Topic Options
#2100308 - 09/26/16 11:25 AM Mastercard requirements for cash advance
smdawson Offline
New Poster

Registered: 06/24/10
Posts: 2
According to MasterCard rules, do banks have to offer cash advances at ALL branch locations?

Top
Operations Compliance
          Learning Connect Webinar          Learning Connect Webinar
#2100393 - 09/26/16 02:41 PM Re: Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
Unless it is a loan production office, the answer is, "Yes."

MasterCard Transaction Rules:

4.14 MasterCard Manual Cash Disbursement Transactions
In the U.S. Region, the Rule on this subject is modified as follows:
Subject to compliance with the Standards, each Customer within the United States Region must provide cash disbursement services to all Cardholders at all of the Customer’s offices where teller services are provided.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2113756 - 01/10/17 04:47 PM Re: Mastercard requirements for cash advance [Re: smdawson]
ForceFull1 Offline
100 Club

Registered: 11/07/03
Posts: 230
Loc: smalltown Iowa
Bumping this thread. Confirming that 4.14 in the MasterCard Transaction Rules still requires us to "provide cash disbursement services to all Cardholders at all of the Customer’s offices where teller services are provided." The most current MasterCard Transaction Rules I can find are dated January 21, 2016 and include this language. Just making sure I'm not overlooking a more current set of rules. Thanks!

Top
#2113779 - 01/10/17 09:59 PM Re: Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
MasterCard keeps the most current versions of their rules available here.

Rule 4.14 of the November 2016 edition of the Transaction Processing Guide:

4.14 Mastercard Manual Cash Disbursement Transactions
In the U.S. Region, the Rule on this subject is modified as follows:
Subject to compliance with the Standards, each Customer within the United States Regionmust provide cash disbursement services to all Cardholders at all of the Customer’s offices where teller services are provided.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2113794 - 01/11/17 08:54 AM Re: Mastercard requirements for cash advance [Re: smdawson]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 36678
Loc: Cape Cod
Just to round this question out a bit, Brian, what does Mastercard (note they have changed their standard spelling to drop the lower case "c") or Visa have to say about cash advances on unembossed prepaid cards often issued by tax services or by many states to distribute state tax refunds directly?
_________________________
John S. Burnett
BankersOnline.com
Professional Compliance Nerd since 1976
Bankers' Threads User #8

Top
#2113837 - 01/11/17 11:25 AM Re: Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
For banks that offer cash advance services, they must provide cash advances to all cardholders, embossed and unembossed.

Mastercard:

4.14.1 Non-discrimination Regarding Cash Disbursement Services
Each Customer and each of its authorized cash disbursement agents must comply with the following requirements at each office at which any cash disbursement services are afforded:
1. Not discriminate against or discourage the use of Cards in favor of any card or device bearing or otherwise issued or used in connection with another acceptance brand; and
2. Provide cash disbursement services to all Cardholders on the same terms and regardless of the Issuer.

VISA: 5.5.1.1 Card and Cardholder Validation in a Face-to-Face Environment

The rule references requirements for processing cash disbursements. It includes anonymous prepaid transactions as being eligible for cash advances.

Verify that the signature on the Card matches the signature on the
Transaction Receipt and on any identification required and presented4
This requirement does not apply to:
● Transactions in which:
– The Card or payment device does not have a signature panel
– A PIN is used
● Anonymous Visa Prepaid Card Transactions
● Visa Commercial Card Transactions
● Vehicle-Specific Fleet Card Transactions
● Visa Easy Payment Service (VEPS) Transactions
● In the Europe Region, Small Ticket Transactions

Short answer: Yes, we must allow cash advances for these cards and follow appropriate verification procedures.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2113859 - 01/11/17 12:35 PM Re: Mastercard requirements for cash advance [Re: BrianC]
MBTCompliance Online
Gold Star

Registered: 04/18/15
Posts: 268
Can a bank stop offering cash advances altogether?

Additionally, are there any other compliance requirements (ex: OFAC check) to consider when offering cash advances to non-customers?


Edited by MBTCompliance (01/11/17 01:10 PM)
Edit Reason: Added Additional Question

Top
#2113896 - 01/11/17 02:11 PM Re: Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
See Mastercard rule 4.14 above. If you are a Mastercard issuer, you are contractually obligated to offer cash advance services. See this Related thread notes VISA relaxed is requirements a couple of years ago.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2113929 - 01/11/17 04:33 PM Re: Mastercard requirements for cash advance [Re: BrianC]
Ken_Pegasus Offline

10K Club

Registered: 08/30/01
Posts: 21705
Loc: Another trip around the sun
Brian,

If people keep asking this question over and over is there any chance you will change your mind?

grin
_________________________
My employer agrees with everything I say, but I'm not sure how that helps you.

Top
#2160441 - 01/12/18 11:16 PM VISA/Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
Ken. Almost a year to the day, but since tax refunds are soon upon us again, I decided to post the latest rules from the October 2017 VISA rules and December 2017 Mastercard rules. I plan to bookmark the thread so it is on speed dial when questions on cash advances begin surfacing again.

VISA Rule 5.9.1.1 Manual Cash Disbursement Requirements

If a Member makes Manual Cash Disbursements to other Issuers' Cardholders, it must do so in a uniform manner for all Visa products properly presented.

In the Canada Region and US Region, a Member authorized to make Cash Disbursements must make Manual Cash Disbursements to other Issuers' Visa Prepaid Cardholders at all of its Branches. A Member may make Manual Cash Disbursements through the offices of its related companies only if all of the following: ● The companies are primarily engaged in providing financial services to the public. ● The Member or the Member's holding company wholly owns the company. ● Visa has given the Member prior approval.

Although VISA no longer requires an issuer to also provide cash advance services, if it does, it must include prepaid cards (which would include unembossed tax refund cards.)

Next question about charging a fee: (we can't)

5.9.1.3 In the Canada Region and US Region, not assess an Access Fee on a Manual Cash Disbursement conducted with a domestic Visa Prepaid Card.

Mastercard Transaction Rules will also require services be afforded to prepaid access:

4.14.1 Non-discrimination Regarding Cash Disbursement Services Each Customer and each of its authorized cash disbursement agents must comply with the following requirements at each office at which any cash disbursement services are afforded:
1. Not discriminate against or discourage the use of Cards in favor of any card or device bearing or otherwise issued or used in connection with another acceptance brand; and'
2. Provide cash disbursement services to all Cardholders on the same terms and regardless of the Issuer.

Offering cash advances is still mandatory for Mastercard issuers.

In the U.S. Region, the Rule (4.14) on this subject is modified as follows: Subject to compliance with the Standards, each Customer within the United States Region must provide cash disbursement services to all Cardholders at all of the Customer’s offices where teller services are provided.

As with VISA, no fee can be charged.

4.14.3 Discount or Service Charges In the U.S. Region, the Rule on this subject is replaced with the following: With respect to the acceptance of prepaid Cards, the Customer and each of its authorized cash disbursement agents must disburse all cash disbursements at par without any discount and without any service or other charge to the Cardholder, except as may be imposed to comply with applicable law. Any charge imposed to comply with applicable law must be charged to and paid by the Cardholder separately and must not be included in the total amount of the cash disbursement.

I often have banks ask if they can send the tax refund people to the ATM. Since they are required to offer the service, they violate the above rules if they do this.


Edited by BrianC (01/12/18 11:18 PM)
Edit Reason: edit title
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2160808 - 01/17/18 04:09 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
Skittles Offline
10K Club

Registered: 09/10/02
Posts: 13121
Loc: TN
Brian,

We googled the Mastercard Transaction Rules. It appears this was updated December 21, 2017 and we were unable to locate section 4.14. Could this have been moved or changed to another section?
_________________________
My Opinions Only

Top
#2160810 - 01/17/18 04:16 PM Re: VISA/Mastercard requirements for cash advance [Re: Skittles]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
It's on page 111 of 297 and the amendment for the U.S. Region is on page 130 of 297 of the 12/21/17 document.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2160815 - 01/17/18 04:40 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
Skittles Offline
10K Club

Registered: 09/10/02
Posts: 13121
Loc: TN
Thank you, Brian. I knew you would lead me in the right direction!


Edited by Skittles (01/17/18 04:41 PM)
_________________________
My Opinions Only

Top
#2165308 - 02/21/18 11:10 AM Re: VISA/Mastercard requirements for cash advance [Re: BrianC]
MBTCompliance Online
Gold Star

Registered: 04/18/15
Posts: 268
Brian,

Regarding this portion of the post above:

"As with VISA, no fee can be charged.

4.14.3 Discount or Service Charges In the U.S. Region, the Rule on this subject is replaced with the following: With respect to the acceptance of prepaid Cards, the Customer and each of its authorized cash disbursement agents must disburse all cash disbursements at par without any discount and without any service or other charge to the Cardholder, except as may be imposed to comply with applicable law. Any charge imposed to comply with applicable law must be charged to and paid by the Cardholder separately and must not be included in the total amount of the cash disbursement."

I was reading and on page 130-131, it says this:

4.14.3 Discount or Service Charges

In the U.S. Region, the Rule on this subject is replaced with the following:

With respect to the acceptance of prepaid Cards, the Customer and each of its authorized cash disbursement agents must disburse all cash disbursements at par without any discount and without any service or other charge to the Cardholder, except as may be imposed to comply with applicable law. Any charge imposed to comply with applicable law must be charged to and paid by the Cardholder separately and must not be included in the total amount of the cash disbursement.

With respect to the acceptance of any type of Mastercard Card other than a prepaid Card, a Customer or its authorized cash disbursement agent may charge a fee for performance of the cash disbursement service (herein, a “Manual Cash Disbursement Access Fee”). Any Manual Cash Disbursement Access Fee charged must be:

1. Not greater than the fee established for any other payment network.

2. Disclosed to the Cardholder before a Transaction authorization request is submitted. At the time of disclosure, the Cardholder must be afforded the opportunity to opt out of completing the Transaction.

3. Disclosed on the Transaction receipt.

4. Detailed in DE 28 (Amount, Transaction Fee) of the Authorization Request/0100 or Financial Transaction Request/0200 message.

5. Detailed in DE 54 (Amounts, Additional) of the First Presentment/1240 message.

6. Included in the total Transaction amount transmitted in DE 4 (Amount, Transaction) of authorization and clearing messages.


I understand this to say we still cannot charge a fee for cash advances on prepaid cards. However, it appears we may now be able to charge a fee for non-prepaid cards. Is that correct? If we can charge a fee, my next question is what do we instruct our tellers to look for to determine whether the card is a prepaid or not? Or would our cash advance terminal be programmed to know the difference between prepaid vs. non-prepaid and assess the fee accordingly?


Edited by MBTCompliance (02/21/18 11:13 AM)

Top
#2165309 - 02/21/18 11:25 AM Re: Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
Related Thread that discusses the changes to VISA rules from 2014.

VISA rules require that a debit or prepaid card will say "Debit" on the physical card somewhere. These are the cards for which you cannot charge a fee.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2168799 - 03/16/18 04:35 PM Re: VISA/Mastercard requirements for cash advance [Re: MBTCompliance]
Bug Offline
New Poster

Registered: 02/06/17
Posts: 2
I read that change in 4.14.3 that we can charge an "Manual Cash Disbursement Fee" if we do so across the board (except prepaid) and disclose on the receipt.

Right?

Top
#2168836 - 03/17/18 12:15 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
Valley girl Offline
Junior Member

Registered: 08/01/14
Posts: 45
Loc: TX
Brian,
I have the VISA Business News issue from 6-26-2014 and it states we must still offer cash advances to prepaid cards. The paragraph is below.

Clients will not be required to support manual cash disbursements in all branches for all cardholders. Provision of manual cash will be an optional service for all products in all regions. If a Visa client opts to support manual cash disbursement requests from other issuers’ cardholders, it must provide the service for all Visa card products.
o Exception: In Canada and the U.S., manual cash disbursements must continue to be supported for Visa Prepaid cards.

Top
#2170201 - 03/26/18 05:21 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
Since I am not a VISA Member Bank, I do not have access to their publications beyond the publically available operating rules I recommend that you direct your question to your VISA representative.

All I have is the previously cited rule excerpt. "In the Canada Region and US Region, a Member authorized to make Cash Disbursements must make Manual Cash Disbursements to other Issuers' Visa Prepaid Cardholders at all of its Branches."

Are all VISA members "authorized to make Cash Disbursements" in the U.S. Region? This doesn't tell me that you are required to offer the service. This just states that if you do offer the service, you cannot exclude prepaid.



Edited by BrianC (03/26/18 05:36 PM)
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top
#2174107 - 04/18/18 01:50 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
DM Offline
New Poster

Registered: 03/04/16
Posts: 2
We are trying to decide if we can pull our cash advance machine from all branches, so I am reviewing the threads related to this question. There was a Visa Business News published on 26 June 2014 that states:

"Given the broad deployment of ATMs and the ease with which cardholders can obtain cash, in-branch teller-provided cash withdrawals are becoming less necessary. In response to client feedback, Visa has made the following rule changes, effective 15 October 2014 (except where noted, below):

• Clients will not be required to support manual cash disbursements in all branches for all cardholders. Provision of manual cash will be an optional service for all products in all regions. If a Visa client opts to support manual cash disbursement requests from other issuers’ cardholders, it must provide the service for all Visa card products.

o Exception: In Canada and the U.S., manual cash disbursements must continue to be supported for Visa Prepaid cards."

I believe the Canada/U.S. exception means that we can't pull our cash advance machines, but that we could limit our processing to only prepaid cards. Does anyone interpret this differently? Please tell me I'm wrong - I'll be thrilled.

Top
#2174138 - 04/18/18 03:29 PM Re: VISA/Mastercard requirements for cash advance [Re: smdawson]
BrianC Online

Power Poster

Registered: 11/26/04
Posts: 4205
Loc: Illinois
As noted in my previous post, direct this question to your VISA representative.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Top

Moderator:  Andy Z, John Burnett, Ken_Pegasus