Topic: Merchant Processing
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Although we are not required to notify customers about the Visa Account Updater (VAU) program, shouldn’t we disclose to our customers that it is available?
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Although not expressly required, there are practical reasons to notify your existing customers about the VAU program and of their right to opt out, and also to include the opt-out right in your new account agreements going forward. For example, some customers may perceive the program as a violation of privacy — or simply may…
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We issue MasterCard debit cards, and we received an email from our core processor that we have to participate in MasterCard’s Automatic Billing Updater (ABU) program. This service requires us to notify MasterCard when a cardholder’s account information changes, so that merchants who have an existing relationship with the cardholder can continue to process recurring payments without an interruption in service. We are required to participate in the program, but customers may opt-out. We will review our privacy policies and account agreements, but what state privacy laws or notice requirements should we be aware of with respect to the ABU program?
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We are not aware of any federal or Illinois law that would require you to provide notice about the MasterCard ABU program and opt-out option to your debit card customers, although we believe it may be prudent to do so. Regulation P generally prohibits a bank from sharing nonpublic personal information about a consumer to…