Card Acquiring Service (CAS) 

Agency Participation Policies

March 25, 2020
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Housekeeping

• We kindly ask to keep lines on mute

• Moderator will place lines on lecture mode for quality 

assurance

• Please do not place calls on hold; feel free to disconnect 

and dial back in if you need to step away

• To ask questions: enter your question in the Q&A message 

feature or questions can be submitted to the CAS Outreach 

Mailbox (CardAcquiringService@fiscal.treasury.gov)

• To comply with the rules outlined by Treasury’s Legislative 

and Public Affairs Division, no presenter(s) will disclose their 

identifies. 

This webinar will be recorded 

Guidelines for today’s session
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Objectives:

• To educate agencies on the policies outlined by the Card 

Acquiring Service (CAS) program. 

How:

• Providing agencies with a detailed synopsis of specific 

CAS participation policies, also known as the “CAS Card 

Rules” that are outlined in the Treasury Financial Manual 

(7000) Volume 1, Part 5: Credit and Debit Transactions. 

• Help our agency customers understand the ramifications 

of non-compliance for important card service rules and 

policies. 

Purpose: Why are you here?
CAS Program 

Agency Participation Policies
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• The card rules apply to federal agencies that are collecting 

or intend to collect obligations via credit or debit card. In 

addition to these requirements, an agency also must 

comply with and be bound by the rules and regulations 

governing all debit and credit card transactions accepted by 

the agency (collectively, the Network Rules), any of which 

may be altered or amended periodically and without notice.

Policies: CAS governing policies

• The TFM is the Department of the Treasury’s (Treasury’s) 

official publication of policies, procedures, and instructions 

concerning financial management in the Federal 

Government.

What is the Treasury Financial Manual (TFM)?

What are the CAS Card Rules?
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Policies: Understand the CAS Card Rules

• Operational 

– Intra-governmental Card Transactions

– Limitations on Card Collection Transactions

– Prohibition of Credit Cards on Debt 

– Honoring of Cards 

– Dispute Processing 

• Security

– Payment Card Industry Data Security Standard

• Administrative

– Maintenance of Agency Contacts

• CAS Program Non-Compliance
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• Definition

– An intra-governmental Card transaction (IGT) is defined 

as a sale of goods or services, or collection of other 

obligation by one government agency from another 

government agency using a government-issued Card.

• Rules for Intra-governmental Transactions

– Each agency is solely responsible for all fees associated 

with processing the transaction, including interchange, 

processing fees and charges for IGTs.

– Failure to pay fees associated with IGT processing may 

subject an agency to the CAS Program Non-Compliant 

Notice and Suspension of Service Process.

Policy: Intra-governmental Transactions 
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Currently, the limit for IGT is 

$24,999.99 

New limit to be 

implemented as of 

FY2021

1 October 2020, the limit for IGT 

will be $10,000.00

Policy: Intra-governmental Transactions
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Policy: Limitations on Card Collections 

• CAS program agencies must limit credit card 

collections of an individual or multiple transactions 

to not exceed $24,999.

Transaction Maximums

• What is a “split transaction”?

• A transaction obligation paid to which a customer 

uses one or more cards over the course of one 

or multiple days that result in an exceeded 

transaction maximum of over $24,999.

Prohibition of Split Transactions
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Policy: Prohibition of Credit Cards on Debt

* All must be paid in full within 30 days*

Card Network Rules

Card Brand 

Changes

Prohibition of 

Debt-for-Debt

Fiscal Service 

Adoption

What is a “debt obligation”?

Loans Obligations in 

arrears

Late 

payments

Payment 

Plans*
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Policy: Prohibition of Credit Cards on Debt

What is not considered to be a “debt 

obligation”?

Purchase of goods or 

services Overpayments
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Policy: Honoring of Cards 

• All valid cards must be honored

– Agencies must honor all valid Cards within the 

appropriate categories of acceptance when properly 

presented as payments from customers and/or 

cardholders.

• Agencies must not:

– Dissuade

– Criticize or mischaracterize

– Persuade

– Engage in harmful activities

that can harm the business or brand of Visa, 

MasterCard, American Express or Discover
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Policy: Dispute Processing 

• Agencies are debited 

automatically for any chargeback 

submitted by a network to the 

Financial Agent. 

Chargeback 

Processing 

• Agencies should respond to a 

chargeback within 15 calendar 

days

• If a complete and proper

chargeback response is not 

received in 45 calendar days, 

the chargeback is finalized.

Chargeback 

Timeline
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Policy: Dispute Processing 

• Our Financial Agent maintains an 

online system that allows for the 

automation of the chargeback 

process

• iQ portal - iQ is a one-stop 

reporting tool that houses all 

cardholder information for 

credit/debit transactions, and 

other relevant financial analytics 

and business intelligence. 

Chargeback 

Tracking
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Security Policy: PCI DSS

• Security 

– Section 7065: Retention and Storage of Card 

Data/Payment Card Industry Data Security Standard

Security is IMPORTANT, ensure your agency is 

COMPLIANT.

Agencies are subject to 

requirements, including the 

Payment Card Industry Data 

Security Standard and the data 

retention requirements set forth 

in the Network Rules. 

Agencies that fail to comply 

with the requirements of this 

section may be subject to 

network fines, and/or penalties, 

liabilities, or damages arising 

under federal law.
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Card Security 101: Security Posture

What is a Security Posture? A consistent standard of 

cardholder data protection across a given footprint. 

Drafting the Posture

• Establish minimum standards

• Create the posture

Establishing the Posture

• Align customer agencies data security structure

• Provide understanding of security measures

Implementing the Posture

• Ideal end-state of security posture standards for 

agency adoption

• Identifying the 4 security posture elements
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Card Security 101: Posture Elements

OUR MISSION: 

Ensure our agency customers are 

utilizing a consistent standard of 

security for cardholder data 

protection

Payment Card Industry Data 

Security Standard (PCI-DSS):

Is an information security 

standard for organizations that 

handle branded credit cards from 

the major card schemes

PCI Compliance

EMV

is a payment method 

based upon a 

technical standard 

for smart payment 

cards and terminals 

ENCRYPTION

is the process of 

encoding a message 

of information

TOKENIZATION

is the process of 

substituting a 

sensitive data 

element with a nonsensitive equivalent
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– POC Maintenance is the responsibility of our Card Servicing 

customers.

– Agencies should inform Fiscal Service/CAS promptly when a Chain or 

Merchant ID point of contact (POC) changes.

– POC changes can be sent to the CAS Agency Outreach mailbox.

Administrative Policy: POC Maintenance 

POC 

Maintenance

Responsibility 

Inform

Change
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Customer agencies using CAS must abide by all 

Network Rules and the policies specified in chapter 

7000 of the Treasury Financial Manual (collectively 

“CAS Program Rules”). 

An agency that fails to comply with any provision of 

the Network Rules may incur fines and penalties 

imposed by a network.

https://tfm.fiscal.treasury.gov/v1/p5/c700.pdf

CAS Program Non-Compliance Policy 
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Agencies that fail to follow all applicable

CAS Program Rules are subject to being 

placed on notice of non-compliance:

CAS Program Non-Compliance Policy 

Phase 1 • Initial Notice of Non-Compliance

Phase 2 • Follow-Up Notice of Non-Compliance

Phase 3

• Final Notice of Non-Compliance 

• Suspending the provision of Card 

acquiring services to the non-compliant 

agency for those cashflows deemed noncompliant
Next Steps
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Next Steps - What’s up next?

1

2

3

4

We are asking participants to refresh themselves with the 

TFM, (https://tfm.fiscal.treasury.gov/v1/p5/c700.html)

Complete the post-webinar survey for this session

Place on your future calendar the upcoming CAS’ 

webinars

Questions can be submitted to the CAS Outreach 

Mailbox (CardAcquiringService@fiscal.treasury.gov) 
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Upcoming Webinars: Save the Date
QUESTIONS?
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Contact Information

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CAS Agency Outreach Mailbox

CardAcquiringService@fiscal.treasury.gov

ARM Mailbox

ARM@fiscal.treasury.gov

For More Information 

CAS Online: www.fiscal.treasury.gov/cas
APPENDIX 
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Section 7010—Scope, Applicability, and Network Rules

Section 7020—Application

Section 7025—Honoring of Cards and Surcharges

– 7025.10—Honoring of Cards

Section 7045—Limitations on Card Collection Transactions

– 7045.10—Transaction Maximums

– 7045.20—Prohibition on Splitting Transactions

Section 7050—Dispute Processing: Retrieval Requests and Chargeback Processing

– 7050.20—Chargeback Processing

Section 7065—Retention and Storage of Card Data/Payment Card Industry Data 

Security Standard

– 7065.20—Payment Card Industry Data Security Standard (PCI DSS)

Section 7070—Training of Key Personnel

– Section 7070.10—Maintenance of Agency Contacts

Section 7090—CAS Program Non-Compliant Notice and Suspension of Service Process

Section 7100—Prohibition of Using Credit Cards For Debt Repayment Obligations

Section 7155—Intra-governmental Card Transactions

Appendix A - TFM References
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ARM – Agency Relationship Management

CAS – Card Acquiring Service

CASA – Card Acquiring Service Application

CIR – Collections Information Repository

TFM – Treasury Financial Manual

SSD – Settlement Services Division 

Appendix B - Glossary