Is This Compliance Release Item Mandatory, Optional, or Informational?
Every map has a legend. A book has a table of contents. Operations bulletins and release documents have a section that identifies:
The type of document: Is this an operational or release related change,
The audience: Does this impact issuers, acquirers, digital partners, or other downstream participants?
Brand or network impacted: Does this affect single message, dual message, batch, tokenization? (Don’t know what these terms mean? Watch my video - Single Message, Dual Message – Say What?
Region: What countries are impacted by this change?
Release: Which release will contain this change (if it is a release related change)?
Action Indicator: Is this mandatory, optional, or informational?
The entity managing the release is pretty good at identifying all but the last of these parameters. The action indicator is a bit problematic.
First of all, the release entity (for example, the payment network) is identifying the action indicator from their perspective. If the document has been created by a downstream partner, like an issuing or acquiring processor, the indicator may show their perspective, or they may just be relaying the perspective of the payment network.
Let’s look at the Action Indicator categories:
Mandatory: The release entity feels all their target audience (those identified in the “audience” section) MUST comply with this requirement. Often, they are right – sometimes they are wrong. I have seen mandates on tokenization that forgot to say, “mandatory only if you participate in tokenization”.
Quick note: You will also want to watch for any compliance program following the release of mandatory release items – non-compliance on mandatory items can cost you money!Optional: This may be the trickiest category. The release entity is actually saying this is not required for some – but they may be saying it is mandatory for others. Our tokenization mandate item is a good example. It should be listed as “optional”. This would indicate anyone NOT participating in tokenization doesn’t need to do this. However, it also indicates that, for anyone participating in tokenization, this release item is MANDATORY.
Informational: These items are important if you want to be a strategic Compliance Team and not just a tactical one. Informational simply means “there is nothing for you to do – at this point”. These items need to be watched by a good Compliance Team for two reasons:
They MAY have unintended impact during the release (and I have seen THAT happen!),
They may be groundwork for future new products. If you want to be ahead of the curve, you will want to know what this optional release item is leading towards.