now. So that’s an expanding area for the MRC as well.

And then kinda lastly, advocacy is a key part of how we work with regulators, the card networks, acquirers like JP Morgan and Allan, to really influence sustainable change across the ecosystem. Our approach would be that we want all parts of the payment value chain represented at the advocacy table because it’s not all about just the regulators, but the impact across the ecosystem.

My specific role is VP of Education and Advocacy, so I oversee all of our content programming, our educational programs, and as we kind of talked about our regulatory and advocacy initiatives.

Chris Uriarte: Great, well, great to have you here. We love MRC here at Glenbrook. Our regular listeners are used to my colleague Bryan doing the intro to this podcast saying that appearance on this podcast does not represent an endorsement by Glenbrook Partners. We very, very highly endorse MRC and Merchant Risk Council. We think every merchant should be a member of MRC, and solution providers get a lot out of it as well.

And Allan, talking about solution providers in the MRC scope, you work for JP Morgan, which I have heard of before, but it’s a very, very big organization with many moving parts. So why don’t you tell us a little bit about the role that you play within the bank.

Allan Shearer: It does. Huge organization, many moving parts, as you said. I sit in the payments division, so JP Morgan Payments. And very specifically within payments division, I am the Head of the Technology, Media and Telecom relationship management sector.

What that really means is I have a team of relationship managers. There’s about 20 of them, span the country, across some of our main hubs, and each of them have a portfolio of clients and their job, I’ve coined a phrase, is to make a very large bank feel like a very small bank. That relationship manager is really the payment consultant for that merchant.

Taking them through optimizations, cost associations, making sure that they are being that full end-to-end payment consultant for them. So I’ve been with the firm about 10 years, and you can tell from the accent, not always from around here. So I started off with the firm in Europe, moved to California about seven years ago, where me and my family live and we love the sun.

Chris Uriarte: Excellent. And I think, just to put this in scope, I think JP Morgan is still by volume, the number one, the largest merchant acquirer on the globe. Is that right?

Allan Shearer: In the US.

Chris Uriarte: In the US. Okay. Okay. So we’ve got multi trillions of dollars worth of volume running through your platforms, I think the last statistic that I read.

Great. So what we like to do usually since you’re both new to Payments on Fire, we kind of have this tradition to get a little bit more of your background to try to figure out how you got into this crazy industry here. So Keith, maybe we’ll start with you. How’d you get into payments?

Keith Briscoe: I, like many in the industry, it certainly wasn’t an initial deliberate choice. I think I was working in the communications and marketing field at the time. This would’ve been 1998. An opportunity became available at a large, and this is an utterly boring kind of category of the industry, but it was a transaction processing, switching, clearing and settlement software provider, which was not at the time the most exciting opportunity for a marketer, given you’re differentiating your product based on transactions per second and things like that that are absolute commodity.

That wasn’t super interesting, but it did lead to a career in payments. And the golden opportunity, I think, was when I started working for Ethoca about, this was in 2013, I think, I joined as Head of Marketing, Chief Marketing Officer and Product Officer for that organization.

And that type of collaboration was just something that lept off the page for a marketer at the time, right? The nature of being able to get in front of a dispute and preventing it through this kind of merchant issuer collaboration, right. So that was a really exciting category to be a part of. And as most people probably know, Ethoca was acquired by Mastercard in 2019.

So that was a gratifying experience to be able to see that through and help grow that business. And that’s ultimately, that kind of gave me a really solid core foundation in fraud and disputes.

Chris Uriarte: Yeah, it’s exciting for this podcast today for sure. Not just in your role as MRC, but you have real life boots on the ground experience in working with merchants. Allan, what was your journey from a wee little lad up in Scotland to today on the west coast of the United States working for JP Morgan?

Allan Shearer: I was born to be in payments, Chris. When a fledgling career in sports was over, I actually went through the traditional banking route. So I did one of the kind of rotational programs at the Royal Bank of Scotland at that time. Got a, just a great foundational learning from a banking landscape.

I was literally a bank teller. I was stamping your utility bills as you were coming in on a Tuesday morning. Went through and done a number of different roles there, through mortgage advice, went through financial planning advice, then went into business banking.

So business banking was my first venture into the payment side of it, when I then started to understand the criticality of merchants and business customers receiving payments, business banking to commercial banking. And it’s something that I say to many people, you’re either in payments for six months or a lifetime. First six months on it, it clicked and I really did enjoy it.

So the Royal Bank of Scotland at that time had a merchant services payments arm called Streamline, moved across to Streamline and Streamline then became Worldpay. So still working in the UK. I was able to be introduced to some great people within the payments ecosystem. Worldpay, at that point in time thought I really knew payments. And I was doing face-to-face retail sales and approval rates were 99% for everyone. There was never any fraud. It was wonderful and I really thought I knew payments.

And moved to JP Morgan, as I said, it’s now about 10 years ago, where I started in the e-commerce space. Primarily from our Dublin office, but I was either Dublin, London, spending a lot of time with the large e-comm clients on the west coast. So that is what’s brought me there.

Chris Uriarte: Well, great to have both of you here today. And today’s episode, we’re really gonna focus on something that I think’s been a long time in the making here, and that’s Visa’s newest fraud monitoring program. And I put that in quotes, new, we’ve been talking about it now for a couple years.

But that’s known as VAMP to most of the industry. And VAMP stands for the Visa Acquirer Monitoring Program. And we’ll get deeper into what we mean by acquirer, what role the acquirer plays here in just a second. But I would say that this has probably been one of the hottest topics in payments if we look back over the last couple years.

Maybe even giving agentic commerce a little bit of run for its money. Agentic commerce is still only about a years long conversation. But we did have a recent informal poll that was done with the MRC payments community. And VAMP still ranked number one as the topic of interest amongst about 150 merchants that responded.

So merchants are still paying attention to this. They’re still very cognizant of some of the key milestones, the dates, the issues, the practical implications associated with it. And we here at Glenbrook get a lot of inquiries from our merchant clients about the implications of VAMP. So we wanted to just do a little bit of a level set today given that there’s some important milestones that have just been enacted in the program and we’ll get deeper into that.

So let’s try to take our listeners a little bit through a journey today. There’s really been a lot of history related to this evolution of VAMP and it’s been challenging for some to really understand where we stand and what the implications are. I’d also like us to talk a little bit today about what some of the larger implications are outside of the Visa world as well, and how others are reacting to these changes.

So perhaps let’s kick us off with a bit of a history lesson, right? And I might start by maybe waxing a little bit philosophical about why these programs really exist in the first place and where they kind of got started. So, we know, we’ve talked on this podcast a lot about trust, the concept of trust in payment systems.

In fact, we did an episode on this just about, I think six or eight weeks ago where we talked about the importance of trust in payments and how trust is really absolutely foundational for any payment system to work. And we know that if fraud really runs outta control in a payment system, it’s users lose trust in the system very quickly and then usually they’d stop using the system as well.

So what we saw some time ago was the card networks come up with the concept of these fraud monitoring programs, which looked at the various fraud rates of merchants. They were measured in different ways. There was different programs between Visa and Mastercard. Those evolved over time. But now these programs have really evolved pretty steadily over the past couple of decades.

But before VAMP, Visa was operating mainly by using two separate monitoring programs. One that looked at fraud, one that looked at disputes. And Keith, I know there’s a long history here and I’m not asking you to bring us through sort of the last 25 years of e-commerce monitoring, but I think it’s good to talk a little bit about where we came from before we got into VAMP.

Could you give us a little bit of color there?

Keith Briscoe: Yeah, and fortunately the AI summary tools are great at helping us kind of walk down memory lane on this front without having to do a lot of digging or bugging my friends like Allan for the bulletins, which of course, as an acquirer he can’t share. But fortunately there are all kinds of organizations that do publish a lot of information about these so we have that information at our disposal.

So, yes, you’re absolutely correct. There were two separate programs. The Visa dispute monitoring program. The Visa fraud monitoring program. The thresholds at that time, just because I think it’s relevant as we start to compare the thresholds and ratios for VAMP as they exist today.

So under VDMP, the dispute monitoring program, the standard level was 100 disputes and 90 basis point. Excessive was 1000 disputes and 180 basis points. And for the fraud monitoring program was a little bit different in construction around actual dollar volume. Standard was 75,000 in fraud volume and 90 basis points, and similarly, excessive was 250,000 and 180 basis points.

There were also kind of early warning levels at that, which were designed to identify merchants who may be trending kind of in a negative direction. So those two were operated independently and in terms of breaching those thresholds and the amount of grace time and so forth, it was a little more forgiving when they were run independently.

Under the VAMP program, it’s not quite as forgiving and some of the ratios are, as we’ll get into it, there is certainly a tightening that is going on around some of the ratios and some of the triggers for entering the program. But I think the feeling obviously was that fraud and disputes are related topics. They’re related examples of a negative customer experience. And so it’s not surprising in any way that I think the networks would want to be maintaining control over these two related, but ultimately different measures. So that’s kind of the history of those two programs.

Chris Uriarte: So I think that’s really interesting. A couple things I’ll pull out just because we’ll sort of compare and contrast as we get deeper into VAMP. Historically is, what you’re saying is fraud was kind of measured in this bucket over here. Disputes were measured in another bucket over here and kind of like never the two shall meet, right? They were assessed independently. And also as you had said, when we were looking at fraud, we were looking at sort of aggregate dollar volume, if you will, of fraud. Where disputes, we were looking at the number of disputes, right.

Keith Briscoe: Yeah. And I think, Chris, just to mention too, it’s really important to note here as well that it is important to measure both because there are cases where obviously a dispute does not necessarily have a matching fraud record. That would presuppose that all fraud is being reported consistently, and we know that generally that’s not the case.

And then on the flip side, there is TC40 reporting and records that, for whatever reason, low dollar value, et cetera, will not result in a chargeback or dispute. It’s a really important distinction to understand that the best way to have a holistic view of that is to look at both fraud and disputes.

Chris Uriarte: That makes sense.

Allan Shearer: I was gonna say, I remember early, early in my fraud days, someone explaining to me not all disputes are fraud, and not all frauds are disputes. Like, it’s such a simple statement, but it’s definitely something that’s lived with me the entire way through this career.

Keith Briscoe: Absolutely.

Chris Uriarte: That is a simple statement. That’s a good one. I feel like that’s something that should be printed out on the poster and put in every merchant or every fraud jobs office.

Allan Shearer: Go back to Mr. Colm Monaghan in Dublin to see if he trademarked that or not.

Chris Uriarte: Very good. From an acquirer’s perspective, Allan, historically, how have these programs been working? I mean, had they been effective? Were there challenges in those programs? What’s kind of your view about this historically?

Allan Shearer: Yeah. And we can kinda separate out some different parts of that question. How have they been working? Generally speaking, and I’m talking on behalf of all acquirers, PSPs, et cetera, but generally speaking, it was pretty much a pass through element. We’ll have a notification comes down from the brands, your merchant has triggered X, we’ll validate some of those data points.

We’ll work with the merchant, we’ll work with a plan to say, right, okay, how did this happen? Is this a flare up? Is this an underlying problem that sits within your system that we have to try and help address with either products or just more attention to it? So that’s how they’ve been working.

Were they effective? I think the answer is, if they were effective, we wouldn’t be here with VAMP, okay. Largely the previous programs, I would define them as a deterrent, right? They’re a deterrent. Please don’t do this bad behavior. If said bad behavior happens, first of all, it’ll be a monetary fine, and then there’s risk of being closed off and shutout.

So I was on stage with Keith last week and I started off by saying what was a controversial statement to say, Visa are trying to do good here. And it was very controversial. As I’m having all these eyes, and I’m saying as an ecosystem, as a consumer, as an acquirer, as a merchant, we still have elevated levels of fraud in our ecosystem.

If the previous programs was effectively working, we would’ve eradicated that fraud. The trend actually is fraud. Now, there’s a number of reasons. The rise of AI, used to be that fraudsters used to have to be very, very smart and have very bad intent. But the rise of AI, they actually only now need bad intent.

So as the world continues to evolve, fraud is still a problem. Visa are trying to change the program, and we’re gonna go into this in a little bit further and give more responsibilities to more parties in that ecosystem, and also trying to put some more products and elements around the ecosystem, not just to be the deterrent as the previous programs were.

Chris Uriarte: I think you raise an interesting point is that you have to kind of look at the current state of fraud to begin with, right? When you think about why we need to evolve these programs, because even though merchants and service providers and technology that merchants are using continues to evolve and get better and get stronger, the rates of fraud across the globe are still really, really high.

We see the Nielsen Report report their end of year fraud findings every year at the end of December. And fraud did tick down globally a couple of basis points, but we’re still significantly higher, almost two percentage points from where we were 10 or 15 years ago.

And I think that reflects kind of what you were saying is that it’s a different ball game now, right? As fraudsters are able to execute at a level of scale, a level of sophistication and a level of effectiveness that we haven’t seen before. And as we always say, we’re always trying to catch up, right? The fraudsters are always two steps ahead.

So I think evolution in these programs is necessary because really the world of fraud around us is evolving every single day, right?

Allan Shearer: Like I said, it was my first controversial statement. I got the room around, Keith agreed with me, and we got the room around the same topic.

Keith Briscoe: A hundred percent. I think the other thing that has to be acknowledged here too is the distinction between first and third party fraud, right? We know all too well that the reason why many merchants will trip into these compliance programs is the nature of the transaction volume and the categories in which they operate. With the prevalence of first party misuse and friendly fraud, it’s really important to monitor these.

But also, in the discussion around VAMP, we’ll obviously talk around the surrounding tools that can help better categorize some of that volume, right? It’s certainly not just that legitimate fraudsters have become more effective at their game. We’ve also trained the consumer how to actually successfully dispute transactions fraudulently, right? And that is contributing significantly to this challenge.

Chris Uriarte: And it’s easy for consumers, right? Consumers, if they’re unhappy, it takes about three minutes for a consumer to go into an app to dispute it. And then they’re sort of done. They’ll worry about it later. They figure their issuer’s gonna take care of it. So there’s a lot of factors working here.

So let’s fast forward a little bit from the historical programs to, I think it was probably around early 2024, Visa now announces this new thing called VAMP, right? And VAMP, I think, had a couple of different intentions, but I think mechanically what it’s focused on doing is replacing those historical VFMP and VDMP, those separate dispute and fraud programs into a single program, right.

And we will talk about also monitoring the levels at a single metric, we’ll talk about in a moment. I think also if I’m right, it wasn’t as simple as just having like a VFMP and a VDMP program, is Visa kind of had all these separate different little programs and rules in different parts of the world as well.

Sometimes there were exceptions to them or specific regional programs. So I think this is just looking to clean things up. So before we kind of get into the dirty details about the formula and the calculations that go into VAMP, Keith, maybe you could bring us through some of just the very basics around VAMP to get us started. I think that would be helpful.

Keith Briscoe: Yeah, I think we’ll have to kind of talk about some of the history here on the first iteration of VAMP, right, for this to kind of make sense fully. I think the thing when it was first introduced that was somewhat puzzling to people, it was certainly a little bit puzzling to me was the actual construction of the calculation, right?

So it was TC40 plus non-fraud disputes divided by overall sales, right? So there was no actual element in that metric for fraud disputes, right? The TC40’s were effectively a proxy for the related impact of the fraudulent disputes. And for a program that is supposed to be combining fraud and disputes into a single program, not having an element in there for fraud disputes was interesting, right? That was an interesting decision.

And at that time, when it was first announced, I think as we know, there were exclusions provided through the Visa tool set, both compelling evidence 3.0, RDR and CDRN. So then that begged the whole question of the construction of the program and the nature of how agnostic it was, right, in the sense that I think as a card network level program, a merchant should have the choice of which tools to use to potentially make a successful impact against that level of fraud and disputes.

Chris Uriarte: Let me pause you just there for a bit because there might be some of our listeners that aren’t familiar with some of these key things that you’re talking about. And in fact, I find even folks that have been really well steeped in payments for years don’t really understand the difference between what a TC40 is and a TC15 is.

And I throw those terms out all the time, and I find about 50% of the time I throw them out without explaining them. And people say, what are you talking about? So let’s start there. Like, what is a TC40 and what is a TC15?

Keith Briscoe: A TC40 is the reported fraud record.

Chris Uriarte: Yep.

Keith Briscoe: Right. And a TC15 is a non-fraud-

Chris Uriarte: Hasn’t been confirmed yet for fraud, right. So disputes would fall more in that TC15 bucket and TC40 is confirmed fraud. So I think merchants are getting these reports and these are essentially the key metrics.

Keith Briscoe: Well, in some cases they’re getting the reports, TC40 reporting has long been kind of controversial in terms of its access and its ease of consumption, all those things. So theoretically, yeah, the merchant can get access to it.

Chris Uriarte: Okay. Sorry to cut you off there. I just wanted to set that record straight.

Keith Briscoe: Yeah. Absolutely. And that’s an important distinction, I think, especially as we’ll discuss the evolution of the program, right. Suffice to say there were a number of, and this is when we effectively began our consultation with Visa as MRC and advocacy kind of organization, right? Which was around the construction of the program, some of these challenges.

The fact that in terms of navigating the competitive environment, I think we would all agree that a merchant, like we were saying, should have some choice over what tool set to use. So I think at that point, because it was primarily based on TC40, they were going to effectively match those to those dispute prevention records to take it out of the numerator, right?

But if there’s not an opportunity to also address the competitive product set, which was the Ethoca product set, right, that has direct integrations into Visa card issuers and covers those transactions. But underneath the initial set of exclusions, achieving those deflections and those prevented disputes out of the competitive tool set would not allow you to make a successful reduction in your overall ratio.

So it was really important, I think, that we address that competitive dimension as well because I think we would all agree that, and this is something I’m really passionate about, merchants should have choice when it comes to a network level compliance program, what tools they can use to successfully reduce that level of essentially breaching the threshold.

Chris Uriarte: So let me try to break this down for our listeners maybe that haven’t been following this over the last year or so. So what we’re saying is that now as part of this VAMP program, what we’re looking at is a combination of the amount of disputes that we get and the amount of confirmed chargebacks that we get.

We put them together, right? And we kind of look at the counts associated with both of those. And that is essentially the basis where we get started in trying to figure out whether we’re above a threshold or not. If we look at the actual formula, right, it’s the amount of disputes plus the amount of confirmed fraud divided by the total amount of transactions.

But what you’ve also brought up is there’s a way to kind of reduce that amount in the numerator, and that’s by using some of these deflection tools like Visa’s Verify, or Mastercard’s Ethoca as well. So it’s possible that a merchant could reduce that count that’s in the numerator if they’re using those tools and are able to deflect those disputes sort of before they become a chargeback.

Is that right?

Keith Briscoe: Yeah, that’s absolutely correct.

Chris Uriarte: Okay. Cool. And Allan, from an acquirer perspective, right, this isn’t just about looking at merchant VAMP levels, let’s just say, I’ll use that term. The VAMP ratio is really the technical term I think that Visa uses. It’s not just about that ratio in the merchant world.

This is also being looked at the acquirer level. Is that right?

Allan Shearer: Correct. Yes. Goes back to what I was saying earlier in terms of how the previous programs were. Sometimes we’re just kinda passing through, where we’re the steward of that message coming down from the network. What the new program has done is it’s brought some of the actual onus onto that acquirer as well.

So it’s trying to engage them and have them take some ownership and responsibility over that entire fraud and disputes ecosystem. Now where that has been beneficial is it makes the, like I said, the acquirer, the PSP, it makes them be involved in some of those conversations. I’d said before, we would discuss with the merchant, okay, is this a flare up? Do we need to embed something deeper?

A PSP and and an acquirer now has to be holistically looking at their overall portfolio. I’m not just saying this and I’m not speaking on behalf of JP Morgan here. It’s, again, it’s on behalf of that kinda PSP ecosystem. They’re now having to do things where I’m sure that some of the frontline sales staff are now actually asking some new merchant prospects what their current ratios are, because your ratio is the collection of your entire portfolio.

So PSPs, acquirers will start to be a bit more selective over the exact clients that are sitting inside their world, but also how they’re actually managing that program. They’ll have to be monitoring. So Visa, yes, will monitor and send you some details when a client and a merchant has qualified for some of these programs.

But also the work has had to be done by these acquirers to start monitoring them on their own. Because once someone has been alerted, you’re already too late, you really need to understand where this is trending. Is it moving towards something? Is there affirmative action that you actually have to take?

And like I said, there’s a number of different acquirers and PSPs that have to address this in a very different way. I’ve said PSPs because, very specifically, this is the acquirer level. So VAMP is at acquirer level. You may also be a PSP that has an underlying two, three, or four different acquirers. So not only are you managing your merchant, your downstream merchant, and their levels that they are trending towards, you’re also going up the way and dealing with those partners in terms of understanding your three or four different underlying acquiring partners that each have their own VAMP thresholds.

And depending on where their thresholds sit, it can absolutely change the actions and financial penalties to the underlying merchant.

Chris Uriarte: So that’s really interesting. Let me break down a couple things that both of you had said here. So, the first thing is Visa is essentially just fundamentally changing the game here in a couple of different ways. So Allan, I think one of the things that you said about the historical programs is that they were really more of a pass through, if you will.

Visa was monitoring, they sort of sent a message down to the acquirers saying, Hey, this merchant is a troublemaker. You need to do something about it. But this is a little different here, right? This is essentially saying that you, the acquirer, have a little bit more skin in the game, if you will, when it comes to monitoring levels of fraud at the portfolio level, right?

So that’s a very different thing, fundamentally.

Allan Shearer: Yeah, totally different. It’s ironically something that, financial institutions will have been very aware of, and they’ll have been monitoring, there is now a program around it. So depending on where certain acquirers were before, they may have to change. Some may have already actually had that methodology, that mindset into how they’ve been managing their overall risk as it pertains to them being part of a financial ecosystem.

So yes, everyone has had to change, just depending on what they were doing before is depending on the level of adaptation that they’ll have had to do with this new program.

Chris Uriarte: Okay. And Keith, we’ve been talking now about this ratio, this formula. But now let’s get into the nuts and bolts of this, right? What actually makes up the formula?

Where have we been with that and where have we landed here in April 2026? What is it actually measuring? How is it actually being calculated?

Keith Briscoe: Okay, so let’s cast our mind back to the original bulletin that came out, I think, in 2024. And at that time, there are two distinct parts of that overall formula. There’s the acquirer portfolio and then there’s the individual merchant excessive ratios, right? So at the acquirer level, so the original threshold, effective 1st January, 2026 announced at the time was to be for the VAMP ratio above standard between 30 and 50 basis points at the acquirer level. And excessive was greater than 50 basis points.

On the merchant side, for the initial threshold, effective 1st April, 2025, it was to be in excess of 50 basis points. And then threshold effective Jan 1 20 26, also higher than 50 basis points. On the merchant side, the numbers were 150 basis points initially, and then to be reset to 90 basis points 1 January, 2026.

So that was the initial construction. And as I think we’ve noted the numerator at that time, was TC15 plus TC40?

Chris Uriarte: So the industry wasn’t happy with that. I’ll just put it to you that way initially. So that’s how it was initially proposed. How did we evolve to where we are now and where did we eventually land?

Keith Briscoe: So eventually after, I mean, and I’m sure Visa heard obviously from many corners, the acquirers, many in the payments processing industry, right, around some of the potential challenges with that calculation. I think the first thing we noted was because the fraud disputes were not included in the numerator as a combined program, I think there was a key dimension of the numerator missing.

And I think Visa’s acknowledged this and in looking at the potential friction that both a fraud and dispute create because they are different events, both should ultimately be included in a more holistic program. So I think once I think Visa got comfortable with that, then the decision had to be made, while there is this perception of potential double counting, given you’ve got both a fraud record and a dispute in the numerator.

So as a result, the ratios needed to be adjusted. So that brings us to the current formula for VAMP and let me just have a look at that. So the current formula for VAMP with both fraud disputes and the fraud records and the numerator is greater than 50 basis points is above standard at the acquirer level, and greater than 70 basis points is excessive at the acquirer level.

So to accommodate the fact that we’ve now got more volume in the numerator, Visa has adjusted the acquirer level thresholds accordingly. So one of the big questions is, are these adjusted sufficiently? That’s an open question I think that we still need an answer on. I think time will tell, I think is the answer on that one.

And then at the merchant specific level, it is 220 basis points currently, but it is going to be going down to 150 basis points come April 1st of this year, I believe.

Chris Uriarte: Right. So we’re recording this for our listeners just right at the cusp of April 1st. So I think we’ve got some merchants that are on the edge of their seats to see whether Visa’s gonna start enforcing this or not. But the rules say that that excessive threshold is going down from 220 basis points to, I think you said, 150 basis points, right, on the merchant level.

So that’s a pretty significant change. But we’ve had this ramp up period now for the last year. So Allan, as Keith had said, we’ve got a different threshold level at the acquirer level, so you as an acquirer essentially need to be monitoring both your portfolio at your acquirer level thresholds plus your merchant specific thresholds as well on an individual merchant basis. Is that right?

Allan Shearer: Correct. Keith did a great job of like going through, there was a lot of basis points that we were going through there. The acquirer levels won’t be changing as of this April 1st. So yes, like you said, it’s 50 basis points in that standard and 70 basis points in that excessive threshold.

So you’ll notice that is much lower for the acquirer than it is for the actual merchant program. That in a way is, once again, to make sure that an acquirer has some responsibility within there if they’re spreading that risk across that portfolio. That’s why they are like, barrier of entry is a much lower barrier of entry at that point.

There’s a number of things that Keith just went through in terms of what has been added to what has changed. The ratios and the thresholds that they have to monitor, they have to be very close to it because the key thing here is it’s the financial penalties that are associated with each of those, and those penalties are different in each of those buckets.

If we talk about from a merchant standpoint, merchant will click that fee. If we talk about it at the acquirer level, the acquirer, say for example, their portfolio gets to that 51 basis points. So they click into that standard. That means that that fee will be assessed to the acquirer and it’ll be assessed to the acquirer for every single merchant that is within that threshold.

So every single merchant that is over that 50 basis points, so almost like resets the merchant level requirements from Visa, because if JP Morgan, for example, went to 51 basis points, Allan Shearer does not receive a fine for every single merchant in our portfolio. The fines are assessed to those merchants that have effectively driven your VAMP ratio into that bucket.

So the key thing at the acquirer levels, it’s ensuring that you understand when those financial penalties would come, because that’s when your qualification for any of those programs change materially.

Chris Uriarte: Okay. So a lot more complexity here in monitoring these thresholds than in the previous world. On that, I wanna transition a little bit more toward the practical aspects of what’s happening now after this has been implemented and trying to get a sense of what you guys are hearing out there in the market.

So, just to kind of reset, right, if I’m a merchant, I need to now holistically look at both disputes and fraud rates together, right? So I’ve got a lot of new variables compared to the old world, right? So the old programs used to look at these things separately, disputes and fraud separately, like we talked about.

But now this is different, right? So if I have high counts in one area, disputes, for example, but low counts in another area of fraud, the other area that we’re looking at, this could still tip the scales past the threshold, right? Very different than what we saw in the previous world. So I’m curious, what are you guys hearing out there in the industry?

We have heard some limited stories. I’m not gonna say that this is a major, major issue, but we have heard stories from some merchants who were in compliance in the previous programs. They were fine, but now they’re out of compliance or close to being out of compliance in the VAMP world, right?

What have you guys been hearing, Allan, very curious to hear from your acquirer perspective on this.

Allan Shearer: And we’ve seen both. We’ve seen both, but we’re able to also, when Visa gives us information, we also had a monitoring period where the program was live, where we started to monitor at different individual merchant levels. So we were able to forecast, yes, this merchant was good in this one versus bad in the next one. They’ve stayed consistent with how Visa will actually monitor, which is down at the descriptor level.

So they stayed very consistent with that part. So whilst it’s very complex, if you put together the structure to be able to monitor it, as long as you put that hard work in at the start, you are able to go through a pretty effective monitoring process. And what I’ll also say is some of the early parts, we’ve had conversations with Visa very specifically for very specific merchants, and part of that is ensuring that our data aligns.

Whilst I will monitor a merchant, that merchant may also be acquiring with four different acquirers. So there is always additional data points, there’s always additional conversations to be had to ensure data is aligning correctly. We’ve got the correct descriptors, we’ve got the correct underlying MIDs, all of those parts, don’t just take it on face value as such, you have to respectfully question to ensure that we are talking about the correct thing.

That I would say is from the early parts in one of my senior relationship managers, guy Chris Bucceri, actually presented at MRC and the title of his presentation was “VAMP is Live, now What?” Because as you said at the start, Chris, we’ve been talking about this for so long, it now is live. Some people still need some information, but they also have to adapt how they’re now monitoring some of those parts.

Chris Uriarte: Those are some great points. So we’re gonna circle back to dig into a few of those in a moment. But Keith, I’m just curious, what are you guys hearing from an industry perspective at MRC? What’s the fallout been? Has it been as big of impact as we thought it might be? What’s the general perception here?

Keith Briscoe: Well, it’s still early days, so I think we’re still tracking that. The one thing I am surprised by, and I’ll give you a couple of anecdotes from the recent MRC that wrapped last week, all of the ask me anything sessions and the Visa question and answer periods we’ve had on that, I typically do ask for a show of hands around people’s familiarity with the program.

And I still am somewhat shocked at those who are expressing either zero familiarity with VAMP or just a moderate level of familiarity with VAMP. The needle is moving. It’s changing. I think, as the industry, we are, because we’ve talked about it so much for sure, we’re beginning to cover the bases and more merchants are hearing about it, which I think is the important thing, but still there is education to do yet.

The other thing we heard was, I asked the question in our VAMP session last week around, have any merchants actually lost processing as a result of that? And there were a couple of merchants, and again, this is something that merchants may or may not be comfortable disclosing in a group setting, right.

But there were certainly a couple of merchants who did express that on a couple of small MIDs, they lost some processing and that’s not shocking, I don’t think, depending on the nature of the merchant of the category they operated in, right. And of course, merchants do undertake this sort of load balancing exercise depending on the current thresholds, they may trip with acquirer A versus B versus C.

So it does take a while for all that volume to normalize and merchants do have choice around where to put that volume, right. So I don’t think those will be long lasting effects necessarily, but I think we will see a little bit of this churn in the early days while processing relationships get stabilized and some of that is done.

Chris Uriarte: It does demonstrate though that the program is very much live. The wheels are turning, it’s working, and both Visa and acquirers are playing by the rules on this, even if it’s small examples. So I think that’s quite interesting. I think the big question that I hear from a lot of folks in the fraud prevention space in particular on the merchant side, first of all, it’s just this general, I would say, why, why are you doing this to me? I think was sort of an initial reaction to this.

Which really leads to a bigger question of what is really driving the change here, right? What really is Visa trying to do? What behavior are they trying to incentivize? To me, this is Visa essentially saying that we’re now kind of leveling the playing field a little bit in a few ways, right?

Disputes are essentially as important as confirmed fraud cases, and a fraud case that costs $1 is essentially just as important as a fraud case that is worth thousands of dollars. So essentially telling merchants, Hey, you have to get your act together, right? You need to stop small value fraud as effectively as you need to stop high value transactions, and you need to ensure that things like your business practices, your products and services, your refund policies, your customer service and all that sort of stuff is really tightened up because those bad experiences often lead to disputes.

And disputes are gonna hurt you as much as confirmed fraud is gonna hurt you in this program, right. So I mean, is Visa really trying to like regulate the customer experience here and go beyond fraud? Am I reading too deep into this? Allan? I know you’ve got a interesting view on this. I’m curious to see what your thoughts are here.

Allan Shearer: And I’ve been part of all of the talks. I’ve heard the same thing in terms of the view of they are trying to like level that playing field, as you said, Chris. I think they’ve done something else, and I don’t necessarily disagree, but I actually think they’re putting more onus upon fraud right.

And if we think about us as consumers, the fact that a TC40 is being logged, and Chris, you got new glasses, didn’t like them, and or it was fraud, right? There’s TC40 there for a hundred dollars and then there’s a dispute there for a hundred dollars. That double counting does happen, in my view.

I don’t necessarily think it’s a bad thing because I think what Visa are saying is from a consumer impact, I think a fraudulent transaction and a fraudulent dispute is much more harmful to a consumer than, for example, I didn’t like the color of said glasses, and I’m going to dispute the payments of it.

I do think that they affect us as consumers differently. So I do believe that Visa has a higher weighting on that fraud part. They think it’s a level playing field. I actually think it’s more weighted towards fraud. I don’t also think that that’s necessarily a bad thing because fraud is probably, and again, if we look at all of the disputes where those dispute sits, fraud still sits as the major disputing factor rather than dissatisfaction, et cetera, et cetera.

So tackling that, I think is, if we rank the priority as number one, and I do believe there’s a heavier weight on that because of that.

Chris Uriarte: That’s very interesting. Keith, what’s your view and MRC’s view on this as some sort of the motivations here?

Keith Briscoe: Yeah, absolutely. I mean, I think you made the comment that is, is Visa starting to regulate customer experience? And in a way, right, I mean, the reality is that by combining these measurements and by tightening up some of the ratios. It does put more scrutiny on where the transaction volume comes from and the merchant practices around ensuring a good consumer experience, right?

So in looking at that, merchants that operate in certain categories that may be following certain practices, right? Not all good transaction volume is good, effectively, right. There are potential consequences and friction points that come with that. So in the case of something that may result in consumer dissatisfaction or a case where a consumer falsely disputes the transaction, there’re being reported as fraud, but we know that’s not the accurate reason for the dispute, right?

So you do get a lot of this reporting that goes on that really should be in a different type of bucket, should be in a non fraud dispute bucket, but gets reported as fraud, because that’s the path of least resistance for the consumer. I do think Visa is definitely stepping into the waters of regulating the consumer experience here and in concert with that, we’ve talked about some of the tools.

Tools like Compelling Evidence 3.0 are designed to retrain some of the consumer behavior that is driving up those ratios. So in many ways, absolutely. I think that is part of the rationale is to tackle both parts of it, begin to address some of the elevated fraud and dispute counts that come from those experiences, but give us an opportunity as an industry to hopefully reshape the way consumers behave in those situations.

Allan Shearer: And Chris, I might just give you a teaser for potentially one of your next podcasts. Everything Keith said there. Completely agree with. Now when we’re talking about regulating that consumer experience, and I don’t think it’s regulating a bit, ensuring the correct controls are there, the majority of merchants that I’m having either early or advanced conversations about the agentic world, that consumer experience within the agentic world going through there, do they, are they getting the same terms and conditions?

Are they getting all the bits and pieces? That’s something for anyone that’s listening to it, and I’m sure, like I said, you’ll be going into it in further detail in further podcasts that consumer experience and how these programs fit into that. It’s a very important part of your agentic journey and any merchant listening to it. Make sure that you’ve got that in mind when you’re thinking about it.

Chris Uriarte: Absolutely. Well, you don’t have to have a crystal ball, Allan, to know that we’re gonna be talking a lot about agentic on our agenda-

Allan Shearer: it was a safe assumption.

Chris Uriarte: -here on Payments on Fire. Safe assumption. Of course. I wanna do a couple quick hits with you guys though to talk about some of the kind of practical implications that we’ve seen over the last year or so.

And these are very common questions that we’ve been hearing from folks across the industry. Some of these we’ve talked about a little bit, but I want to get a little bit deeper into it. So the first question is, Allan, I’ll throw this at you. How does an acquirer monitor merchants who are processing across different MIDs?

You had said that this is, the monitoring is focused mostly on descriptor, right? That’s kind of the key. Can you just explain that a little bit more?

Allan Shearer: Exactly. Yeah. So Visa and Mastercard, similar programs, like everything we do in this ecosystem, they’re similar but not the same.

Mastercard will have their programs and will be at the MID level, so you can have the exact same transaction, but across two separate MIDs. Quite often that will be currency related, and those MIDs will have their own ratios, that will have their own alerting and programs. Visa go down the descriptor route. So you can have a number of MIDs, but if you’re selling almost like the same product as such, that same line of business from the merchant, it’s the descriptor that is denominator that is used for it.

So that means that yes, you may have MID doing first time transactions, a MID doing your recurring transactions. You may have separated out from a functionality and, like you said, a tactical reason. But we will track it and Visa will track it at that descriptor level. So when it is Chris star Glenbrook partners, that’s the trigger point for those programs.

Chris Uriarte: Okay. That’s a very common question, so thanks for clarifying that. The second one I’ll also throw at you, Allan, is related to this differentiation between acquirer thresholds and merchant thresholds, right? How are acquirers really handling this as you get closer to your own thresholds, right? Do you start putting pressure on higher fraud merchants, even though those merchants still might be way below the merchant specific thresholds?

I think that’s a concern that a lot of merchants are asking is, is my acquirer gonna be coming at me just because they’re close to their portfolio threshold, but me as a merchant, I might be far away from the merchant threshold. I understand this policy is gonna change, is gonna be drastically different from acquirer to acquirer, but what are you seeing out there and how are you guys handling this?

Allan Shearer: It is gonna be, like you said, drastically different. And I’ll speak more in general terms across the acquiring landscape. I’ll go back to a previous statement. I said, there are already a number of acquirers that operate in a manner of, they’re trying to protect the sanctitude and the trust of the entire ecosystem.

So they’ve already been working in that type of way of, as a merchant’s fraud starts to increase. They also see that as an increase to theirs, as a merchant, each one of you has a MID, and I like to say that MID has a credit score, right? A credit worthiness. The issuer thinks about you with a credit score.

I love that concept. I have the exact same as an acquirer. I have an acquiring BIN, and whenever an issuing bank sees a transaction coming from me, it has that same effect of how much fraud do I see coming from Acquirer X, from PSP Y. So there are already a number that have been operating in this vein for many, many years, where as merchants start to increase, they do work with them to bring that down.

What you’ve said is, well, there are concerns with some of the merchants out there, they are valid concerns because across the ecosystem. There will be acquirers and PSPs that have fraud rates, that are fraud rates and disputes rates that are very close to those ratios. The reality is the underlying merchant behavior that is pushing that ratio, going up close to and over some of those thresholds.

So yes, I already know of a number of merchants that are having very in depth conversations because they’re either getting close to that threshold and they’re trying to take assertive actions or they’re already talking on like financial penalties associated with it.

When I was on stage with Keith, I actually brought up, there was a couple of quotes that was from Visa’s chief, I think it’s Chief Risk and Customer Service Officer, guy Paul, and he actually start to now discuss some of the early findings that they have had. I think he said almost half. And I’ll give you the details to you can quote in your source. Almost half of the acquirers that they have had enter the VAMP thresholds have actually been able to then exit the VAMP thresholds.

With that exit, their processing volume has increased. Again, I go back to that you have a credit score at an issuer, so the issuers are improving more of their transactions because of that good behavior and the issuers associated with those transactions, their fraud has gone down. So Visa are starting to give some early indications.

We don’t have data associated with it, but very early indications on some of the benefits that has come. But yeah, those benefits will have come from a mixture of spending a lot more time with merchants to bring it down. Some merchants will have been off boarded. Now, again, this is the general ecosystem I’m speaking

Chris Uriarte: Yeah. Yeah. Sure. Well, that’s interesting. Keith, does this resonate with what you’re hearing in the industry? Merchants concerned about these acquirer thresholds, are merchants getting pressure from their acquirers, even though there may be far away from the merchant threshold?

Keith Briscoe: There is certainly concern about it and as we mentioned there, as Allan mentioned, there’s some offboarding that is likely going on, and we have heard from a few merchants who did say they lost processing. It certainly wasn’t a large number of merchants at this point.

But I think one of the other things worthy about what Allan said as well is in looking at the way to maximize the potential revenue opportunity, right? Merchants can take a number of approaches. They can look to acquire risky traffic, right, and play that card. But that’s going to result in obviously the profiling of both the merchant and acquirer level that’s going to result in more issuer declines, right?

Or they can look to potentially clean up the way they acquire volume and traffic, and begin over time to see more acceptance and fewer fraud declines. Kind of two edges of the same sword in a way, right. But one is a much healthier way to achieve, I think, the desired outcomes that comes up much lower friction to the consumer.

And I think Visa is definitely trying to balance all of these impacts to all the players across the ecosystem in a way that’s more productive and fairer.

Chris Uriarte: That’s very interesting. And I wanna ask you one more question about what you’re hearing out there, Keith. We’ve talked about TC40 and TC15 numbers a lot. Those are absolutely critical to these calculations. But we’ve continued to hear some stories about merchants having some challenges at either obtaining those reports themselves, maybe obtaining accurate data, they’re getting abstracted reports from their provider that isn’t maybe a hundred percent matching the TC40 and 15 data and other various challenges like that.

Are we getting better at this at an industry level? Is this still a challenge?

Keith Briscoe: I think it’s still a challenge. I mean, the fact is that there is a commercial product, I believe, that is designed to provide that TC40, right. And I think this is one of those things that in terms of a level playing field and in terms of merchants not having potential blind spots, I would argue this is probably something that should be available widely at no cost.

That might be a somewhat controversial statement, but I think this idea that if we really want to see this change across the industry, something like TC40 should be something every merchant is aware of in order to inform their practices, right. And so this is where we get into some of that difficulty around the trade off of the commercial dimension of some of these tool sets versus what’s in the best interest of the entire industry.

Chris Uriarte: Absolutely. Alright, great. Let’s talk a little bit about looking ahead here. So both of you, just off the plane from Las Vegas at MRC Las Vegas, the flagship event for the Merchant Risk Council. I know there was still a lot of discussion regarding VAMP out there last week. So Keith, can you bring us through any updates that were shared or just in general what the buzz was about this.

Keith Briscoe: I mean, look, in general, I think some of the headlines are really around the level of transparency that merchants have as they’re trending toward kind of the danger zone around breaching VAMP ratios, right? So there certainly are merchants who, I think, feel that they should have better communication from their acquirers on this front. And I think Allan has previously articulated, some of the tools that exist don’t give merchants enough kind of trending warning as they start to approach those thresholds, right?

So there was a lot of commentary, I think, that Visa heard from our merchants around wanting better, more proactive reporting so they could actually understand where they sit. As we know, a lot of merchants operate with service providers like PSPs and with chargeback management companies that can obviously look at exposure across acquirers, right, and give merchants more insight into when they’re starting to trend into dangerous territory.

But I think Visa certainly heard, I think, that there’s a desire for more merchant facing both metrics, information analytics, as well as guidelines. And they did take that away and they indicated that they’d be looking at all of those different alternatives, all those different opportunities, to augment what the acquirers are currently doing.

So I think that was one very strong message that, it’s challenging because that’s typically not what the networks do, they communicate largely by their acquirers. But I think on this front, Visa has certainly heard the message and the frustration from merchants that they do want more of that information.

Chris Uriarte: Well, that’s good to hear. And Allan, between cocktails and meetings and parties and everything else in Las Vegas, what did you hear on this topic?

Allan Shearer: I was shocked, apalled, and put them all in together. But it’s exactly what Keith said and what we said at the start of it as well. The lack of information that some merchants still have on this. We’ve talked a lot about TC15s and TC40s. Keith just said it there. TC15s and TC40s is the bare minimum that you should have, right? That’s a level playing field. You should absolutely have that.

And a big part of my presentation was it all sits upon the cleanness of the data that you will have, the ability to understand that data, and there’s also a part with data which is the so what? Don’t just give me a number. Don’t just send me the file. The, so what part of is, how should I be ingesting this? How should I be looking at it? A lot of the work that we do with merchants is, here’s what I will show you, but also you are multi acquired. You have a number of different regions that we maybe don’t support you in. Here’s what you should be doing collectively to start to build this in yourself.

We really do look at as a point of we’re trying to help them consult to be the best merchant that they can be and be as optimal as they can be. And the big gap is still getting enough data through to the merchants for them to really be able to understand it, be able to track it

Chris Uriarte: It’s all about the data really at the end of the day, which is why I ask you guys this question, why it was absolutely key. I wanna shift a little bit away from Visa. It’s always about Visa, Visa, Visa. It’s like Marcia, Marcia, Marcia. Maybe that doesn’t translate as well for you guys, Keith being a Canadian, Allan being Scottish, but the old Brady Bunch line is Marcia, Marcia, Marcia. It’s always about Marcia. It’s never about Jan.

Well, here we are, we’re always talking about Visa in these sorts of programs, but what about our friends at Mastercard? Usually we have this trend where Visa comes out with a program, they lead with it, and then a year later or so, Mastercard comes up from behind and they introduce their own program here.

But I feel that they’ve been pretty quiet on this. I mean, we’ve seen some tweaks, I think, to their existing programs, but no sort of like major structural changes similar to what we see with VAMP. Is that right? Is anybody aware of anything going on with Mastercard?

Keith Briscoe: I haven’t heard anything material on this front. I mean, I think Mastercard is certainly taking a wait and see kind of approach with how all of this shakes out, right. I think some of the principles that will for sure be adopted and looking at the tool sets, obviously. And one thing we didn’t talk about was upcoming out of CE 3.0, merchants will have the ability to have the benefit of both an eliminated TC40 record, right, if it’s confirmed to be first party misuse as well as the corresponding dispute. And one outstanding question is what then happens to the competitive tool set, right. Mastercard has its own competitive tool set, including the CE 3.0 equivalent first party trust, right. So I think in some of the backbone of some of those programs, Mastercard has its own version. How that’s going to translate into a revised fraud and dispute management program. I haven’t heard anything on that yet.

Allan Shearer: Very similar. Nothing announced. Think they’re in the wait, monitor very closely because the benefit that you get of going second is learn from some of the hiccups in the rollout from the previous. Like, what has worked well, what is not working.

Like I said, Visa has just announced some of the benefits that they are seeing from the early parts of it. So Mastercard should be paying very close attention to that and really highlighting on where’s the good, where’s the bad, where’s the ugly. Again, if you go second, you have an obligation to be bringing the best to it.

Keith Briscoe: This is true.

Chris Uriarte: Well, you know, I always say it’s sort of like Mastercard sometimes takes the Apple or the Steve Jobs approach, which is, you don’t have to be first, right? You could sit back and you could wait, but you just want to be best. Now you could argue whether Mastercard’s been best at this. That’s a whole nother discussion for another day.

But I certainly do think that’s a little bit of their philosophy is, as Keith had said, I think they’re sitting back and waiting to see how this all works out for Visa. And they could go from there. I did wanna finish up today just, because we’re legally required by law to talk about agentic commerce and any of these payments podcasts.

I do want to just very quickly hit on agentic and we don’t have to get deep, too deep into this, but just at the end of the day, do we think that this causes a lot more issues once we start to scale up agentic, right? So I think we’ve got perhaps early in agentic lots and lots of possibilities for disputes to start going through the roof here, right?

I asked the agent to buy this for me. They didn’t buy this, they bought something else, for example. I’m just gonna charge that back. Things along those lines. Is this something that we need to be aware of? What’s our thoughts here? Has there been a little buzz about this at MRC this past week?

Allan Shearer: Yes. If we go back to what we said at the start, the reason that VAMP is here is because the previous programs were not as effective as they needed to be and aren’t bringing the outcomes. But also the world has changed and it had to update. With agentic, there’ll be a number of things that change in our world, and the first thing I would say is whether it’s fraud, whether it’s a dispute, I would look at it and go, are our current frameworks within the ecosystem that we operate in today fit for purpose in an agentic world.

If I’m an issuing bank and I’m receiving a chargeback, as I receive that chargeback, am I going to look at it differently if it’s under agentic. Has my consumer signed up for different terms and conditions because it is agentic, do I know it was an agent that purchased that?

There’s a number of things, not only just VAMP, the entire way through the payment ecosystem that I think will have to adapt. I think it’s healthy adaptation. I think it is moving forward. VAMP is definitely one that when I see, if I see my VAMP ratio, if I see my fraud ratio, I almost would want an asterisk in terms of yes, this was the ratio and this part of it was under my agent at this point in time.

This was agent transactions because I think it needs enough of that attention brought to it because yes, it has the potential. I’m a very optimistic Scottish man, there’s not many of us that come out of that country. I do think it’s something that we will all benefit from going forward, but I want to make sure that we don’t just kinda shovel it into the same bucket.

We’ve talked about buckets. I don’t want it in the same bucket. I believe it requires its own bucket. It requires its own lampshade going under it to ensure that we are addressing whether it be fraud, whether it be payment acceptance in that specific area.

Chris Uriarte: Keith, I will give you the last word on agentic here. What are you guys thinking about and how it plays into this?

Keith Briscoe: Yeah, there’s definitely a feeling this is gonna result in more confusion potentially, but also more deliberate misuse of the dispute system. I think it’s the old bubble analogy. If you start to tighten things up in one area, let’s say CE 3.0 and first party misuse, right, that consumer is going to find potentially other ways to abuse the dispute system, right?

And agentic is one of the obvious paths for that. I think we all probably appreciate as well that when you’re in the bank’s shoes and you’re getting an intake from a consumer who is citing that they didn’t make that purchase because it was done through an agent, the regulatory environment doesn’t necessarily keep pace with that in real time, right?

So a card issuer does not necessarily have all they need to be able to push back on a consumer if they made decision or a purchase through an agentic agent, right? So there is this lag that is created and some of that consumer behavior can then get perpetuated, right, if they’re not consequenced for misusing the system in that way.

So there is this complexity of what happens on the issuer end of the spectrum as well that I think is going to present a few wrinkles for these agentic flows, for sure.

Chris Uriarte: So guys, say what you want about agentic, I’m not sure if we’re gonna be talking about agentic in three years or five years, but I’m sure that VAMP is probably still gonna be around. So we’re gonna keep an eye on this. I thank you today for this. Really, really rich discussion on this. Still very important topic.

Keith Briscoe from The Merchant Risk Council, Allan Shearer from JP Morgan. Thanks for joining me today and to all of our listeners, thanks again for listening to Payments on Fire. Do good work and have a great day.