OCC Updates Merchant Processing Booklet

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On August 20, the OCC issued Bulletin 2014-41, which announces a new “Merchant Processing” booklet of the Comptroller’s Handbook. This booklet replaces the booklet of the same name issued in December 2001 and provides updated guidance to examiners and bankers on assessing and managing the risks associated with merchant processing activities. Specific updates address: (i) the selection of third-party organizations and due diligence; (ii) technology service providers; (iii) on-site inspections, audits, and attestation engagements, including the “Statement on Standards for Attestation Engagement” (SSAE 16) and the “International Standard on Assurance Engagements” (ISAE 3402); (iv) data security standards in the payment card industry for merchants and processors; (v) the Member Alert to Control High-Risk Merchants (MATCH) list; (vi) BSA/AML compliance programs and appropriate policies, procedures, and processes to monitor and identify unusual activity; and (vii) appropriate capital for merchant processing activities.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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