Visa 10.5 - Visa Fraud Monitoring Program (VFMP)
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Disputes arising from VFMP compliance violations. If you're in the VFMP, issuers can file disputes under this code.
Overview
This code is used when a merchant is enrolled in Visa's Fraud Monitoring Program and fails to comply with program requirements, or when fraudulent transactions occur from a VFMP-enrolled merchant.
When This Code Applies
- Merchant is in VFMP
- Fraud transaction from VFMP merchant
- Merchant failed VFMP compliance
- Excessive fraud rate violations
VFMP Thresholds
Standard VFMP Thresholds
| Tier | Fraud Basis Points | Fraud Transactions |
|---|---|---|
| Early Warning | 65 bps AND | 75 transactions |
| Standard | 90 bps AND | 100 transactions |
| Excessive | 180 bps AND | 1,000 transactions |
VFMP Timeline
| Stage | Consequence |
|---|---|
| Month 1-4 | Identification, remediation required |
| Month 5-8 | $25,000/month fines |
| Month 9+ | $75,000/month fines |
| Month 12 | Card acceptance termination possible |
Conditions for Valid Dispute
Issuer Must Verify
- Merchant is enrolled in VFMP
- Transaction is fraudulent
- Within program timeframes
Merchant Situation
- Already under enhanced monitoring
- Limited representment options
- Higher scrutiny on all disputes
Representment Options
Limited options when in VFMP:
1. Transaction Was Authorized
Evidence required:
- Strong authentication proof (3DS with ECI 05)
- Cardholder correspondence
- Device/IP matching prior purchases
2. Fraud Prevention Was Applied
Evidence required:
- Fraud screening records
- 3DS attempt logs
- Declined transaction history showing controls
3. Exit VFMP Status
Focus on reducing fraud rate below thresholds to exit program. Prevention > representment.
Prevention Strategies (VFMP Exit Focus)
Immediate Actions
- Enable 3DS 2.0 - Get liability shift on all transactions
- Tighten fraud scoring - Decline more borderline transactions
- Review product/pricing - High-fraud products may need removal
- Velocity limits - Cap orders per customer/card/IP
Monitoring
- Daily fraud review - Don't wait for monthly reports
- Track basis points - Know your real-time fraud rate
- Dispute categorization - Understand fraud sources
Customer Verification
- Enhanced verification - Phone/email confirmation
- Delivery confirmation - Required signatures
- New customer friction - Higher hurdles for unknowns
Win Rate Expectations
Representment during VFMP is challenging:
| Defense Type | Expected Win Rate |
|---|---|
| 3DS fully authenticated | 70-85% |
| Strong prior relationship | 40-60% |
| Standard evidence | 15-30% |
Reality: Focus on fraud prevention, not representment.
Exiting VFMP
Exit Requirements
- Fraud rate below thresholds for 3 consecutive months
- Demonstrated compliance improvements
- Acquirer confirmation
Exit Strategy
- Aggressive fraud blocking - Accept fewer risky orders
- 3DS on everything - Maximize liability shift
- Product review - Remove fraud-attracting items
- Customer segmentation - Whitelist trusted customers
Common Mistakes
- Ignoring VFMP enrollment - Hope is not a strategy
- Continuing normal operations - Must change immediately
- Fighting all disputes - Waste of resources during VFMP
- No root cause analysis - Will re-enter program
Related Codes
- 10.1 - EMV Counterfeit
- 10.2 - EMV Non-Counterfeit
- 10.3 - Other Fraud Card Present
- 10.4 - Card Not Present Fraud
Next Steps
In VFMP program?
- Immediately implement 3D Secure
- Set up dispute alerts to reduce dispute count
- Review fraud rules → Tighten velocity checks
- Follow the Reduce Chargebacks Fast playbook
Get out of VFMP:
- Reduce fraud ratio below thresholds for 3 consecutive months
- Work with processor on remediation plan
- Consider temporarily blocking high-risk transactions