Mastercard Incorporated; Analysis of Agreement Containing Consent Orders To Aid Public Comment, 2357-2360 [2023-00559]
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Federal Register / Vol. 88, No. 9 / Friday, January 13, 2023 / Notices
• construction of various related
facilities, including a new permanent
access road for the Cavern 4 Well Pad;
and
• non-jurisdictional facilities
consisting of a new electric service line
to the Cavern 4 Well Pad and a new
fiber optic line from the Cavern 4 Well
Pad to the Storage Facility.
Dated: January 6, 2023.
Kimberly D. Bose,
Secretary.
Background
[FRL OP–OFA–052]
On November 23, 2022, the
Commission issued a Notice of Scoping
Period Requesting Comments on
Environmental Issues for the Proposed
Tres Palacios Cavern 4 Expansion
Project. The Notice of Scoping was sent
to affected landowners; Federal, State,
and local government agencies; elected
officials; environmental and public
interest groups; Native American tribes;
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the Notice of Scoping, the Commission
received comments from the Texas
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primary issues raised by the Department
concerned impacts of the Project on
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[FR Doc. 2023–00549 Filed 1–12–23; 8:45 am]
BILLING CODE 6717–01–P
ENVIRONMENTAL PROTECTION
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Revision to FR Notice Published 11/
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Dated: January 9, 2023.
Cindy S. Barger,
Director, NEPA Compliance Division, Office
of Federal Activities.
[FR Doc. 2023–00589 Filed 1–12–23; 8:45 am]
BILLING CODE 6560–50–P
FEDERAL TRADE COMMISSION
[File No. 201 0011]
Mastercard Incorporated; Analysis of
Agreement Containing Consent Orders
To Aid Public Comment
Federal Trade Commission.
Proposed consent agreement;
request for comment.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair methods
of competition. The attached Analysis of
Proposed Consent Orders to Aid Public
Comment describes both the allegations
in the complaint and the terms of the
consent orders—embodied in the
consent agreement—that would settle
these allegations.
DATES: Comments must be received on
or before February 13, 2023.
ADDRESSES: Interested parties may file
comments online or on paper, by
following the instructions in the
Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Please write: ‘‘Mastercard
Incorporated; File No. 201 0011’’ on
your comment and file your comment
online at https://www.regulations.gov by
following the instructions on the webbased form. If you prefer to file your
comment on paper, please mail your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW, Suite CC–5610 (Annex Q),
Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT:
Christina Brown (202–326–2125),
Bureau of Competition, Federal Trade
Commission, 400 7th Street SW,
Washington, DC 20024.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
SUMMARY:
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Federal Register / Vol. 88, No. 9 / Friday, January 13, 2023 / Notices
Commission Act, 15 U.S.C. 46(f), and
FTC Rule § 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing a consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of 30 days. The following Analysis of
Agreement Containing Consent Orders
to Aid Public Comment describes the
terms of the consent agreement and the
allegations in the complaint. An
electronic copy of the full text of the
consent agreement package can be
obtained from the FTC website at this
web address: https://www.ftc.gov/newsevents/commission-actions.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before February 13, 2023. Write
‘‘Mastercard Incorporated; File No. 201
0011’’ on your comment. Your
comment—including your name and
your state—will be placed on the public
record of this proceeding, including, to
the extent practicable, on the https://
www.regulations.gov website.
Due to protective actions in response
to the COVID–19 pandemic and the
agency’s heightened security screening,
postal mail addressed to the
Commission will be delayed. We
strongly encourage you to submit your
comments online through the https://
www.regulations.gov website.
If you prefer to file your comment on
paper, write ‘‘Mastercard Incorporated;
File No. 201 0011’’ on your comment
and on the envelope, and mail your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW, Suite CC–5610 (Annex Q),
Washington, DC 20580.
Because your comment will be placed
on the publicly accessible website at
https://www.regulations.gov, you are
solely responsible for making sure your
comment does not include any sensitive
or confidential information. In
particular, your comment should not
include sensitive personal information,
such as your or anyone else’s Social
Security number; date of birth; driver’s
license number or other state
identification number, or foreign
country equivalent; passport number;
financial account number; or credit or
debit card number. You are also solely
responsible for making sure your
comment does not include sensitive
health information, such as medical
records or other individually
identifiable health information. In
addition, your comment should not
include any ‘‘trade secret or any
commercial or financial information
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which . . . is privileged or
confidential’’—as provided by Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and
FTC Rule § 4.10(a)(2), 16 CFR
4.10(a)(2)—including competitively
sensitive information such as costs,
sales statistics, inventories, formulas,
patterns, devices, manufacturing
processes, or customer names.
Comments containing material for
which confidential treatment is
requested must be filed in paper form,
must be clearly labeled ‘‘Confidential,’’
and must comply with FTC Rule
§ 4.9(c). In particular, the written
request for confidential treatment that
accompanies the comment must include
the factual and legal basis for the
request and must identify the specific
portions of the comment to be withheld
from the public record. See FTC Rule
§ 4.9(c). Your comment will be kept
confidential only if the General Counsel
grants your request in accordance with
the law and the public interest. Once
your comment has been posted on
https://www.regulations.gov—as legally
required by FTC Rule § 4.9(b)—we
cannot redact or remove your comment
from that website, unless you submit a
confidentiality request that meets the
requirements for such treatment under
FTC Rule § 4.9(c), and the General
Counsel grants that request.
Visit the FTC website at https://
www.ftc.gov to read this document and
the news release describing this matter.
The FTC Act and other laws the
Commission administers permit the
collection of public comments to
consider and use in this proceeding, as
appropriate. The Commission will
consider all timely and responsive
public comments it receives on or before
February 13, 2023. For information on
the Commission’s privacy policy,
including routine uses permitted by the
Privacy Act, see https://www.ftc.gov/
site-information/privacy-policy.
Analysis of Agreement Containing
Consent Orders To Aid Public Comment
I. Introduction
The Federal Trade Commission has
accepted, subject to final approval, a
consent agreement with Mastercard
Incorporated (‘‘Mastercard’’).
Mastercard operates a payment card
network over which merchants can
route debit transactions. Mastercard also
operates as a token service provider that
generates payment tokens for
Mastercard-branded debit cards,
including tokens saved in ewallet
applications on mobile devices.
The consent agreement contains a
proposed order addressing allegations in
the proposed complaint that Mastercard
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has inhibited merchants’ ability to route
electronic debit transactions in violation
of the Durbin Amendment, 15 U.S.C.
1693o–2(b)(1)(B), and Regulation II, 12
CFR 235.7(b), and therefore also in
violation of the Federal Trade
Commission Act, 15 U.S.C. 41 et seq.
The proposed order has been placed on
the public record for 30 days to receive
comments from interested persons.
Comments received during this period
will become part of the public record.
After 30 days, the Commission will
again review the consent agreement and
the comments received and will decide
whether it should withdraw from the
consent agreement and take appropriate
action or make the proposed order final.
The purpose of this analysis is to
facilitate public comment on the
proposed order. It is not intended to
constitute an official interpretation of
the complaint, the consent agreement,
or the proposed order, or to modify their
terms in any way.
II. The Complaint
This matter involves allegations that
Mastercard’s policy with respect to
payment tokens saved in ewallets
illegally inhibited merchants from being
able to route electronic debit
transactions to competing payment card
networks. The Commission’s complaint
includes the following allegations.
When a consumer presents a debit
card to a merchant to make a purchase,
the merchant or the merchant’s bank
(known as the ‘‘acquirer’’) uses a
payment card network (the ‘‘network’’)
to communicate with the bank or credit
union that issued the card (the
‘‘issuer’’). If the transaction is approved,
the network also handles the transfer of
funds. The selection of a network to
process a transaction is known as
‘‘routing.’’
Debit transactions can be ‘‘cardpresent’’ (e.g., where the cardholder
presents their debit card to a merchant
in person) or ‘‘card-not-present’’ (e.g.,
where the cardholder is not physically
present with the merchant, as in
ecommerce transactions made online or
through an application on a mobile
device). The volume of card-not-present
ecommerce transactions has grown
significantly in recent years, including
for debit cards used in ewallets such as
Apple Pay, Google Pay, and Samsung
Wallet.
When a cardholder loads a debit card
into an ewallet, the debit card is
‘‘tokenized,’’ meaning the primary
account number (‘‘PAN’’) printed on the
card is replaced with a different
number—the ‘‘token’’—to protect the
PAN during certain stages of a debit
transaction. The token service provider
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(‘‘TSP’’) that generates the token also
maintains a ‘‘token vault’’ that stores the
PAN corresponding to each token.
When a cardholder initiates a debit
transaction using an ewallet, the
merchant receives only the token, and
not the PAN. The merchant sends this
token to its acquirer, which sends the
token to a network for processing. For
the transaction to proceed, the TSP must
‘‘detokenize’’ the token for the network,
which includes converting the token to
its associated PAN stored in the token
vault.
Mastercard’s rules require that a
Mastercard-branded debit card that is
loaded into an ewallet be tokenized.
Mastercard is also the TSP for nearly all
Mastercard-branded debit cards used in
ewallets. When an ewallet transaction
using a Mastercard-branded debit card
is routed to Mastercard, Mastercard thus
can perform the detokenization and
process the transaction. Competing
payment card networks, however, do
not have access to Mastercard’s token
vault. To route a Mastercard-branded
tokenized transaction to a competing
network, a merchant’s acquirer or the
competing network therefore must ask
Mastercard to detokenize the token.
Merchants are thus dependent on
Mastercard’s detokenization to route
ewallet transactions using Mastercardbranded debit cards to competing
networks.
Mastercard’s ewallet token policy
leverages tokens to protect its card-notpresent ecommerce revenue by
inhibiting merchants’ ability to route
such transactions to competing
networks. For card-present debit
transactions using an ewallet—which
occur when a cardholder makes a
purchase in-store by holding their
mobile phone with an ewallet
application to a merchant’s terminal—
Mastercard will detokenize so that
merchants may route the transactions to
competing networks. In this scenario,
the merchant’s acquirer or competing
network will ‘‘call out’’ to Mastercard’s
token vault, which will provide the
PAN associated with the token.
In contrast, Mastercard will not
detokenize for card-not-present
(ecommerce) debit transactions,
including those using an ewallet. Under
Mastercard’s policy, there is no process
by which a merchant’s acquirer or a
competing network can call out to
Mastercard’s token vault and obtain the
PAN associated with an ewallet token
used in a card-not-present debit
transaction, as it can in a card-present
transaction. Thus, when a Mastercardbranded card is used in an ewallet for
a card-not-present debit transaction, that
transaction must be routed over the
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Mastercard network, and merchants are
unable to route transactions to
competing networks. Indeed,
Mastercard requires, and affirmatively
tells merchants that it requires, that
merchants route card-not-present
ewallet transactions using Mastercardbranded debit cards to the Mastercard
network.
II. Legal Analysis
Mastercard’s ewallet token policy
inhibits merchant routing choice in
violation of the Durbin Amendment, 15
U.S.C. 1693o–2(b)(1)(B), and its
implementing regulation, Regulation II,
12 CFR 235.7(b). As part of the DoddFrank Wall Street Reform and Consumer
Protection Act of 2010, Congress
amended the Electronic Funds Transfer
Act (‘‘EFTA’’) to add Section 920,
colloquially known as the Durbin
Amendment.1 The Durbin Amendment
instructed the Federal Reserve Board to
promulgate implementing regulations,
resulting in the publication of
Regulation II in July 2011.2 The Durbin
Amendment and Regulation II were
adopted to address concerns about the
lack of competition in debit card
processing and associated high
processing fees—and they embody the
principle that merchants must have the
opportunity to choose between at least
two unaffiliated networks to process
debit transactions.
The Durbin Amendment and
Regulation II contain two sets of
prohibitions designed to promote
merchant and consumer savings
associated with processing debit
transactions. First, they prohibit
network exclusivity by (a) prohibiting a
debit card issuer or payment card
network from directly or indirectly
restricting the number of networks on
which a debit transaction can be
processed to less than two unaffiliated
networks, (b) requiring that a debit card
issuer enable payment card networks
that satisfy certain minimum standards,
and (c) prohibiting a payment card
network from limiting an issuer’s ability
to contract with any other network.3
Second, they prohibit an issuer or
payment card network from directly or
indirectly inhibiting a merchant’s ability
to choose which of the networks
enabled for the debit card is used to
process a given transaction.4
1 Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law 111–203 1075 (July 21,
2010) (codified at 15 U.S.C. 1693o–2).
2 Debit Card Interchange Fees and Routing; Final
Rule, 76 FR 43394 (July 20, 2011) (codified at 12
CFR 235.1 et seq.).
3 15 U.S.C. 1693o–2(b)(1)(A); 12 CFR 235.7(a).
4 15 U.S.C. 1693o–2(b)(1)(B); 12 CFR 235.7(b).
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Violations of EFTA provisions, like
the Durbin Amendment, are strict
liability offenses.5 Accordingly, a
prospective defendant incurs civil
liability merely from its violation of the
Durbin Amendment—a showing of
scienter, actual harm, or anticompetitive
effects is not necessary to establish a
violation.6
For purposes of the Durbin
Amendment and Regulation II, a ‘‘debit
card’’ includes more than the physical
piece of plastic found in a cardholder’s
wallet. Under both, a debit card is ‘‘any
card, or other payment code or device,
issued or approved for use through a
payment card network to debit an
account, regardless of whether
authorization is based on signature,
personal identification number (PIN), or
other means, and regardless of whether
the issuer holds the account.’’ 7 Ewallet
tokens are payment codes stored inside
an ewallet and used through a payment
card network to debit a cardholder’s
account; they are thus debit cards
governed by the Durbin Amendment
and Regulation II.
Mastercard’s ewallet token policy
does not allow card-not-present debit
transactions using ewallet tokens (i.e.,
debit cards) to be routed to competing
debit networks. A merchant thus has
only one option: Mastercard’s network.
Mastercard’s policy thereby inhibits the
merchant’s ability to direct the routing
of card-not-present transactions using
ewallet tokens over the available
network of its choosing, in violation of
the Durbin Amendment and Regulation
II.
Even if, for the sake of argument, an
ewallet token is characterized not as a
debit card but as a means of access to
the underlying PAN, Mastercard still
unlawfully inhibits merchant routing
choice with respect to card-not-present
5 See, e.g., Clemmer v. Key Bank Nat’l Ass’n, 539
F.3d 349, 355 (6th Cir. 2008) (recognizing an EFTA
regulation imposes a strict liability standard); Burns
v. First Am. Bank, 2006 WL 3754820, at *6 (N.D.
Ill. Dec. 19, 2006) (‘‘EFTA is a strict liability
statute.’’).
6 See Bisbey v. D.C. Nat’l Bank, 793 F.2d 315,
318–19 (D.C. Cir. 1986) (holding EFTA does not
require proof of actual injury); FTC v. PayDay Fin.
LLC, 989 F. Supp. 2d 799, 811–13 (D.S.D. 2013)
(granting summary judgment to the FTC on
violations of EFTA and Regulation E after rejecting
justifications not explicitly contemplated by the
regulation’s language); Cobb v. PayLease LLC, 34 F.
Supp. 3d 976, 984 (D. Minn. 2014) (‘‘[E]ven where
a plaintiff did not suffer damages under the plain
terms of the Act, civil liability attaches to all
failures of compliance with respect to any provision
of the Act.’’) (internal quotation marks and citation
omitted, emphases in original); Burns, 2006 WL
3754820, at *6 (‘‘[A]gain, no necessary scienter . . .
Nor must a plaintiff seeking statutory damages
prove that he suffered actual damages as a result of
a defendant’s conduct.’’).
7 12 CFR 235.2(f)(1) (emphasis added); 15 U.S.C.
1693o–2(c)(2).
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ewallet transactions. Mastercard
requires that all Mastercard-branded
debit cards loaded into ewallets be
tokenized. And, in fact, nearly all such
cards are tokenized by Mastercard—via
decisions in which merchants have no
say. Because Mastercard tokenizes these
cards and then withholds
detokenization, card-not-present ewallet
transactions are not routable to
competing networks—these networks
are unable to process the transactions
without the corresponding PANs.
Mastercard thereby inhibits merchant
routing choice by employing a
technology that compels merchants to
route transactions over Mastercard’s
network.
Additionally, Mastercard’s
agreements with ewallet providers
require those providers to inform
merchants that, by accepting card-notpresent transactions through ewallets,
merchants agree that transactions made
with Mastercard-branded debit cards
will be routed to Mastercard. Mastercard
thereby inhibits merchant routing
choice by contract.
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III. Proposed Order
The proposed order seeks to remedy
Mastercard’s illegal conduct by
requiring Mastercard to provide PANs
so that merchants may route tokenized
transactions using Mastercard-branded
debit cards to the available network of
their choosing. Under the proposed
order, Mastercard must also refrain from
interfering with the ability of other
persons to serve as TSPs, and it must
not take other actions to inhibit
merchant routing choice in violation of
Regulation II, 12 CFR 235.7(b).
Section I of the proposed order
defines the key terms used in the order.
Section II of the proposed order
addresses the core of Mastercard’s
conduct. Paragraph II.A. requires
Mastercard, upon request by an
authorized acquirer, authorized
network, or other authorized person in
receipt of a Mastercard token, to provide
the PAN associated with the token for
purposes of routing the transaction to
any competing network enabled by the
issuer. This provision is designed to
restore and preserve merchant routing
choice so that merchants may accept
ewallet tokens without being forced to
route all such transactions over
Mastercard’s network. The order
specifically requires that Mastercard
provide PANs for ecommerce, card-notpresent debit transactions in the
ordinary course, including in a manner
consistent with the timeliness with
which Mastercard provides PANs for
card-present transactions and without
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requiring consideration for making the
PANs available.
Paragraph II.B. prevents Mastercard
from prohibiting or inhibiting any
person’s efforts to serve as a TSP or
provision payment tokens for
Mastercard-branded debit cards. This
paragraph prevents Mastercard from
taking other actions that would inhibit
merchant routing choice in the context
of tokenized transactions.
Paragraph II.C. prohibits Mastercard
from, directly or indirectly by contract,
requirement, condition, penalty, or
otherwise, inhibiting the ability of any
person that accepts or honors debit
cards for payments to choose to route
transactions over any network that may
process such transactions, in violation
of Regulation II, 12 CFR 235.7(b). This
paragraph prevents Mastercard from
taking other actions, even outside the
context of tokenized transactions, that
would inhibit merchant routing choice.
The proposed order also contains
provisions designed to ensure
Mastercard’s compliance with the order.
Section III requires Mastercard to
provide notice to competing networks,
acquirers, and issuers via an ad hoc
Mastercard bulletin using language
found in the proposed order’s Appendix
A. Section IV requires Mastercard to
provide prior notice to the Commission
before the commercial launch of any
new debit product that requires
merchants to route debit transactions to
Mastercard’s network. Sections V
through VII contain provisions
regarding compliance reports to be filed
by Mastercard, notice of changes in
Mastercard, and access to Mastercard
documents and personnel.
As stated in Section VIII, the
proposed order’s purpose is to remedy
Mastercard’s alleged violation of the
Durbin Amendment, EFTA Section
920(b)(1), 15 U.S.C. 1693o–2(b)(1), as set
forth by the Commission in its
complaint. Section IX provides that the
order will terminate 10 years from the
date it is issued. However, if the United
States or Commission files a complaint
in federal court alleging a violation of
the proposed order (and the court does
not dismiss the complaint or rule that
there was no violation), then the order
will terminate 10 years from the date
such complaint is filed.
By direction of the Commission.
April J. Tabor,
Secretary.
[FR Doc. 2023–00559 Filed 1–12–23; 8:45 am]
BILLING CODE 6750–01–P
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DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Administration for Community Living
Statement of Delegation of Authority
Notice is hereby given that I have
delegated to the Administrator of the
Administration for Community Living
the authorities vested in the Secretary of
Health and Human Services under the
Rehabilitation Act of 1973 as amended
in the Workforce Innovation and
Opportunity Act (Pub. L. 113–128), to
Chair the Interagency Committee on
Disability Research for the purposes of
promoting the coordination and
collaboration of federal disability and
rehabilitation research and related
activities as stipulated in the ICDR’s
statutory mission.
This authority may be redelegated to
the Director of the National Institute on
Disability, Independent Living and
Rehabilitation Research. Exercise of this
authority shall be in accordance with
established policies, procedures,
guidelines, and regulations as
prescribed by the Secretary. The
Secretary retains the authority to submit
reports to Congress and promulgate
regulations.
This delegation is effective
immediately. I hereby affirm and ratify
any actions taken by subordinates that
involved the exercise of the authorities
delegated herein prior to the effective
date of the delegation.
Dated: January 10, 2023.
Xavier Becerra,
Secretary.
[FR Doc. 2023–00574 Filed 1–12–23; 8:45 am]
BILLING CODE 4154–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2007–D–0201]
Dosage and Administration Section of
Labeling for Human Prescription Drug
and Biological Products—Content and
Format; Draft Guidance for Industry;
Availability
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice of availability.
The Food and Drug
Administration (FDA, Agency, or we) is
announcing the availability of a draft
guidance for industry entitled ‘‘Dosage
and Administration Section of Labeling
for Human Prescription Drug and
Biological Products—Content and
SUMMARY:
E:\FR\FM\13JAN1.SGM
13JAN1
Agencies
[Federal Register Volume 88, Number 9 (Friday, January 13, 2023)]
[Notices]
[Pages 2357-2360]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-00559]
=======================================================================
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FEDERAL TRADE COMMISSION
[File No. 201 0011]
Mastercard Incorporated; Analysis of Agreement Containing Consent
Orders To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement; request for comment.
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SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair methods of competition.
The attached Analysis of Proposed Consent Orders to Aid Public Comment
describes both the allegations in the complaint and the terms of the
consent orders--embodied in the consent agreement--that would settle
these allegations.
DATES: Comments must be received on or before February 13, 2023.
ADDRESSES: Interested parties may file comments online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Please write: ``Mastercard
Incorporated; File No. 201 0011'' on your comment and file your comment
online at https://www.regulations.gov by following the instructions on
the web-based form. If you prefer to file your comment on paper, please
mail your comment to the following address: Federal Trade Commission,
Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610
(Annex Q), Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Christina Brown (202-326-2125), Bureau
of Competition, Federal Trade Commission, 400 7th Street SW,
Washington, DC 20024.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade
[[Page 2358]]
Commission Act, 15 U.S.C. 46(f), and FTC Rule Sec. 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing a consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of 30 days. The following
Analysis of Agreement Containing Consent Orders to Aid Public Comment
describes the terms of the consent agreement and the allegations in the
complaint. An electronic copy of the full text of the consent agreement
package can be obtained from the FTC website at this web address:
https://www.ftc.gov/news-events/commission-actions.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before February 13,
2023. Write ``Mastercard Incorporated; File No. 201 0011'' on your
comment. Your comment--including your name and your state--will be
placed on the public record of this proceeding, including, to the
extent practicable, on the https://www.regulations.gov website.
Due to protective actions in response to the COVID-19 pandemic and
the agency's heightened security screening, postal mail addressed to
the Commission will be delayed. We strongly encourage you to submit
your comments online through the https://www.regulations.gov website.
If you prefer to file your comment on paper, write ``Mastercard
Incorporated; File No. 201 0011'' on your comment and on the envelope,
and mail your comment to the following address: Federal Trade
Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite
CC-5610 (Annex Q), Washington, DC 20580.
Because your comment will be placed on the publicly accessible
website at https://www.regulations.gov, you are solely responsible for
making sure your comment does not include any sensitive or confidential
information. In particular, your comment should not include sensitive
personal information, such as your or anyone else's Social Security
number; date of birth; driver's license number or other state
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure your comment does not include
sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule Sec.
4.10(a)(2), 16 CFR 4.10(a)(2)--including competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule Sec. 4.9(c). In
particular, the written request for confidential treatment that
accompanies the comment must include the factual and legal basis for
the request and must identify the specific portions of the comment to
be withheld from the public record. See FTC Rule Sec. 4.9(c). Your
comment will be kept confidential only if the General Counsel grants
your request in accordance with the law and the public interest. Once
your comment has been posted on https://www.regulations.gov--as legally
required by FTC Rule Sec. 4.9(b)--we cannot redact or remove your
comment from that website, unless you submit a confidentiality request
that meets the requirements for such treatment under FTC Rule Sec.
4.9(c), and the General Counsel grants that request.
Visit the FTC website at https://www.ftc.gov to read this document
and the news release describing this matter. The FTC Act and other laws
the Commission administers permit the collection of public comments to
consider and use in this proceeding, as appropriate. The Commission
will consider all timely and responsive public comments it receives on
or before February 13, 2023. For information on the Commission's
privacy policy, including routine uses permitted by the Privacy Act,
see https://www.ftc.gov/site-information/privacy-policy.
Analysis of Agreement Containing Consent Orders To Aid Public Comment
I. Introduction
The Federal Trade Commission has accepted, subject to final
approval, a consent agreement with Mastercard Incorporated
(``Mastercard''). Mastercard operates a payment card network over which
merchants can route debit transactions. Mastercard also operates as a
token service provider that generates payment tokens for Mastercard-
branded debit cards, including tokens saved in ewallet applications on
mobile devices.
The consent agreement contains a proposed order addressing
allegations in the proposed complaint that Mastercard has inhibited
merchants' ability to route electronic debit transactions in violation
of the Durbin Amendment, 15 U.S.C. 1693o-2(b)(1)(B), and Regulation II,
12 CFR 235.7(b), and therefore also in violation of the Federal Trade
Commission Act, 15 U.S.C. 41 et seq. The proposed order has been placed
on the public record for 30 days to receive comments from interested
persons. Comments received during this period will become part of the
public record. After 30 days, the Commission will again review the
consent agreement and the comments received and will decide whether it
should withdraw from the consent agreement and take appropriate action
or make the proposed order final.
The purpose of this analysis is to facilitate public comment on the
proposed order. It is not intended to constitute an official
interpretation of the complaint, the consent agreement, or the proposed
order, or to modify their terms in any way.
II. The Complaint
This matter involves allegations that Mastercard's policy with
respect to payment tokens saved in ewallets illegally inhibited
merchants from being able to route electronic debit transactions to
competing payment card networks. The Commission's complaint includes
the following allegations.
When a consumer presents a debit card to a merchant to make a
purchase, the merchant or the merchant's bank (known as the
``acquirer'') uses a payment card network (the ``network'') to
communicate with the bank or credit union that issued the card (the
``issuer''). If the transaction is approved, the network also handles
the transfer of funds. The selection of a network to process a
transaction is known as ``routing.''
Debit transactions can be ``card-present'' (e.g., where the
cardholder presents their debit card to a merchant in person) or
``card-not-present'' (e.g., where the cardholder is not physically
present with the merchant, as in ecommerce transactions made online or
through an application on a mobile device). The volume of card-not-
present ecommerce transactions has grown significantly in recent years,
including for debit cards used in ewallets such as Apple Pay, Google
Pay, and Samsung Wallet.
When a cardholder loads a debit card into an ewallet, the debit
card is ``tokenized,'' meaning the primary account number (``PAN'')
printed on the card is replaced with a different number--the
``token''--to protect the PAN during certain stages of a debit
transaction. The token service provider
[[Page 2359]]
(``TSP'') that generates the token also maintains a ``token vault''
that stores the PAN corresponding to each token. When a cardholder
initiates a debit transaction using an ewallet, the merchant receives
only the token, and not the PAN. The merchant sends this token to its
acquirer, which sends the token to a network for processing. For the
transaction to proceed, the TSP must ``detokenize'' the token for the
network, which includes converting the token to its associated PAN
stored in the token vault.
Mastercard's rules require that a Mastercard-branded debit card
that is loaded into an ewallet be tokenized. Mastercard is also the TSP
for nearly all Mastercard-branded debit cards used in ewallets. When an
ewallet transaction using a Mastercard-branded debit card is routed to
Mastercard, Mastercard thus can perform the detokenization and process
the transaction. Competing payment card networks, however, do not have
access to Mastercard's token vault. To route a Mastercard-branded
tokenized transaction to a competing network, a merchant's acquirer or
the competing network therefore must ask Mastercard to detokenize the
token. Merchants are thus dependent on Mastercard's detokenization to
route ewallet transactions using Mastercard-branded debit cards to
competing networks.
Mastercard's ewallet token policy leverages tokens to protect its
card-not-present ecommerce revenue by inhibiting merchants' ability to
route such transactions to competing networks. For card-present debit
transactions using an ewallet--which occur when a cardholder makes a
purchase in-store by holding their mobile phone with an ewallet
application to a merchant's terminal--Mastercard will detokenize so
that merchants may route the transactions to competing networks. In
this scenario, the merchant's acquirer or competing network will ``call
out'' to Mastercard's token vault, which will provide the PAN
associated with the token.
In contrast, Mastercard will not detokenize for card-not-present
(ecommerce) debit transactions, including those using an ewallet. Under
Mastercard's policy, there is no process by which a merchant's acquirer
or a competing network can call out to Mastercard's token vault and
obtain the PAN associated with an ewallet token used in a card-not-
present debit transaction, as it can in a card-present transaction.
Thus, when a Mastercard-branded card is used in an ewallet for a card-
not-present debit transaction, that transaction must be routed over the
Mastercard network, and merchants are unable to route transactions to
competing networks. Indeed, Mastercard requires, and affirmatively
tells merchants that it requires, that merchants route card-not-present
ewallet transactions using Mastercard-branded debit cards to the
Mastercard network.
II. Legal Analysis
Mastercard's ewallet token policy inhibits merchant routing choice
in violation of the Durbin Amendment, 15 U.S.C. 1693o-2(b)(1)(B), and
its implementing regulation, Regulation II, 12 CFR 235.7(b). As part of
the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010,
Congress amended the Electronic Funds Transfer Act (``EFTA'') to add
Section 920, colloquially known as the Durbin Amendment.\1\ The Durbin
Amendment instructed the Federal Reserve Board to promulgate
implementing regulations, resulting in the publication of Regulation II
in July 2011.\2\ The Durbin Amendment and Regulation II were adopted to
address concerns about the lack of competition in debit card processing
and associated high processing fees--and they embody the principle that
merchants must have the opportunity to choose between at least two
unaffiliated networks to process debit transactions.
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\1\ Dodd-Frank Wall Street Reform and Consumer Protection Act,
Public Law 111-203 1075 (July 21, 2010) (codified at 15 U.S.C.
1693o-2).
\2\ Debit Card Interchange Fees and Routing; Final Rule, 76 FR
43394 (July 20, 2011) (codified at 12 CFR 235.1 et seq.).
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The Durbin Amendment and Regulation II contain two sets of
prohibitions designed to promote merchant and consumer savings
associated with processing debit transactions. First, they prohibit
network exclusivity by (a) prohibiting a debit card issuer or payment
card network from directly or indirectly restricting the number of
networks on which a debit transaction can be processed to less than two
unaffiliated networks, (b) requiring that a debit card issuer enable
payment card networks that satisfy certain minimum standards, and (c)
prohibiting a payment card network from limiting an issuer's ability to
contract with any other network.\3\ Second, they prohibit an issuer or
payment card network from directly or indirectly inhibiting a
merchant's ability to choose which of the networks enabled for the
debit card is used to process a given transaction.\4\
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\3\ 15 U.S.C. 1693o-2(b)(1)(A); 12 CFR 235.7(a).
\4\ 15 U.S.C. 1693o-2(b)(1)(B); 12 CFR 235.7(b).
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Violations of EFTA provisions, like the Durbin Amendment, are
strict liability offenses.\5\ Accordingly, a prospective defendant
incurs civil liability merely from its violation of the Durbin
Amendment--a showing of scienter, actual harm, or anticompetitive
effects is not necessary to establish a violation.\6\
---------------------------------------------------------------------------
\5\ See, e.g., Clemmer v. Key Bank Nat'l Ass'n, 539 F.3d 349,
355 (6th Cir. 2008) (recognizing an EFTA regulation imposes a strict
liability standard); Burns v. First Am. Bank, 2006 WL 3754820, at *6
(N.D. Ill. Dec. 19, 2006) (``EFTA is a strict liability statute.'').
\6\ See Bisbey v. D.C. Nat'l Bank, 793 F.2d 315, 318-19 (D.C.
Cir. 1986) (holding EFTA does not require proof of actual injury);
FTC v. PayDay Fin. LLC, 989 F. Supp. 2d 799, 811-13 (D.S.D. 2013)
(granting summary judgment to the FTC on violations of EFTA and
Regulation E after rejecting justifications not explicitly
contemplated by the regulation's language); Cobb v. PayLease LLC, 34
F. Supp. 3d 976, 984 (D. Minn. 2014) (``[E]ven where a plaintiff did
not suffer damages under the plain terms of the Act, civil liability
attaches to all failures of compliance with respect to any provision
of the Act.'') (internal quotation marks and citation omitted,
emphases in original); Burns, 2006 WL 3754820, at *6 (``[A]gain, no
necessary scienter . . . Nor must a plaintiff seeking statutory
damages prove that he suffered actual damages as a result of a
defendant's conduct.'').
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For purposes of the Durbin Amendment and Regulation II, a ``debit
card'' includes more than the physical piece of plastic found in a
cardholder's wallet. Under both, a debit card is ``any card, or other
payment code or device, issued or approved for use through a payment
card network to debit an account, regardless of whether authorization
is based on signature, personal identification number (PIN), or other
means, and regardless of whether the issuer holds the account.'' \7\
Ewallet tokens are payment codes stored inside an ewallet and used
through a payment card network to debit a cardholder's account; they
are thus debit cards governed by the Durbin Amendment and Regulation
II.
---------------------------------------------------------------------------
\7\ 12 CFR 235.2(f)(1) (emphasis added); 15 U.S.C. 1693o-
2(c)(2).
---------------------------------------------------------------------------
Mastercard's ewallet token policy does not allow card-not-present
debit transactions using ewallet tokens (i.e., debit cards) to be
routed to competing debit networks. A merchant thus has only one
option: Mastercard's network. Mastercard's policy thereby inhibits the
merchant's ability to direct the routing of card-not-present
transactions using ewallet tokens over the available network of its
choosing, in violation of the Durbin Amendment and Regulation II.
Even if, for the sake of argument, an ewallet token is
characterized not as a debit card but as a means of access to the
underlying PAN, Mastercard still unlawfully inhibits merchant routing
choice with respect to card-not-present
[[Page 2360]]
ewallet transactions. Mastercard requires that all Mastercard-branded
debit cards loaded into ewallets be tokenized. And, in fact, nearly all
such cards are tokenized by Mastercard--via decisions in which
merchants have no say. Because Mastercard tokenizes these cards and
then withholds detokenization, card-not-present ewallet transactions
are not routable to competing networks--these networks are unable to
process the transactions without the corresponding PANs. Mastercard
thereby inhibits merchant routing choice by employing a technology that
compels merchants to route transactions over Mastercard's network.
Additionally, Mastercard's agreements with ewallet providers
require those providers to inform merchants that, by accepting card-
not-present transactions through ewallets, merchants agree that
transactions made with Mastercard-branded debit cards will be routed to
Mastercard. Mastercard thereby inhibits merchant routing choice by
contract.
III. Proposed Order
The proposed order seeks to remedy Mastercard's illegal conduct by
requiring Mastercard to provide PANs so that merchants may route
tokenized transactions using Mastercard-branded debit cards to the
available network of their choosing. Under the proposed order,
Mastercard must also refrain from interfering with the ability of other
persons to serve as TSPs, and it must not take other actions to inhibit
merchant routing choice in violation of Regulation II, 12 CFR 235.7(b).
Section I of the proposed order defines the key terms used in the
order.
Section II of the proposed order addresses the core of Mastercard's
conduct. Paragraph II.A. requires Mastercard, upon request by an
authorized acquirer, authorized network, or other authorized person in
receipt of a Mastercard token, to provide the PAN associated with the
token for purposes of routing the transaction to any competing network
enabled by the issuer. This provision is designed to restore and
preserve merchant routing choice so that merchants may accept ewallet
tokens without being forced to route all such transactions over
Mastercard's network. The order specifically requires that Mastercard
provide PANs for ecommerce, card-not-present debit transactions in the
ordinary course, including in a manner consistent with the timeliness
with which Mastercard provides PANs for card-present transactions and
without requiring consideration for making the PANs available.
Paragraph II.B. prevents Mastercard from prohibiting or inhibiting
any person's efforts to serve as a TSP or provision payment tokens for
Mastercard-branded debit cards. This paragraph prevents Mastercard from
taking other actions that would inhibit merchant routing choice in the
context of tokenized transactions.
Paragraph II.C. prohibits Mastercard from, directly or indirectly
by contract, requirement, condition, penalty, or otherwise, inhibiting
the ability of any person that accepts or honors debit cards for
payments to choose to route transactions over any network that may
process such transactions, in violation of Regulation II, 12 CFR
235.7(b). This paragraph prevents Mastercard from taking other actions,
even outside the context of tokenized transactions, that would inhibit
merchant routing choice.
The proposed order also contains provisions designed to ensure
Mastercard's compliance with the order. Section III requires Mastercard
to provide notice to competing networks, acquirers, and issuers via an
ad hoc Mastercard bulletin using language found in the proposed order's
Appendix A. Section IV requires Mastercard to provide prior notice to
the Commission before the commercial launch of any new debit product
that requires merchants to route debit transactions to Mastercard's
network. Sections V through VII contain provisions regarding compliance
reports to be filed by Mastercard, notice of changes in Mastercard, and
access to Mastercard documents and personnel.
As stated in Section VIII, the proposed order's purpose is to
remedy Mastercard's alleged violation of the Durbin Amendment, EFTA
Section 920(b)(1), 15 U.S.C. 1693o-2(b)(1), as set forth by the
Commission in its complaint. Section IX provides that the order will
terminate 10 years from the date it is issued. However, if the United
States or Commission files a complaint in federal court alleging a
violation of the proposed order (and the court does not dismiss the
complaint or rule that there was no violation), then the order will
terminate 10 years from the date such complaint is filed.
By direction of the Commission.
April J. Tabor,
Secretary.
[FR Doc. 2023-00559 Filed 1-12-23; 8:45 am]
BILLING CODE 6750-01-P