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Re: PCI Compliance
From: Nathan Sweaney <nathan () sweaney com>
Date: Fri, 12 Apr 2013 00:23:45 -0500

You are correct. The merchant of record (whoever signs the contract to
accept credit cards) is responsibly for completely complying with the
entire PCI-DSS (and any other security requirements provided by the card
brands that they accept). This is spelled out in their Merchant Agreement
contract with their processor or acquiring bank. I obviously haven't seen
their contract, but I've looked at tons from various banks and they all
have the exact same boilerplate sections provided by the card brands.

It sounds like they are the merchant of record, but it's your customers
whose cards will be processed. If so, that puts you in an awkward position.
Legally the vendor will liable for any fines associated with a breach, but
your name could be smeared because they were your customers. If you have
any leverage, you might insist they provide a copy of their merchant
agreement, or even a letter from their bank attesting that they don't have
to fully comply. They won't be able to do that, but it might help you
convince them that they're wrong.


On Thu, Apr 11, 2013 at 4:04 PM, Jeff h <holden.tech () gmail com> wrote:

I have a question I hope someone can answer regarding PCI.  We have a
vender that we use that hosts an application.  The vender says they are a
Level 4 merchant and use a third party for all credit card transactions. So
they would have to fill out a SAQ C and have an external scan by an
approved vender.

Do they still have to abide by all PCI DSS requirements even if they are
not spelled out in SAQ C, such as password length, reuse, and expiration?

The vender has a document they describe their security controls and they
do not even meet PCI DSS already lax standard of at least 7 character
passwords. They claim that since they are level 4 they don't need to.

My understanding was all requirements still apply even if it dosen't go
through every single requirement in SAQ C they still have to check the box
that says "I have read the PCI DSS and I recognize that I must maintain
full PCI DSS compliance at all times"

So who is correct?

Thanks,
Jeff

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