What is the Terminated Merchant File (TMF) or MATCH List?
So… you’re stuck on the list? Let’s dive into what it really means for a merchant to get put on the TMF or Match List.
For the financial institutions that offer them, merchant accounts represent a certain level of risk. Irresponsible, unreliable or fraudulent merchants can create a financial loss for the processing bank that approved those merchants. In order to protect themselves, many merchant account providers refer to a list known as the Terminated Merchant File (TMF) list when considering new clients. Otherwise known as the MATCH (Merchant Alert To Control High-Risk) list, the Terminated Merchant File or TMF list is a list compiled and managed by MasterCard, of business owners (merchants) whose accounts have been terminated in the past 5 years for any of a variety of reasons.
Why Are Merchants Placed on Terminated Merchant File?
MATCH LIST REASON CODES
The table below provides the standard reasons that a merchant will be added to the Terminated Merchant File or MATCH list. These are official reasons provided by Mastercard.
Terminated Merchant File Definition
The Terminated Merchant File or TMF is a list compiled and managed by MasterCard, of business owners (merchants) whose accounts have been terminated in the past 5 years for any of a variety of reasons.
| MATCH Reason Code | Description |
|---|---|
| 01 |
Account Data Compromise An event leading to the unauthorized access or exposure of account information, either directly or indirectly. |
| 02 |
Common Point of Purchase (CPP) Fraud Account information is compromised at the merchant's location and subsequently used for unauthorized transactions at other merchant sites. |
| 03 |
Laundering The merchant is found to be involved in laundering, which involves submitting non-genuine transaction records for supposed sales of goods or services to actual cardholders. |
| 04 |
Excessive Chargebacks For a merchant reported by a Mastercard acquirer, experiencing Mastercard chargebacks exceeding 1% of their total Mastercard transaction count in any single month, with a total exceeding USD 5,000. For a merchant under an American Express acquirer (ICA numbers 102 through 125), surpassing American Express's chargeback thresholds. |
| 05 |
Excessive Fraud The merchant has engaged in fraudulent activities, where the ratio of fraud to sales dollar volume exceeds 8% in a calendar month, including 10 or more fraudulent transactions amounting to USD 5,000 or more. |
| 06 | Reserved for Future Use |
| 08 |
Mastercard Questionable Merchant Audit Program The merchant is classified as questionable under the Mastercard Questionable Merchant Audit Program criteria. |
| 09 |
Bankruptcy/Liquidation/Insolvency The merchant is, or is likely to become, incapable of meeting financial obligations. |
| 10 |
Violation of Standards A merchant reported by a Mastercard Acquirer that was found to be non-compliant with one or more operational standards. These standards outline the required procedures for transactions involving card usage, such as honoring all cards, displaying logos, cardholder charges, and adhering to minimum/maximum transaction amount rules, along with avoiding prohibited transactions as detailed in Chapter 5 of the Mastercard Rules manual. For merchants reported by an American Express acquirer (ICA numbers 102 through 125), non-compliance with any American Express regulations, bylaws, rules, or operational guidelines related to American Express card transactions was noted. |
| 11 |
Merchant Collusion The merchant engaged in collusion to commit fraudulent activities. |
| 12 |
PCI Data Security Standard Noncompliance The Merchant failed to comply with Payment Card Industry (PCI) Data Security Standard requirements. |
| 13 |
Illegal Transactions The Merchant was engaged in illegal Transactions |
| 14 |
Identity Theft The Acquirer has reason to believe that the identity of the listed Merchant or its principal owner(s) was unlawfully assumed for the purpose of unlawfully entering into a Merchant Agreement. |
What Happens When You Are Placed on MATCH List or TMF?
Banks and other account providers find the TMF or Match File list to be incredibly useful. It protects them from approving a merchant who could cause a loss. However, the list can make life quite difficult for a merchant who finds himself listed in the file. Often, merchants apply for a new merchant account, get turned down, and only then find out they have been added to the list.
Unfortunately, a business cannot simply substitute a new signer to get approved elsewhere because the name of the business, it’s principal signers, and both their addresses are recorded in the MATCH file. A merchant’s problems can even follow them to unrelated business ventures. The TMF effectively works as a blacklist against merchants who banking institutions deem too high-risk. For this reason, every business owner should work to understand how the list is operated and what a merchant can do if they find themselves on it.
When a merchant whose name appears on the MATCH file merchant list applies for a merchant account through a new financial institution, their application will be flagged. Likely, the new processing bank will turn down the application and deem it as too high risk. The processing bank may choose to contact the institution that added the merchant’s name to the list and inquire about the circumstances that led to the account termination. Using that information, they may choose to accept the merchant’s application, reject it, or offer a conditional acceptance with restrictions.
What kinds of problems can cause a merchant to be listed on the TMF or Match List?
In short, any sort of activity that causes the account holder to appear to be a bad risk. This can include excessive chargebacks, or excessive fraudulent transactions; noncompliance with PCI-DSS (payment card industry data security standards), the compromise of merchant account data; laundering, fraud, or collusion on the part of the account holder, or evidence that he was engaged in illegal transactions; an inability of the merchant to meet financial obligations due to bankruptcy or insolvency; or evidence that the account was opened fraudulently and that the identity on the account was stolen, lastly a merchant can be listed for violation of standards (agreement). Fortunately, there are many simple things you can do to prevent future fraud.
What kinds of problems can cause a merchant to be listed on the TMF or Match List?
In short, any sort of activity that causes the account holder to appear to be a bad risk. This can include excessive chargebacks, or excessive fraudulent transactions; noncompliance with PCI-DSS (payment card industry data security standards), the compromise of merchant account data; laundering, fraud, or collusion on the part of the account holder, or evidence that he was engaged in illegal transactions; an inability of the merchant to meet financial obligations due to bankruptcy or insolvency; or evidence that the account was opened fraudulently and that the identity on the account was stolen, lastly a merchant can be listed for violation of standards (agreement). Fortunately, there are many simple things you can do to prevent future fraud.
How Accurate is the Terminated Merchant File?
Though the TMF or Match List is managed by MasterCard, individual acquiring banks have the power to add or remove the names of merchants from the database if they have justification. There is little oversight in this process; MasterCard explicitly states in its Security Rules and Procedures that it does not attempt to verify the accuracy of, or basis for, the listing of any merchant on the TMF list, and that the data contained therein may be inaccurate or the circumstances giving rise to a merchant’s inclusion on the list may be under dispute.
How Do I Remove My Name From the TMF or MATCH list?
It can be hard for a merchant to get his or her name off the TMF or Match List, depending on the reason he or she was listed initially – fraud is a particularly difficult hurdle to overcome. The only recourse is to contact the banking institution that listed you in the first place and try to resolve whatever issue led to the termination; only the processing bank that placed you on the TMF has the power to remove your name. Alternatively, if you feel the TMF or Match listing is unfair, there are lawyers who specialize in this niche. Bank Card Law is one resource to help with this matter. They have successfully removed match listed merchants since 1994. Otherwise, your listing will remain active for five years.
