Payment Network Compliance Assessment

Payment Network Compliance Assessment

Assess payment network compliance for "$ARGUMENTS". Evaluate Nacha ACH Operating Rules, card network requirements, and state money transmitter licensing obligations.

Prerequisites

Read .metapowers/compliance/$ARGUMENTS/00-scope.md. If this file does not exist, tell the user:

Phase 0 (Scope) has not been completed for "$ARGUMENTS". Run /compliance:regulatory-landscape $ARGUMENTS first, or use --skip-checks to bypass.

If --skip-checks is present in $ARGUMENTS, skip this check.

Process

1. Read context files:

   • Read plugins/compliance/shared/grc-lifecycle-guide.md for GRC methodology reference
   • Read plugins/compliance/shared/assessment-template.md for output structure
   • Read .metapowers/compliance/$ARGUMENTS/00-scope.md for scope and control framework context

2. Nacha ACH Operating Rules:

   • Assess authorization requirements (consumer and corporate, written/electronic/oral)
   • Evaluate ACH processing procedures (origination, file formatting, settlement timelines)
   • Review return handling procedures (return reason codes, timeframes, re-initiation rules)
   • Assess risk management requirements (exposure limits, monitoring, ACH audit)
   • Evaluate Nacha Third-Party Sender (TPS) registration and obligations if applicable
   • Review WEB debit authorization and fraud detection requirements
   • Assess compliance with Supplementary Fraud Detection Standards for WEB debits

3. Visa Core Rules and Product Rules:

   • Assess compliance with Visa Core Rules and Visa Product and Service Rules for card programs
   • Evaluate BIN sponsorship arrangement and registered agent/third-party agent status
   • Review cardholder agreement and disclosure requirements
   • Assess dispute resolution and chargeback management procedures
   • Evaluate Visa Operating Regulations for program-specific requirements (prepaid, credit, debit)
   • Review PCI DSS compliance requirements as mandated by Visa

4. Mastercard Standards and Rules:

   • Assess compliance with Mastercard Standards (formerly Mastercard Rules)
   • Evaluate registration requirements (Service Provider, Payment Facilitator, Staged Digital Wallet Operator)
   • Review Mastercard Identity Check and Strong Customer Authentication requirements
   • Assess chargeback and dispute management compliance
   • Evaluate Mastercard program-specific requirements for applicable products

5. State money transmitter licensing:

   • Determine which states require money transmitter licenses (MTL) based on business model
   • Assess applicability of exemptions (bank exemption, agent of the payee, licensed entity agent)
   • Review current licensing status across all required states
   • Evaluate NMLS (Nationwide Multistate Licensing System) registration and filings
   • Assess bonding, net worth, and permissible investment requirements per state
   • Review state examination and reporting obligations (call reports, audited financials)
   • Evaluate Uniform Money Services Act adoption in applicable states

6. Federal registration requirements:

   • Assess Money Services Business (MSB) registration with FinCEN
   • Evaluate biennial renewal and update filing compliance
   • Review state-level MSB registration requirements where applicable
   • Assess compliance with MSB-specific BSA/AML program requirements

7. Write the artifact to .metapowers/compliance/$ARGUMENTS/01-assess/payment-network.md following the assessment template structure with:

   • ACH Compliance — Nacha rule adherence, authorization, returns, and risk management
   • Visa Compliance — Core Rules adherence, registration, and program requirements
   • Mastercard Compliance — Standards adherence, registration, and program requirements
   • State Licensing — MTL coverage map, exemption analysis, and gap identification
   • Federal Registration — FinCEN MSB status and BSA/AML program
   • Evidence Inventory — existing evidence and evidence gaps
   • Remediation Priorities — ranked list of gaps to address

Output

The payment network assessment written to .metapowers/compliance/$ARGUMENTS/01-assess/payment-network.md. Present a summary to the user highlighting:

• ACH rule compliance status and key gaps
• Card network registration and compliance status
• State licensing coverage and gaps (number of states licensed vs. required)
• Top 3 gaps requiring remediation