The Payments Experts Podcast

Why Merchants Get MATCH’d After Fraud They Didn’t Cause: Inside the BRAM Fine System | PEP109

Expert Payments Attorneys of Global Legal Law Firm Episode 109

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0:00 | 26:59

Negotiation changes when you have leverage. Our playbook: lock out debits, demand the underlying basis, and force real answers, sometimes by filing a complaint.

A six figure “brand fine” lands out of nowhere, nobody will show you the underlying letter, and the funds can get pulled before you even have a chance to respond. That is the reality we see for merchants caught in the gap between card network rules, sponsor bank obligations, and the merchant processing agreement that quietly shifts liability downstream. 

We sit down with Global Legal Law Firm attorneys Christopher Dryden and Bryce Van De Moere to talk through why these penalties feel so arbitrary, why the numbers can swing from $50,000 to $200,000, and why the system often seems designed to keep merchants in the dark.

We break down how brand reputation fines get assessed upstream and shoved downhill until the merchant is left holding the bill with little to no explanation. We also share the tactics we use to force transparency, protect cash flow, and negotiate when a processor or bank refuses to engage.

• how brand fines work between card brands, sponsor banks, processors, ISOs, and merchants
• why merchants often cannot see the brand letter or the alleged offending behavior
• how “taking first” undermines notice and an opportunity to be heard
• why brand fines can be negotiable despite being presented as non-negotiable
• when it makes sense to lock out debits to create leverage
• why we sometimes skip demand letters and go straight to a filed complaint
• how consolidation in payments limits merchant choice and increases risk

We walk through the full chain of responsibility from the card brand to the sponsor bank to the processor to the ISO, and finally to the business owner trying to make payroll. Along the way, we dig into the most frustrating part: the lack of transparency and the lack of a fair process. If you have ever asked, “How can I defend myself if no one will tell me what I did,” we tackle that head on, including what we have seen actually move the needle when compliance teams refuse to engage.

Then we get practical about leverage and outcomes. We talk about why locking out debits can change the negotiation, how and why brand fines can sometimes be negotiated down, and when escalation to a filed complaint is the only way to trigger real deadlines and real accountability. If you care about merchant rights, payment processing compliance, and protecting small business cash flow, this conversation is for you. Subscribe, share this with a business owner who takes cards, and leave a review with the question you want us to answer next.

Processors can pull funds before you even get notice. We break down the chain from card network to sponsor bank to processor to ISO to merchant, and why “due process” disappears in payments. 

**Matters discussed are all opinions and do not constitute legal advice.  All events or likeness to real people and events is a coincidence.**

PEP Links:
https://www.globallegallawfirm.com/podcasts/


A payments podcast of Global Legal Law Firm

SPEAKER_01

So when you you lock them out, A, like now I just find it's very, it's it's much easier to negotiate with somebody when you have something that they want. And and and even at $250,000, $300,000 or whatever, whatever the amount may be, the banks are don't move fast. And that they're not going to take action immediately to try to go get that money. And if you got me or anybody that's representing you, they're gonna have to deal with me and they're gonna have to explain themselves. I want to make sure that they took the opportunity to negotiate it down because they don't give a shit. They've already don't give a they don't care because because, yeah, are you from roll? They've already got their money. They have no they have no dog in the fight.

SPEAKER_00

You should have let me interrupt you.

SPEAKER_01

I know they have they have no dog in the fight.

Why Merchants Get Squeezed

SPEAKER_02

Welcome to the Payments Experts Podcast. A podcast of global legal law firm. We hope you enjoyed this episode.

SPEAKER_00

First off, I want to apologize to Bryce for Jeremy's introduction because Bryce is far more than the manager of our match program. 100% I didn't say manager. Bryce is Bryce is a legal warrior who goes against the big entities that just don't care about everybody downstream, in my humble opinion. But this is we're we're Jeremy finally browbeat us to get down in here in the pods podcast studio and out of Bryce's office where we sit and just commiserate with one another and uh and you know we'll take our anger management session down here. But uh we've been talking about some interesting subject matter recently. Um, we're always talking about it, actually. It's just a matter of taking the time and coming and sharing it with all of you. Uh, but you know, I asked Bryce to kind of focus in on the things that he's seeing most often and kind of what he feels is the most inequitable, um, especially as it relates to merchants, because Bryce and his group probably works with merchants more than anybody else in our firm. Uh, and it's a totally different perspective, from my opinion. Like it's uh it's one in which the merchants are underrepresented, have less contractual rights. Um, usually like the idea of good faith isn't really extended to them in the operation of a merchant processing agreement, and uh really they just get dictated to. Um, I see it happen all the

What Brand Reputation Fines Are

SPEAKER_00

time. So uh in that respect, um, some of the things that we wanted to talk about, I mean the first one is, you know, Bryce has had some recent experience with Bram fines, which are these nebulous brand reputation uh, you know, assault on the card brands, nebulous language in a contract, which uh merchants get penalized with to like exorbitant amounts. You thought like surcharge and cash discounting non-compliance fines were big, brand fines even greater. But tell us about Bryce.

SPEAKER_01

Well, first off, then thank you for that introduction. Yeah, of course. And I have to say, like, I I am really blessed like by the with the work that I get to do now. Not only does it give me the opportunity to work out all of the bullying that I that I had to endure in like middle school and and you know high school, but uh it's also it just gives me the opportunity finally like when you look at something, and I'm Jerry, I'm sure you can relate to this. When you look at something, and it's just wrong. I mean, it's just it's just wrong from everywhere you look at it. And and a lot of times, like nobody can do anything about it. Like, like he says, you it's just you have to accept it. And I'm put I've for better or worse been able to put myself in a position where I don't have to accept it. I I and and I try to do that for my clients as much as I can. Like they, I think I've said this before, but I have enormous empathy for anybody who decides to go into business, especially as I'm released to payment processing these days, because everybody has to get their hook into you. Like the amount of fees that are that are pulled out of your profits, your revenue that appear on a merchant statement are, you know, absol absolutely appalling. And they make absolutely sure that they get their take. And so the merchant is supposed to just, I mean, I'm probably you know, I mean, probably making a light of it, but they have to subsist on the scraps so that I know that their profit margins are razor thin. And uh, and so I uh, you know, when you start from that basis, I I really feel like I'm on the right side, you know, like I really, really do, like all the time. So um, yeah, brand fines, and I know we've kind of discussed this uh a lot before, but uh, and um I'm just gonna give my opinion on how it's well, I know how it's handled, but how you know uh merchants can at least like defend themselves, you know, when this happens. So you'll, you know, the merchant will will likely get notifications from the processor, the bank, but more lucky the processor, because the processor does all of the bank's dirty work. And the ISO does all the dirty work, and they'd be like, oh yeah, you got a brand fine, uh, but we can't show it to you. Uh we we we can't explain why it is what it is, um, and you gotta pay it. And uh, and that's really all the merchants ever gonna get. I I I've I think I've seen a brand letter, brand letter by like like three, four times total, and usually it was a mistake that somebody didn't know that they were not supposed to turn it over to me. And so they're like, Yeah, merchant, you got a fine. Well, that's not really the case because actually the contracts are between MasterCard and the bank, and they don't want to talk to anybody else. So actually the fine is assessed against the bank.

SPEAKER_00

Yeah.

SPEAKER_01

Because they did faulty underwriting, because I guess, you know, because I, you know, and here I'm actually gonna like fall on the side of the banks because when they signed this merchant up and they invested all this money in them, they thought that they were in compliance. And actually at that time, they probably were in compliance. But then MasterCard decided, nah, we don't like that rule anymore. We're gonna change it. So now it's like because the bank doesn't have a time machine and can't go back and correct a problem that it didn't that didn't even exist at the time, they want their cut from the bank. Uh and and so, and and then unbeknownst to the merchant, and I'm I I doubt, I doubt they know it's buried so deeply in the terms and conditions, is that you know the merchant is agreeing that they will be responsible for any penalty or fine that is assessed against the bank or the processor for their processing behavior.

SPEAKER_00

So Yeah, but you're talking about uh not to interrupt your flow because you're just like on your tirade, obviously.

SPEAKER_01

No, I think it's a tirade about that, yeah.

SPEAKER_00

But you actually gave the instance where the bank actually does have some sort of um or less culpability, right? Like it's not necessarily like the bank finds itself in the same position as the merchant. It doesn't matter. You know uh all processing is dictated by the the sponsor bank's credit underwriting guidelines. But like Bryce says, like the flavor of what the card brands are willing to entertain as far as you know types of industries that they'll allow, and it's it's a really fluid thing, right? And so it could be that when the bank did do its underwriting, which they're never doing the underwriting, but when the bank or the shadow underwrit, but when they did approve the merchant and they approved the processing activity, yeah, like they they actually um you know they were probably doing their job and then something changed and then the fine comes down.

SPEAKER_01

But well, let's be honest here, like the bank the oh yeah, actually I'm sorry.

SPEAKER_00

But but I think that there's a lot of instances where there is a lot of like fraud on the way in. And look, I'm not excusing poor underwriting, but I am saying that there are many times that like some of these violations are legitimate. It's the fines that are like crazy.

SPEAKER_01

Well, yeah, and and and and you know, I mean, most of the time the bank has no no idea what's what's going on. I mean, they they have they have delegated, as they are, is their right, they have delegated a certain portion of the responsibilities that they have to meet uh with MasterCard to uh another party, and they're just like, you know, we got enough on our plate, you guys handle it. So very often they have no idea that any of this has happened. And, you know, I I say a lot of times to a lot of banks, because I I spend a lot of time dealing with the stripes and the PayPals of the world, and and they have like five, six different sponsor banks, you know, and and uh and I'll have to end up having to sue the bank. And and you know, invariably an attorney will call me up, it'll get, you know, get a sign of the case, call me up and be like, well, why what's the claim about? Because it's pretty much the first time anybody's actually looked at it. Uh and I'm like, look, dude, if you and I are talking, it's just because your processor has failed miserably to communicate with me. I'm asking like simple questions here, and they just will not tell me anything. So I'm like, screw you, you can't give me what I need anyway. So I'm just gonna go to your boss. And so that's why we're having this conversation. And then finally, somebody for the first time looks at at the case and and we're able to like work it out. But I don't think that by and large, these processors know that they have no accountability and they just seem to be perfectly, you know, okay with dragging their banks unnecessarily into lawsuits when a simple conversation at the outset could have, you know, could have ended everything. Um we're reasonable people. If if you got me, you got me. But you gotta at least tell me what we did so that we can address it. And that that is like kind of what what drive what drives me.

SPEAKER_02

But uh, you know, I mean but yeah, can I ask the question, Bryce? Yeah, but so you you mentioned in your opening statement that the processor or the bank, whoever it is, reaches out to the merchant and says, hey, you owe this money. No. Talk about the scenarios where they don't even say that. Well, no, they don't they just take the money or they withhold it from the residuals of that are coming

The Cascading Fine And No Notice

SPEAKER_02

in. Oh, get those calls off the top.

SPEAKER_00

It's it's not the residuals. So, like I think it's really important to understand the cascading effect of a brand fine. Like, please explain. Yeah. Ultimately, like Bryce said, the sponsor bank is contracted with the card network. The card network is the originator of the fine. Okay. The sponsor bank is ultimately responsible to them, but the sponsor bank can go ahead and reach to the processor. The processor can reach to the ISO, and the ISO can reach down to the merchant. Ultimately, based on the MPA, it's the merchant that's responsible. And again, this is one of those things where no merchants even try to negotiate their agreements. I mean, it is like I we need to keep ta attacking the merchant processing agreement. But like, I understand that there's obligations by the merchant, but you know, there's this idea of due process in our society, which is a notice and an opportunity to be heard, right? What you just talked about is even not even getting notice. There's the taking, right? They just the taking happens before you even get a voice to contest it, right? There's but there's no process outlined when fines and fees come down the pipe for a merchant to even even for uh an abbreviated time period to have adequate information to respond, right? Before the taking occurs. And the because this is a contract and it's not statutory, because again, the card brands aren't regulated, the contract is supposed to have some sort of measure of good faith in its operation between the parties. Well, that doesn't really ever happen in this context. And so this is just push it down, push it down, push it down until the merchant eats it, or the merchant eats a large portion of it. The crazy part is that the brand fines, first off, I don't know how they're how they're valued. Nobody does, yeah. And and and when I tell you that they range from $50,000 to $200,000 for nebulous behavior that's unidentified, that's how much that can range for. And I don't know because of the lack of transparency. Like they seem to think that they there's this uh not just ability, but like duty to withhold the information that it's somehow sacred.

SPEAKER_02

Yeah, that they're protecting something.

SPEAKER_01

Yeah, like well, they're no, they're protecting themselves with providing reasons. Privacy considerations and all this stuff, and I'm like, well, privacy considerations. I don't give a crap what your protocol is because if we're in court, you're still gonna have to tell me. So, like, why not tell me now?

SPEAKER_00

But you know, I um and if you're go ahead and finish, so then then I'll No, I was uh like I just think that there's this cascading effect, and what most people don't know is that the Bram fines are negotiable.

SPEAKER_01

Well, they are, and and that's like so you read, you know, you read the Bram letter, and it'll give the violation, won't explain what the the how the violation applies to the behavior, but just as you you broke this rule, this rule, this rule, this amount of money is is a stakeholders.

SPEAKER_00

Yeah, it won't even identify what the be offending behavior was to violate the rule.

SPEAKER_01

Yeah, but you and you see like 300,000 and then they negotiate it down to like 46, and you're like, how, how, how, like, like what? Yeah, like because you're just pulling a number out of the sky. Exactly. You're telling me that you can't explain to me why. Yeah, it's basically, yeah, it's like, you know, they want to keep their relationship alive. So they're they're gonna kick down something. And now I even wonder if like they actually, when the negotiation happens, like before they get their money from the merchant, because you know, I want to back up a little bit, because this is a family show, I'll I'll temper my language. But like, you know, crap rolls downhill. So the bank just boom takes it from the processor right away. Like the MasterCard hits the bank with the fine, bank just turns around, just grabs it right out of the processor's account. Like, no questions asked. So the processor or the ISO rather, because it keeps, you know, everybody keeps taking from the person below them until it reaches the merchant.

Locking Out Debits To Negotiate

SPEAKER_01

And so what I recommend my clients do, and uh, and you know, I mean, this is my opinion, you're gonna have to make your own decision here. But I'm like, look, if if you get wind of the fact that, you know, a brand fine has been assessed against you, and I had yet to see one time, one time I saw a brand fine assessed without a match placement, which is like a whole different bottle of wax. But um, if you get wind of the fact, they're coming at you saying, hey, you've been fine this amount, uh, we need you to pay this, immediately go to your bank and say, prohibit all trans all debits from from attempted debits drawing to stripe or or whatever the process of guys is just like lock them out because you're not gonna be processing anyway. And and I can't do anything to protect your whatever reserve that they've negotiated with you. Hopefully they've negotiated one there and it's like grabbing money like all they can, but like lock them out and then and then and then they'll come back. They'll be like, hey, why aren't you paying this? I'm like, well, what is this based on? Did you negotiate it? Like, are we gonna have an abil an ability to appeal like the reason for the assessment? Because MasterCard just shoots in the hip. They they very rarely ever have a justification for for what they do because they just get like a weird feeling and like $250,000 because of my weird feeling. I I don't have to explain it to you because nobody at MasterCard talks to each other, and you're never gonna actually reach the person who actually made the decision or explain why. So so they they just swing wildly. But that's that's the other thing. Like so but let me let me finish this. But so so when you you lock them out, A, like now I just find it's very, it's it's much easier to negotiate with somebody when you have something that they want. And and and even at $250,000, $300,000 or whatever, whatever the amount may be, the banks are don't move fast. And that they're not going to take action immediately to try to go get that money. And if you got me or anybody that's representing you, they're gonna have to deal with with me and they're gonna have to explain themselves. I want to make sure that they took the opportunity to negotiate it down because they don't give a shit. They've already don't give a they don't care because because yeah, are you broken roll? They've already got their money. They have no they have no dog in the fight.

SPEAKER_00

You should have let me interrupt you.

SPEAKER_01

They I know they have they have no dog in the fight. So how do you negotiate with somebody with no no dog in the fight?

SPEAKER_00

Well, the the the the bigger one is this uh like and and I've seen this not in Bram or or Match, I've seen this in the in the bank deposit ones with Chase. You got somebody in compliance that's just justifying their existence, right? No, no, no, no, no, like in and it's like you know, look, they colored outside the lines, yeah. And they but they colored outside the lines, right? And it's that's bad, yeah. And it's this idea of like not understanding that rules are malleable and open to interpretation, or it's not a black and white thing, and that, yes, they colored outside the lines. Let's explain how they were being bumped while they were coloring, and this is why it ended up in that result. But because we deal with lawyers, and sometimes I think the lawyers are just playing possum, but a lot of times I think it's whoever they're dealing with back at the institution that is dictating to them like, no, no. And it's somebody who is just that lives in like like an engineer, right? If you ever like have dealt with an engineer on a problem and you're not an engineer, like you'll notice that they approach it entirely differently and they analyze it differently. And it's the same thing with people that do compliance. It's like we do compliance, but we also live in the real world world, and we see how facts apply to rules. Yeah, these people don't, they just live in the rules, and then it's just like it like it's a black and white analysis. And so I think sometimes when you're talking about the bank or you're talking about Visa MasterCard, it's the compliance people that are sitting back there that are going, like, hey, this this happened, this happened. And some of it's egregious and some of it's a really close call.

SPEAKER_02

100%, Chris.

SPEAKER_00

And that was very well said. I think you put your finger right on it. Yeah. I look, I I don't always think it's I don't always think it's one factor, right? I mean, I think it's the way that the system is architected, it creates a lot of inequities and most of them like sit with the merchant. And and that's one of these things about this podcast that I wish we understood, because we're lawyers, not marketing people, how to actually make it to the merchants with our message, because they're the ones that are underrepresented and need us. And in fact, I find that the most successful agents that I encounter in our practice that we do contract work for, and they're the ones that are white glove guys. They're the ones that understand the merchants, understand their business, understand their processing and are and understand payment processing, and they're there finding them the right partners, monitoring what they're doing, making sure that if there's gonna problem that could arise, they're addressing it beforehand. So, like the agents that deal with these types of merchants, like these are the people that we want to talk to because the the only way to change this industry, and I think Bryce has done a lot of really good work to make people change the way that they're approaching these types of instances with merchants, uh, is we gotta like make noise. We've got to make noise to try to change. Like, I'll tell you, I think that MasterCard started putting out an email that you can email to find out whether you're on the match list and why. And it has to come from the account holder or a beneficial owner of the business and somebody associated with the account, and it has to match the identification information on the MPA. But I think that's a direct result of what Bryce did with match. I mean, like, I think that the fact that that even exists, because they got tired of us, and the only way for things to change, yeah, the only thing that way for things to change is for us to like actually make noise. Yeah, and and I think with that noise that there will be some all we're asking for is a fair process. Even if you decide against us, like you're not even allowing us to have a voice, right? Like you're you're taking before we are even able to be heard, and you know, it kind of like rolls to the next part, but like, you know, the merchants, dude, they're just trying to defend their cash flow. Yeah, they're just just trying to defend like being able to maintain the business that they've started. It was like what the guy said yesterday on our podcast. Like, you know, there's very few positive touch points for the merchant in any respect, right? And this is one of those touch points that doesn't have to be as negative as it is, and it just is. But like most of it's just around like you know, protecting cash flow. I mean, you've had an instance recently where that that's been a primary concern.

SPEAKER_01

Yeah, and and and and we'll uh I mean yeah, we'll get to that. I'm not gonna name I don't want to name names yet, but but uh yeah, I mean because we're gonna we're gonna see how this plays out. We'll talk about foreshadowing for the for the podcast.

When Complaints Beat Demand Letters

SPEAKER_01

But uh, you know, we've moved to a you hit their nail right in the head about the whole thing, you're not calling the lines and because we've moved to from a letter writing, you know, tactic to just going straight to a complaint. Because and and people are like, you know, why do you have to do that? Like because it because it is, it's more expensive. Like to draft a complaint costs like several thousand dollars. But it has become absolutely necessary the process because you know, when you're dealing with the bank directly or stripe directly, you're dealing with an analyst or a compliance attorney. You're not dealing with a litigator. And so, you know, you're like, hey, you'll make I'll make all these arguments and they'll go, okay, I'll check, and then they'll go to the bank and they're like, no. And I'm like, they're no. And I'm like, oh, okay, well, I guess we're done here. You know, but so when you file a complaint, we usually like we usually email them a copy of the complaint, we give them, I'm like, hey, look, respond to us uh, you know, within a week, or this is really the only play that you left us. Like, so we're gonna have to take this to the next level. Well, then what that does is then they go out and they they hire litigation attorneys. And litigation attorneys have like have to be accountable. And and they have dead deadlines. And like they want to, you know, because the analysts and the and the comp and the in the and the general counsels, they're only interested in covering the bank's ass. Litigation is like, is like these are real world consequences, especially when you and uh you know, and I know you know that you don't have any actual basis for anything you've done. Like MasterCard is not gonna ride in, you know, and and rescue you with all this real information. You're being completely hung out to dry by MasterCard. And I feel bad for you, but that's not my that's not my problem. Like you said, we have this due pro we have this thing called due process, and and if you're gonna, you know, if you want this money from my client, we'll settle up at the at the end of all this after you answered these questions, you know, like one way or the other. Because that and that's really the only way you're gonna play it. Like, do you want to pay me to just throw letter after letter into the abyss and like get no response or or a shitty, a crappy response? Um, you know, or or do you want to just like just like hit them upside the head with and actually get much faster results? And and it's it's unfortunate that we you know we have to just go right into the fight. Uh luckily, you know, most of the time it never goes any farther than the complaint because, you know, the litigation attorneys understand that like they have a duty to disclose this information and they're gonna have to disclose it one way or the other. And they're just gonna have to go make their client understand. And I don't think that's an easy fight for them either. But that's just them in a precarious position. Absolutely. But but you but it it's just the way it's gotta be. And hard deadlines. And we're getting results. Yeah, the hard deadlines and the intervention of the court or or an arbitrator, it just changes the entire dynamic of the negotiation. And and that's I think ultimately we're showing that we're getting much faster, much better results for our clients by just going right at them.

SPEAKER_00

Yeah. Yeah. And and and and I like, look, in certain circumstances, demand letters can be very effective. Like, you know, I mean, for our more sophisticated clients with a problem in their banking relationship, a simple letter to the board of directors at the bank talking about potential director liability could get you some movement. Um, we've seen that really help. But like most times, you know.

SPEAKER_01

Well, they have every incentive to just sit. Because they're like, okay, you know, you're you're even in the app and mister Yapp and Mr. Attorney, but until you actually make the affirmative move, like we're perfectly satisfied with our position. We're not gonna do anything. So it's ultimately it's just an absolute as a move you at least in my in my practice, it it's is absolutely necessary.

SPEAKER_00

But even in litigation, man, I mean, how many times in litigation do we see the and I can't tell if it's the attorneys or the or the banker who's controlling it, but it maybe it's the attorney where they look at the contract and say, well, we wouldn't have to perform for this long, so we'll just hold you off or whatever.

SPEAKER_01

I mean, it well, the litigation counsel comes in and they're like, Okay, so like what's this case about? And I'm like, nobody told you? Like it's and that's what I realized. Like, nobody's actually looking at this. Like nobody cares. It's not coming out of anybody's pocket, it's coming out of some, you know, huge unlimited slush fund over at the bank. Like, they don't have to care. But so like it's it's just basically like have we're having the same conversation all over again, but you're actually listening this time.

SPEAKER_00

So I mean, yeah, it's yeah, but the real the like the the real world consequences for the merchants, they're it's it's a

Consolidation Risks And Final Takeaways

SPEAKER_00

problem.

SPEAKER_02

It's a real problem, Chris. I talk to merchants all the time who are a a week or two away from having to close up shop, literally.

SPEAKER_00

Yeah, and the American dream is supposed to be the ability of small business, right? But now, like, what percentage of of payment is card payment? I mean, like, and if you can't play this game, then you can't play any game and you're just beholden to it.

SPEAKER_01

I mean, everything's consolidating too. Like, like Sears went out of business. Like, so you have like a Target, Walmart. I mean, there used to be when we were in our day, yeah, you know, there used to be just a huge amount of options. Do you you could go and go to tons of stores, you go to a mall and see tons of stores. Everything is consolidated down. And so everybody's rights get, you know, get more and more tightly constrained.

SPEAKER_00

Well, that's even in payment processing, man. You you've got really everything leads back to FiServer global payments at this point, right? I mean, or Tis is Elivan. Yeah, I mean, yeah, yeah. Elevon's an outlier out there, but ultimately there's not too much in the way of choices. And it's it's kind of uh like that's the problem, is at what point does somebody come in and say, yeah, like this this is problematic? I mean, I will say, like, Illinois came up with the the you know, their own legislation-related interchange, and that got upheld.

SPEAKER_02

Thank you for listening to this episode of the Payments Experts Podcast, a podcast of Global Legal Law Firm. Visit us online today at Global Legal Law Firm dot com. Matters discussed are all opinions that do not constitute legal advice. All events or likeness to real people, and events is a coincidence.