Constellation Payments – Rules & Disclosures

1. Purpose of This Page

This page is designed to provide merchants with guidance concerning:

• Fees and assessments,
• The scope of our business,
• Our approach regarding compliance, data security, and monitoring, and
• The rights and obligations of both CPP and our merchants.

2. Billing Rules & Methodology for Dues and Assessments

Why Timing Matters

To avoid billing merchants in arrears, CPP uses a transparent rolling effective rate model.

How It Works

1. Rolling 12-Month Effective Rate:
   • Each merchant’s fees related dues and assessments (“D&A”) are based on their 12-month rolling average of actual D&A.
   • New merchants are initially assigned their Independent Software Vendor’s (“ISV”) current effective rate for D&As until sufficient history is established, at which point, such fees are assessed on the basis of the above.
2. Monthly Billing:
   • Fees are billed using the current effective rate rather than waiting for the actual D&A, which allows timely, predictable billing.
3. True-Up Adjustments:
   • If D&A later shows a meaningful variance, the rate is adjusted prospectively to maintain fairness.

What Merchants Can Expect

• Predictable fees each month,
• Consistent fee application based on known averages,
• Transparency about how rates are derived.

3. Fee Structure and Changes

All fees—including processing, chargeback, and other service fees—are defined in the merchant’s agreement and may be updated with at least 30 days’ prior notice.

Fees are typically deducted from settlement deposits. When there are insufficient funds, CPP may debit the designated bank account in accordance with the applicable Sub-Merchant Agreement.

4. Merchant Conduct & Acceptable Use

General Standards

Merchants must:

• Operate lawful, bona fide businesses;
• Comply with all applicable laws and card-brand rules;
• Provide accurate information during underwriting and throughout their relationship with CPP.

Prohibited Activities

Merchants may not use CPP services for illegal, deceptive, or high-risk activities including (but not limited to):

• Gambling or online gaming,
• Adult entertainment or sexually explicit content,
• Money services, check cashing, or cryptocurrency transactions,
• Sale of controlled substances or unlicensed firearms,
• Credit repair, debt elimination, or “get rich quick” programs,
• Counterfeit, infringing, or deceptive products,
• Any other business type prohibited by the card brands.

Restricted / Enhanced Due Diligence

Certain industries—such as firearms and ammunition, age-restricted products, or travel services—require additional documentation, licensing, and monitoring. These merchants undergo enhanced underwriting and must remain in full compliance with applicable federal, state, and local laws at all times.

5. Underwriting and Risk Monitoring

CPP reviews and assesses each merchant prior to onboarding based on:

• Business history and ownership,
• Creditworthiness of the merchant and its principals,
• Type of goods/services and fulfillment process, and
• Any applicable card-brand or processor pre-approval requirements.

We continuously monitor transactions for chargebacks, suspicious activity, and AML/BSA compliance. CPP may require reserves, delay settlements, or suspend processing if risk thresholds are exceeded or regulatory obligations demand it.

6. Cardholder Data Security

Merchants must be in compliance with PCI DSS (Payment Card Industry Data Security Standards) at all times.

Merchants may only use PCI-compliant third-party vendors for the storage or transmission of cardholder data and must immediately report any suspected or actual data breach to CPP.

CPP does not sell or disclose merchant or cardholder information except as required by law or as required by the various card brands.

7. Refunds, Chargebacks, and Disputes

• Merchants are responsible for processing customer refunds promptly and in accordance with applicable card-brand rules.
• CPP passes through all chargeback notifications and may debit the merchant’s account for disputed amounts and any associated fees.
• Excessive chargebacks may result in additional monitoring, reserve requirements, or termination of processing privileges.

8. Termination and Account Closure

CPP may terminate a merchant relationship for reasons including but not limited to:

• Fraud, excessive chargebacks, or regulatory non-compliance,
• Violations of card-brand or network rules, or
• Material breach of agreement terms.

Upon termination, funds may be held in reserve for at least 180 days to cover potential disputes or chargebacks, after which any remaining balance will be released.

9. Transparency & Regulatory Status

• Constellation Payments is not a bank or money transmitter.
• All settlement of funds is performed by our sponsor bank partner.
• CPP acts as a registered payment facilitator and agent of the acquiring bank.
• Merchants release customers from liability once payment is received by the acquiring bank or CPP as agent.

10. Privacy and Data Protection

We value your privacy. Merchant data is collected and used only for purposes of risk management, transaction processing, compliance, and support.

Please refer to our Privacy Policy for full details.

11. Links to Card-Brand Rules

Merchants are required to comply with all card-brand regulations. You can review the latest versions at:

• Visa Rules
• Mastercard Rules
• Discover Rules
• American Express Rules

12. Questions or Complaints

For compliance or billing questions, contact:

Email: [email protected]