Card Acquiring Service (CAS) 

Transaction Thresholds

July 29, 2020
Page 2 L EAD ∙ T RANSFORM ∙ D ELIVER

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 

identities. 

This webinar will be recorded 

Guidelines for today’s session
Page 3 L EAD ∙ T RANSFORM ∙ D ELIVER

Objectives:

• To educate agencies on the policies outlined by the Card 

Acquiring Service (CAS) program on transaction 

thresholds and non-compliance.

How:

• Provide agencies with a detailed synopsis of specific 

transaction thresholds outlined in the Treasury Financial 

Manual (TFM) Chapter 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?
Page 4 L EAD ∙ T RANSFORM ∙ D ELIVER

Overview: Thresholds & Non-Compliance

TFM & CAS Card Rule Review

Transaction Maximums

Prohibition of Split Transactions 

Intra-governmental Card Transactions

CAS Program Non-Compliance 

Next Steps 

Questions
Page 5 L EAD ∙ T RANSFORM ∙ D ELIVER

• 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?
CAS Transaction Thresholds & 

Non-Compliance
Page 7 L EAD ∙ T RANSFORM ∙ D ELIVER

Transaction Maximums

• Section 7045—Limitations on Card Collection 

Transactions

– 7045.10—Transaction Maximums

– CAS program agencies must limit credit card 

collections of an individual or multiple transactions to 

not exceed $24,999.99.

Policy: Limitations on Card Collections 

$24,999.99

Credit card 

MAX limit
Page 8 L EAD ∙ T RANSFORM ∙ D ELIVER

• Prohibition of Split Transactions

– 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.

• Examples:

Policy: Limitations on Card Collections 

Obligation Amount - $ 48,000

CARD 1

$ 24,999.99

CARD 2

$ 23,000.01

$ 48,000

X CARD 1

$ 24,999.99

$ 48,000

CASH

ACH

Debit Card
Page 9 L EAD ∙ T RANSFORM ∙ D ELIVER

Debit Card

• No threshold limit

Automated Clearing House (ACH)

• $99,999,999.99 threshold limit

• $100,000 limit for Same Day ACH 

Check 

Cash

Policy: Alternative Payment Options
Page 10 L EAD ∙ T RANSFORM ∙ D ELIVER

• 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 
Page 11 L EAD ∙ T RANSFORM ∙ D ELIVER

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 

$9,999.99 to decline at $10,000.00

Policy: Intra-governmental Transactions
Page 12 L EAD ∙ T RANSFORM ∙ D ELIVER

• Intra-Governmental Payment and Collection 

(IPAC)

– IPAC is a way for Federal Program Agencies (FPAs) to 

transfer funds from one agency to another with 

standardized descriptive data. 

– Interagency Agreement (IAA)

– TFM Chapter. 4700, Appendix 8 Intra-governmental 

Transactions (IGT) Buy/Sell

– For more information on IPAC, please visit the IPAC 

webpage at: https://www.fiscal.treasury.gov/ipac/

Policy: IGT Alternative Payment Options
Page 13 L EAD ∙ T RANSFORM ∙ D ELIVER

CAS FPAs must abide by all Network Rules and policies outlined 

in Chapter 7000, Vol. 1 (Part 5) of the TFM. Agencies that fail to 

follow all applicable rules are subject to being placed on notice of 

non-compliance. 

CAS Program Non-Compliance Policy 

Date 1 – CAS sends 

Initial Notice to noncompliant agency

Date 3 – CAS 

sends out 

Final Notice of 

NonCompliance

Expected response 

within 15 business 

days after date 1

Expected 

response 

within 7 days 

of receipt of 

Follow-up 

Notice

Agencies have 15 business days to 

respond to Initial Notice of NonCompliance

Phase 2:

In order to restore services, noncompliant agencies must become 

compliant and submit a new CAS 

application 

CAS may 

suspend 

services to 

noncompliant 

agency

Date 2 – CAS 

sends Followup Notice to 

non-compliant

agency

Agencies have 7 business days after 

receipt to respond to Follow-up 

Notice of Non-Compliance

15 days 7 days of receipt

The CAS Program Non-Compliant Notice Process can be found 

following this link https://tfm.fiscal.treasury.gov/v1/p5/c700.html

and it includes the following steps:
Next Steps
Page 15 L EAD ∙ T RANSFORM ∙ D ELIVER

Next Steps - What’s up next?

We are asking participants to refresh themselves with the 

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

Complete the post-webinar survey

Submit questions to the CAS Outreach Mailbox 

(CardAcquiringService@fiscal.treasury.gov) 

2

1

3
Page 16 L EAD ∙ T RANSFORM ∙ D ELIVER

Upcoming Webinars: Save the Date
QUESTIONS?
L EAD ∙ T RANSFORM ∙ D ELIVER

Contact Information

Page 18

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 
Page 20 L EAD ∙ T RANSFORM ∙ D ELIVER

Section 7045—Limitations on Card Collection 

Transactions

– 7045.10—Transaction Maximums

– 7045.20—Prohibition on Splitting Transactions

Section 7090—CAS Program Non-Compliant Notice and 

Suspension of Service Process

Section 7155—Intra-governmental Card Transactions

Appendix A - TFM References
Page 21 L EAD ∙ T RANSFORM ∙ D ELIVER

ARM – Agency Relationship Management

CAS – Card Acquiring Service

FPA – Federal Program Agency

IGT – Intra-governmental Transactions

IPAC – Intra-governmental Payment and Collection 

TFM – Treasury Financial Manual

SSD – Settlement Services Division 

Appendix B - Glossary