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Solutions for upcoming Mastercard recurring-charge requirements through OLX?

Erin Macleod

Hi all - with Mastercard introducing new requirements for communicating with recurring donors, is there anything currently in the works to make sure this is directly doable through OLX/RE?

The two requirements I'm thinking of specifically are:

1) Donors must receive a communication every time they are charged that shows the recent charge details and instructions on how to cancel / Donors whose charges fall more than six months apart must receive a reminder in advance. This seems like something you could set up a mailing for, but wondering if there is a built-in batch solution rather than having to design a new query/mailing combo that pulls against recent or upcoming charges.
2) When signing up for recurring giving, donors must see a clear summary of how much and how often they will be charged before the credit card is authorized. Right now when creating a recurring gift via an OLX form, the only info supplied is “Give [monthly] on [day 1 of each month]” and “Your first gift will occur on 4/1/2022”. Do OLX forms have the ability to generate a summary that shows both frequency and amount before the Donate button is clicked?

Interested to hear if other orgs have any clever uses for out-of-the-box RE/OLX solutions to ensure compliance!

Thanks,
Erin

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Comments

Dariel Dixon

@Erin Macleod I'm not familiar with these requirements. Do you have a link so I can learn more?

Erin Macleod

Dariel Dixon:
@Erin Macleod I'm not familiar with these requirements. Do you have a link so I can learn more?

@Dariel yes - here is a good overview:

Dariel Dixon

This is interesting @Erin Macleod. I am by no means a lawyer, and I didn't stay at a Holiday Inn Express last night, but this is quite ambiguous about these listings. It mentions subscription models and the like, which I would assume recurring gifts would be considered, but for many organizations, there is no benefit involved. Does this apply if you aren't selling a product with the subscription? Are NPOs included with this, or is there an exclusion if there is no product or membership? I would definitely run it past legal counsel to determine if your organization needs to comply. Now how to comply, well, that is a difficult solution. I am surprised that this hasn't come up before, as it appears that VISA has a similar mandate that has already gone into effect. I'll be following this closely, as I'm sure that many orgs will need to update their communication and policies regarding these changes.

Faith Murray

This is indeed an interesting policy change. @Crystal Bruce, could you pull in someone from Payment Services, who specializes in nonprofits, to provide guidance on this issue?

Faith Murray

In reading through this article a second time, I believe that OLX already covers some of the bases. But not all! Here's what I take away from it:

Prior to enrolling consumers in a subscription, merchants must, at the point of payment, disclose the subscription terms and obtain the customer's affirmative acceptance of the terms. OLX forms ask donors to enroll in recurring gifts by clicking the recurring option and tells [monthly] on [day 1 of each month]. Since the Donate button (acceptance) occurs on the same page as the terms (rather than a second page, link, or pop-up window), it satisfies the point-of-payment requirement.
Immediately following enrollment, merchants will need to send a confirmation of the consumer's enrollment by email or any other electronic method. This summary is provided in the automatic email receipt generated upon donation in OLX forms. The difficulty here is if you enroll a donor manually from a mailed-in credit card enrollment, and they don't provide an email address. Does this mean requiring email addresses before allowing someone to become a monthly donor?
This confirmation must include … clear instructions on how the consumer can cancel the subscription. This would be up to us, the nonprofit, to include in our email receipt verbiage!
After each billing for the subscription, merchants must send a receipt for the billing by email or any other electronic method … including clear instructions on how the consumer can cancel the subscription. This is doable through NXT, I believe, as you have the option to email gift receipts during batching. OLX itself has no function for this, making a problem for RE users not using NXT. Also, these rules don't provide the option for snail mail receipts, do they?
Merchants must provide an online or electronic cancellation method to subscribers. Could accomplish this with an email contact, Google form, or repurposed sign-up form. At present, however, OLX has no function to allow donors to control their gift records, as Luminate does.

Erin Macleod

I completely agree @Dariel Dixon - for a set of regulations aiming to reduce vagueness, it doesn't really provide hard specifics itself! The trouble I'm having in nailing down the precise requirements is compounded by the fact that I'm only able to find this info from secondary sources, not directly from Mastercard (our payment processor alerted us originally, and there are some “commentary” links like the below).

My take on this is that they do refer to “customers” and “payments” in the sense of providing a product/service, but there is also some language referring more broadly to “charges” and “billing” without reference to a product/service. I am also definitely not a lawyer and would be very happy to have our legal team interpret this differently, but my instinct is to be on the safe side and consider any kind of repeating charges as being subject to this (and as you've mentioned, this type of regulation is likely to become more robust in the near future anyways). It really seems like it's not causing much concern in the wider community, so crossing my fingers that it's not as imminent as it seems…

Crystal Bruce

Faith Murray:
This is indeed an interesting policy change. @Crystal Bruce, could you pull in someone from Payment Services, who specializes in nonprofits, to provide guidance on this issue?

Hi Faith! I've passed this along to the CM of OLX, Ray Bergman, who will surface this up through his team. Thanks!

Dariel Dixon

Erin Macleod:
I completely agree @Dariel Dixon - for a set of regulations aiming to reduce vagueness, it doesn't really provide hard specifics itself! The trouble I'm having in nailing down the precise requirements is compounded by the fact that I'm only able to find this info from secondary sources, not directly from Mastercard (our payment processor alerted us originally, and there are some “commentary” links like the below).
My take on this is that they do refer to “customers” and “payments” in the sense of providing a product/service, but there is also some language referring more broadly to “charges” and “billing” without reference to a product/service. I am also definitely not a lawyer and would be very happy to have our legal team interpret this differently, but my instinct is to be on the safe side and consider any kind of repeating charges as being subject to this (and as you've mentioned, this type of regulation is likely to become more robust in the near future anyways). It really seems like it's not causing much concern in the wider community, so crossing my fingers that it's not as imminent as it seems…

Your instincts on this are good @Erin Macleod. I think that bringing in the proper personnel and asking the right questions would be prudent. @Faith Murray does bring up good points, but the point about communicating with the customer before every charge would definitely be a new change to our processes. I'm keeping an eye out on this.

Faith Murray

Thanks so much, Crystal!

JoAnn Strommen

Recurring charges can be set up through NetCommunity as well so following with interest.

Sending notice in advance for annual credit card/direct debit charges was something I did for the very few at previous org. Have not initiated that procedure here and have run across several.

I passed on info to our CEO and CFO and asked if they thought we should have our legal counsel review. No response yet.

Shaun Porteous

Hello All,

Great discussion on this community post! I’m Shaun and I work as Senior Product Manager on Blackbaud Payment services. This thread was shared with me, and I wanted to provide a response relating directly to the Mastercard requirements for March 22.

I’ve provided an extract below directly form Mastercard relating to their requirements.

Mastercard Requirements

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Breakdown

An email confirmation – Acknowledgement email sent to donor at time of signup/enrolment to their recurring gift outlining the details of their recurring gift such as donation amount, frequency and cancel instructions.
Email receipt - A receipt is required after each debit of a recurring donation from a donor’s card and any receipts to donors or constituents to include verbiage on how to cancel recurring payments including a phone number or instructions (i.e. For more information on your recurring payment, including how to cancel, click here.)
Electronic cancelation – This term as confirmed by Mastercard directly as, the requirement that there should be somewhere on your organisations site that explains what a recurring donor has to do to cancel (i.e. call a number, fill out an electronic form, etc.) and electronic notifications (acknowledgment emails & receipts) should either include the phone number or have a link to that cancelation page on the organisations site (i.e. For more information on your subscription, including how to cancel, click here.)

We have published a knowledge base article that shares some information also - https://kb.blackbaud.com/knowledgebase/articles/Article/198858

Recommendation note, not a requirement – the purpose of Mastercard’s requirements are intended to reduce complaints and chargebacks and drive a more positive customer experience for customers/donors who might not understand they were enrolled in an automatic renewal subscription or negative option program (or who do not understand the billing terms), forgot they enrolled, or have difficulty cancelling their subscriptions. Therefore, this acts more as a best practice and recommendation would be to roll out the Mastercard requirements as best practice for all your recurring donors that pay with payment method of credit card (i.e., Visa, AMEX, etc. ).

Shaun Porteous

Senior Product Manager, Payments

RDO

Dina Rieman

Thanks Shaun for the nice outline of this change with Mastercard. Just a quick question - the KB link attached to your post references these changes are for Canada. Can you confirm if this change is for all or just Canada? Thank you.

Shaun Porteous

Hi Dina, The Mastercard change is for ALL. I'll have the team update the KB article.

JoAnn Strommen

So, do VISA, Discover and AMX have similar requirements?

Faith Murray

One of my questions still is: how do we implement this with donors who have no email address on file (those who sent in monthly donor enrollment by mail)? Fully a quarter of all our recurring donors meet this situation. Also, everything in this requirement seems to specify electronic receipts, but most of our receipts are done through snail mail.

My Director and I talked it over and thought a special mailing might be in order, informing donors of the new requirements and asking them to either provide an email address or else confirm opt out of digital receipt notifications (and then document that in their records).

Shaun Porteous

Hi Faith, For donors that have no email address the direction from Mastercard in their FAQs (shich I've pasted below) recommends the charity should take every effort to notify the cardholder by other means.

Extract from Mastercard's FAQs

17. For the electronic notifications required for subscription merchants, what happens if the cardholder does not have an email address? The merchant should make every effort to notify the cardholder by other means

Thanks,

Shaun

Danielle Lifshitz

Thanks for this. So this is just a recommendation from Mastercard and not a requirement? Does it still apply if the recurring gift is simply a monthly donation and not a membership or subscription?

Faith Murray

@Shaun Porteous thank you for that clarification! That makes me feel more reassured. ?

Jaclyn Whitelock

I came across this after a post elsewhere, and am still not entirely sure I'm grasping correctly if it is a “recommendation” or a requirement. (And if it is a requirement, why does OLX for example, not offer more native functionality to meet these requirements?)

One thing I would be interested in others thoughts around is receipts for each payment. We issue consolidated tax receipts on a yearly basis for monthly donors, and I consider this to be a best practice unless the donor requests otherwise- receiving 12 tax receipts throughout the year is cumbersome and hard to keep track of for donors. If by “receipt”, just a general confirmation notification of funds withdrawn would suffice, this could be doable (though I wonder if more unsubscribes would result?)

Candy Reichert

When a Recurring Gift is established, either electronically, via phone, or mail, we already have a Recurring Gift “welcome” letter that I send out each month. That would cover all initiations for recurring gifts.

Cindy Gericke

Wondering….the new donor portal that has been vetted and rolling out soon - since the donor is able to make changes themselves within the portal, could BB add a statement in there covering these bases? If the donor wants to view their giving (we also do a year end for recurring gifts unless donors request them monthly) they are free to log in at will. Since OLX uses email address, this new portal would be an ideal jumping off point for inviting the recurring donors as the first users in an org wanting to do an initial roll out (I say initial, because a new donor portal will require maintenance/support for donor inquiries etc similar to “helpdesk” and this could be overwhelming for smaller orgs where the RE DBA is responsible for these issues). The portal is an invite only system currently so a statement could even be inserted into the invitation?? Thinking aloud..

Sarah Martin

@Shaun Porteous I have noted that for offline recurring gifts that are set up for consolidated receipting at the end of the year, we can't meet these recommendations in RE NXT. Our monthly donors prefer to be receipted once, at the end of the year. Will Blackbaud be creating a system that can automatically email donors who have offline recurring gifts in RE NXT monthly and allow charities to put in our own messaging about how donors can contact us to cancel?

I'm being specific about allowing us to craft the message, as we are always keeping up to date with best practices for donor communication and each organization may have different contact info for donors.

We use Luminate Online and I have rejected using consolidated receipting in LO, but for those donors who complain and want one receipt at the end of the year we cancel their online and start an offline recurring gift in RE NXT.

But if this “recommendation” becomes a requirement in the future, we're talking about thousands (or tens of thousands) of emails needing to be sent every month after processing in RE NXT. That is a huge burden to leave on charities with limited resources and we will expect Blackbaud to have solutions that are easy to implement and meet the best practices of donor communications.

So, please let me know if this is something on the Blackbaud developers' radars. Thank you.

Kate Bachman

@Shaun Porteous
Hi Shaun, thank you for clarifying this information. Two quick questions:

With the email receipt that also has cancellation information in it, is this something that I can just generate on my own in the body of an email or does it need to be “pre-generated” such as from the receipt mail tab that the knowledgebase article talks about?
I understand this applies for infinite recurring gifts (non-ending) for Mastercard users. We have many constituents who have a pledge with monthly payments (for instance they pay September 1 2022-June 1 2023) - do these go under the new stipulations with Mastercard?

Thanks in advance!!

Shaun Porteous

@Kate Bachman

Hi Kate,

The receipt doesnt have to be an official tax receipt, more a receipt/acknowledgement of the debited amount from the donors card/account. It does have to have data such as frequency, amount, reference # etc. along with the cancelation instructions. Or you can also use an official Tax Receipt also.
For pledges - Yes they'd be included because the end result is still a recurring donation albeit on a sometimes imbalanced frequency or with missed donations.

Shaun Porteous

@Sarah Martin

Hi Sarah,

Thanks for reaching out.

Remember than your donors can also opt-out to receiving the monthly receipting email. That's also an option as long as your record and store their Opt-Out request.
I cant talk too much to each of our products as my role is specifically within Blackbaud Payments - but we have created our resource site with each Blackbaud product manager adding updates on how each of our products achieves and satisfies the compliance standards.

If you have further questions relating to the specific tasks of a product such as OLX, RE NXT or LO, I'd recommend reaching out to your Customer Success Manager who will assist and walk through more details specific to the product.

To also share, my recommendation was to roll out the approach to all card types not just Mastercard, eventually, if your organization is optimsed to do so. The Mastercard standards are a requirement for ALL Mastercard transactions.

Shaun Porteous

@Candy Reichert

Hi Candy,

As long as the welcome letter provides the details of the recurring gift sign-up. i.e. frequency, amount, cancelation instructions, etc. If not, then an Acknowledgment email / Thank you email to the donor on sign-up would be the best approach.

Thanks,

Shaun

Shaun Porteous

@Jaclyn Whitelock

Hi Jaclyn,

The Mastercard standards are a requirement for all Mastercard transactions. The receipting doesn't have to be an official Tax receipt, it can be, or it can be a receipt/acknowledgement of debiting the funds, outlining the amount, the frequency, reference and cancelation instructions.

Thanks,

Shaun

Shaun Porteous

@Danielle Lifshitz

Hi Danielle,

For all Mastercard transactions this is a requirement. And yes, this applies to monthly recurring donations.

Thanks

Shaun

Krista Lippert

@Shaun Porteous
Hey Shaun, I just saw this post. Is this true that Mastercard issued an extension and that paper receipts are not required?

Austen Brown

@Krista Lippert - If you haven't seen the webinar from BBMS on this, I recommend you catch the next viewing on Sept 12. @Shaun Porteous shares a lot of really useful information, including details on what is required with this. Click here to register for the upcoming webinar.