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The billing company has always been the merchant in the eyes of MC and Visa, they are the account holder.
If they go over the limits they are fined, nothing has changed with MC really except for this whacked out idea they have of brand identity and how to promote it. I'd imagine some of the non adult companies are screaming blood murder over all this since there are some of them affected as well.
Visa's now looking at everyone on an individual basis but having an IPSP in front of you when they are taking aim is still worth the money that you spend on it, imo.
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