The exact verbiage from MasterCard's U.S. Operations Bulletin dated May 27, 2014.
"MasterCard is revising its “zero liability” rule in the U.S. region by simplifying the language and applying the rule to all
MasterCard® branded POS and ATM transactions."
An Issuer must not hold a Cardholder liable for a Transaction that was not authorized by the Cardholder if the Cardholder exercised reasonable care in safeguarding the Card from risk of loss or theft and, upon becoming aware of such loss or theft, promptly reported the loss or theft to the Issuer.
This Rule shall not apply to a Transaction conducted with a Card that is:
a. issued to an entity other than a natural person;
b. issued for a commercial purpose; provided, the Rule shall apply to a Transaction conducted with Card for a “small business” program as described on
www.mastercardbusiness.com (under “Small Business,” select the “Products” tab);
c. issued and/or sold to a person until such time as that person’s identity is registered by or on behalf of the Issuer in connection with such issuance and/or sale, which registration may include customer identification program requirements.
On the surface I can see how one could interpret this as being all transactions regardless of network since the rule does not specify, but we have to look to the definition of ATM Transaction in
MasterCard Rules.
ATM Transaction
A cash withdrawal effected at an ATM Terminal with a Card and processed through the
MasterCard ATM Network. An ATM Transaction is identified with MCC 6011 (Automated Cash
Disbursements—Customer Financial Institution).
I agree with John. MasterCard branded networks would be MasterCard, Maestro, & Cirrus. I don't see how this could extend to transactions processed using competing networks. That being said, I also wouldn't want to get hit with non-Compliance fines from MasterCard. Sounds like a good questions for the attorneys.