Epoch

EPOCH wants to quote VISA OP Regs and Principles in order to clarify previous posts regarding new VISA Regs.

Most of these issues specifically address erroneous information provided by others on previous threads.

Cross Border Acquiring Issues

4.2.D.5 Jurisdiction

4.2.D.5.a - An acquirer must ensure that its IPSP does not contract with a prospective Sponsored Merchant outside the Acquirers
jurisdiction, as specified in

- Section 2.10 Visa International By-Laws and Regional Board Delegations and
- Section 4.2.B.1b VISA USA Inc. Operating Regulations

4.2.D.5.b - An Internet Payment Service Provider may have contracts with multiple Acquirers, but may only submit Transactions to an Acquirer
from Sponsored Merchants within that Acquirer's jurisdiction.

How does Globill and any other IPSP outside of the USA intend on circumventing the above OP Regs? How as a US based webmaster do
you honestly believe that you can process through an IPSP outside of the USA? The simple answer is you can't. If you do you will
get caught and terminated as a VISA merchant.

Also, You can only register a URL with an IPSP(s) in one region, you cannot submit transactions for that URL through
a US Based IPSP and also through a non-US based IPSP, when you are caught you will be terminated from the VISA system as well.

What this means is, if you desire to have a backup processor then the backup processor must also be located in the same region.
That means in the USA, (IBill, CCBill, EPOCH/Paycom, WSB) - these are the only registered IPSP's that we are currently aware of
in the USA (however there may be others that we are not aware of at this point)

Issues regarding Reporting and Registration for VISA International Sponsored Merchants

Operating Principles for VISA International

Operating Principle 1.6.

The International Operating Principles for IPSP's contain language, which states
that the IPSP must provide comprehensive lists (including names of principles, country
of domicile, etc.) of all its Sponsored Merchants and transaction level detail reports
to its Acquirer and upon request to VISA. Acquirers and IPSP's must establish procedures
to ensure Terminated Merchants are not permitted to be Sponsored Merchants.

**So if you are outside of the USA you will still have to answer to VISA in terms
of reporting and registration. Whether you call it being registered as they do in the
VISA USA region, "or required to provide lists" in every other region it means the same
thing. The only difference is there is currently no fee for "registration."

Operating Principle 1.7.

The IPSP must not sign any Sponsored Merchants outside the Acquirers jurisdiction.

**Again, if you reside in the USA you CANNOT be a Sponsored Merchant for an IPSP outside the USA.

Another principle states that "The acts, omissions, and circumstances of each Sponsored Merchant
shall be treated as the acts, omissions, and circumstances of the IPSP."

**ALL IPSP's are liable for the acts of ALL of its Sponsored Merchants.

So what does this all mean? Basically you cannot run nor hide from the new VISA rules. The only
benefit to circumventing these new rules is not having to pay $750.00 for registration.
You shouldn't even ask yourself "is $750.00 worth the risk of losing your ability to process credit card transactions?"

NEW EPOCH POLICY EFFECTIVE NOVEMBER 1, 2002 related to VISA Transactions

EPOCH WILL NOT process transactions for any Sponsored Merchants who processes transactions outside of their
registered jurisdiction, this means that if EPOCH registers you as a US Sponsored Merchant and ANY of your URLs
EVER process ANY transactions in another VISA region we will immediately terminate your account with EPOCH, terminate
all recurring billing, hold all processing proceeds and refer the URLs to VISA International for non-compliance. This
is an EPOCH policy designed to protect our business and our Sponsored Merchants ability to continue to process long
into the future.

Please understand that it potentially only takes one bad apple to spoil the entire barrel, for this reason EPOCH
will have a zero tolerance policy for violating VISA Regs. We understand that this is a tough stance however we
are fully aware of the consequences that entities will face if they in fact violate or attempt to circumvent these
new rules established by VISA.

Our long time valued customers understand that we are willing to forgo growth in our business in order to
maintain our current clients business operating ability. So if you are with EPOCH we trust you will stay, if
you are not with us we welcome you if you are willing to play by the rules.

Once again, if you are a US Sponsored Merchant you can have a backup processor which is also a US based IPSP
(i.e. IBill, CCBill, EPOCH/Paycom, WSB).

Please remember ALL IPSP's are responsible for the actions of ALL of it's Sponsored Merchants, thus the new policy.


CLAY
EPOCH