Compromised Accounts

Visa Recovery Process FAQs

What must issuers do in order to participate in the Account Data Compromise Recovery (ADCR) process?

For issuers to participate in the ADCR process, they must—for each Business ID (BID)—be registered to receive CAMS alerts. Additionally to receive recovery of a portion of their operating expenses, they are required—for each BID—to enroll in the Operating Expense Recovery process.

How do issuers register to receive cams alerts?

To receive CAMS alerts issuers must submit an email to visariskmanager@visa.com and request a CAMS alert registration form.

How do issuers request to enroll in the operating expense recovery process?

Enrollment for participation in the Operating Expense Recovery process is done at the BID level. Issuers that license BINs must complete and submit the Account Data Compromise Recovery Process Operating Expense Recovery Enrollment Form for each of their BIDs.

What is the cost to enroll in ADCR?

There are no enrollment fees.

Are the administrative fees netted on a quarterly basis?

Each qualifying CAMS event will have separate credits. All credits issued, whether for recovery of counterfeit fraud losses or operating expenses will be distributed on a quarterly basis and each credit will be net of the appropriate administration fee.

Does an issuer have to experience magnetic-stripe (POS 90) counterfeit fraud in order to qualify for operating expense reimbursement?

No. Analysis of the magnetic-stripe (POS 90) counterfeit fraud will be considered in determining whether an event is eligible for operating expense recovery, however it is not a minimum requirement.

Why is ADCR limited to cams events with 350,000 accounts or greater?

Since the ADCR process requires a significant amount of administration, Visa needed to establish a minimum number of account numbers so that the process would not be applied to small events involving relatively small amounts of fraud. Based on analysis of previous events, only 0.16 percent of account numbers in qualifying events experience magnetic-stripe (POS 90) counterfeit fraud. Therefore, an event with 10,000 account numbers would only have approximately 16 fraudulent accounts and seemed to be a reasonable minimum.

What can an issuer do if the amount of account numbers in a cams event is less than 350,000 or if the fraud falls outside of the defined 3535 month window? Will there be an alternative process available?

No. If the compromise event does not meet the ADCR eligibility requirements, there is no alternative process available. In those situations, the fraud is the issuers’ responsibility.

How will issuers be notified that a CAMS alert qualifies for participation in ADCR?

Once Visa makes a final decision that an event qualifies for ADCR, all impacted issuers will be notified. Visa is still working out the details of how that communication will be distributed. Please note that in a best case scenario, that determination will be approximately four to five months after the date of the CAMS alert. This is because Visa must first make a preliminary determination of eligibility, then provide the acquirer 30 days to appeal. At the end of the appeal timeframe, Visa then evaluates all information before making a final decision.

What transactions qualify for recovery?

The following transactions qualify for recovery:

  • Transactions must be reported properly through the Visa Fraud Reporting System
  • Transactions must be reported as a full magnetic-stripe read transaction (POS Entry Mode of 90)
  • Transactions must be reported as counterfeit (Fraud Type 4)
  • Transactions must fall within the 13 month event window
    • Up to 12 months prior to CAMS alert date
    • And one month post CAMS alert date
  • Transactions with account numbers not involved in a prior compromise event within the 12 months prior to the event

What is meant by event window?

For magnetic-stripe (POS 90) counterfeit fraud transactions to qualify for recovery for a specific compromise event, their transaction dates must fall within the start and end date established for each compromise event. This timeframe is called an event window. Each compromise event that qualifies for participation in the ADCR process has its own event window. The event window is based on the date of the related CAMS alert and can be up to 12 months prior to the CAMS alert date and one month post the CAMS alert date.

How does Visa know that the fraud is tied to a specific CAMS event?

An event qualifies for ADCR based on Visas’ analysis of the forensic reports, information provided by issuers, information provided by the acquirer/merchant involved in the compromise event and analysis of fraud reporting. Additionally, account numbers that were involved in a prior event within the previous 12 months are excluded. Only the remaining account numbers that incurred magnetic-stripe (POS 90) counterfeit fraud losses are eligible for recovery.

How do chargebacks affect an issuer's recovery?

There are very few chargeback rights associated with magnetic-stripe (POS 90) counterfeit transactions. Given that liability is calculated at an aggregate basis for incremental fraud only, Visa is not accounting for chargebacks at this time. Visa will continue to monitor the activity to evaluate whether it makes sense to change this policy in the future.

Why are issuers only receiving operating expense recovery on 80 percent of the account numbers at risk?

The Operating Expense Recovery process provides some relief for accounts that had to be “worked” once a CAMS alert is issued. At the time of a CAMS alert, many account numbers on the alert are no longer active. They have already been closed, reissued, are expired, blocked, etc. Therefore there are no, or very little, incremental operating expenses that are incurred. An issuer survey conducted reflected that 80 percent of account numbers on CAMS alerts are actually worked.

When must an issuer enroll by to participate in the operating expense recovery process?

Enrollment must occur prior to the date of a given CAMS alert.

Will the enrollment process for operating expense recoveries ever expire?

This is an open enrollment process. Issuers can sign up at any time and once enrolled will remain eligible for recovery until such time the process is no longer supported.

The operating expense recovery amount of $37 does not cover issuer's true costs. Why is it so low?

Issuers vary widely on the processes they implement when a CAMS alert occurs. Some automatically reissue all or some of the account numbers listed. Some simply implement monitoring or enhance their current monitoring programs. Others do a combination of these. Still others do nothing. The current recovery amount of $1 is a reasonable starting point and may be reevaluated in the future.

What is baseline percentage?

Baseline percentage is the percentage of magnetic-stripe (POS 90) counterfeit fraud to total fraud in the Visa system excluding accounts in the event being evaluated.

What is baseline fraud?

Baseline Fraud is the amount of magnetic-stripe (POS 90) counterfeit fraud that would have been expected on the event account population if the compromise event had not occurred, in other words business as usual. It is calculated by multiplying the Baseline Percentage by the total fraud for the event.

What is incremental fraud?

Incremental Fraud is the total magnetic-stripe (POS 90) counterfeit fraud for an event minus Baseline Fraud. In other words, it represents the fraud amount that exceeds the Baseline Fraud amount.

Will the baseline calculation and the incremental calculation be published per event, and if so, where?

Yes. The baseline and incremental calculations will be included in the reporting that is provided to all impacted issuers.

When calculating the baseline percentage, will any other compromise events be removed to reach the final percentage?

The baseline percentage is the percentage of magnetic-stripe (POS 90) counterfeit fraud to total fraud in the Visa system, excluding only those accounts in the event being evaluated.

How will issuers be notified of their respective liability or reimbursement amounts?

After the close of the event window and when the fraud reporting period has elapsed, Visa will calculate each issuer’s respective liability or reimbursement amount and submit the results via email. Issuers will receive an Account Data Compromise Recovery - Issuer Recovery Statement. Acquirers will receive an Account Data Compromise Recovery – Acquirer Liability Statement. (CO-OP will receive for all shared clients)

Who will receive these statements by email?

Issuer statements will be emailed to both the Primary Center Manager and Fraud Manager(s) using the email addresses currently available in Visa’s corporate database, or to the designee provided through the Operating Expense Recovery enrollment process.

Who should issuers contact to update ADCR notification contact names and email addresses?

Send an email request to USMembercontacts@visa.com or contact Franchise Communications at (650) 432-7064.

Some Visa members sponsor other issuers and receive CAMS alerts on their behalf. Do these issuers need to register for CAMS themselves or are sponsoring members able to do it on their behalf?

CAMS alert registration and ADCR enrollment is done at the BID level. Only institutions that license their own BINs can register for CAMS.

If issuers experience a significant spike in magnetic-stripe (POS 90) counterfeit fraud after the event window has passed, will the original baseline for the event be re-evaluated?

Once the event window is closed, there will not be any adjustments made to the Baseline. One of the guiding principles of the ADCR process is to place a cap on the liability for which the acquirer is held liable. Issuers are encouraged to follow best practices and monitor and control fraud or re-issue accounts that are impacted by these events.

Will issuers need to do anything in order to collect the recovery amount noted on their issuer account data compromise recovery statement?

No. Visa will process these credits through the Global Member Billing Solution; also know as Integrated Billing.

Under what circumstances would an issuer not receive a fraud loss payout?

Issuers would not receive recovery of magnetic-stripe (POS 90) counterfeit fraud losses for the following reasons:

  • The compromise event did not qualify for participation in the ADCR process Magnetic-stripe (POS 90) counterfeit fraud transactions are not properly fraud reported as counterfeit (Fraud Type 4) within 90 days of the transaction processing date
  • The compromise event did not have 10,000 or more account numbers
  • The net recovery amount is less than $25
  • The issuer was not registered to receive CAMS alerts
  • The total amount of magnetic-stripe (POS 90) counterfeit fraud was not above normal levels
  • Visa is unable to collect liability from the acquirer

If an issuer BID or BIN is transferred during the event window, who will receive any payment due?

Visa will pay (through GMBS) the member of record at the time of the calculation.

Why is it that issuers will not receive recovery amounts that are under $25.00?

It is cost prohibitive to administer small recovery amounts.

Are there any issuer appeal rights if they believe their amount to be inaccurate?

No. Visa’s decision is final. If you believe there is an error, you may want to consider reviewing your fraud reporting practices to ensure they align with Visa U.S.A. Inc. Operating Regulations. Only issuers who have properly reported magnetic-stripe (POS 90) counterfeit fraud (Fraud Type 4) transactions within 90 days of the trans-action date, and whose transaction date falls within the event window, will be eligi-ble for recovery. You may also want to validate that none of your fraud transactions were returned (rejected) by Visa due to failed Fraud Reporting System edits.

Does participation in the ADCR process prohibit me from pursuing any legal rights against an acquirer?

Participation in the ADCR process does not relinquish any legal rights that may exist outside of the Visa system unless otherwise agreed upon by both the issuer and the point of compromise. Example: TJX compromise

Why doesn't the ADCR process allow for the recovery of card-not-present transactions?

This new process replaces the compliance right that existed prior to October 1, 2006 covering a violation for storing magnetic-stripe data that resulted in a financial loss for an issuer. Since chargeback rights exist for card-not-present transactions, they are not included in this process.

Will Visa be monitoring the abuse of the fraud reporting process?

Yes. Visa does plan on monitoring issuers fraud reporting.

Why does the 400-day event performance window not allow the 90-day timeframe for fraud reporting to be completed once a CAMS alert is communicated to issuers?

The event performance window does not affect the fraud reporting window at all. Regardless of when a fraud transaction occurred, the full 90-day fraud reporting window is allowed. Calculation of issuer recovery amounts does not occur until the 90-day fraud reporting window has elapsed.

What specific analysis is done on the fraud data? What can Visa do to prove the acquirer that true counterfeit fraud occurred?

Visa analyzes trends of magnetic-stripe (POS 90) counterfeit fraud for the accounts in the event and compares that to norms for the Visa system overall. The data used for all calculations is obtained from the Visa Fraud Reporting System that is reported in accordance with the Visa U.S.A. Inc. Operating Regulations.

What, specifically, does Visa do to determine if a merchant has been a common point of purchase?

Common points of purchase can be identified from a variety of sources including the merchant themselves, the acquirer, issuers, or Visa internal analysis. The Visa Fraud Control team will send a CAMS alert if it determines, based on all available information, that account numbers have been placed at risk. The ADCR process will only apply to a subset of CAMS alerts. See the Transaction Recovery Qualification section for more information.

If an issuer notifies a cardholder that his or her account has fraud on it and then at a later date that same account number shows up on a CAMS alert and it qualifies for ADCR, does the issuer have to report that fraud to Visa again?

If the issuer properly reported the transaction to Visa as counterfeit (Type 4) and validated that the cardholder was in possession of their card at the time of the transaction, the fraud reporting to Visa will be captured by ADCR—no additional work is required.