I recently had contact with a senior VP at Visa and he confirmed that Visa hopes to publish FAQs on their new rules in early-February. The FAQs will provide guidance on how Visa intends to interpret promotional/introductory offers and clarity around the enhanced statement descriptor requirement, including examples of what they will view as acceptable.
Interestingly, he said the descriptor issue generated the most questions about the new rules, and that Visa will try to provide flexibility for merchants without undermining the intention of the policy changes.
I did ask whether the requirement for a link to facilitate cancellation is required in all pre-bill notices and received a clarification that it was only required before the first paid charge (I presume this translates to the first full paid charge for discounted offers). However, I was also informed that Visa is not looking to prescribe specific requirements but is striving to ensure that consumers are provided an easy online method to cancel recurring charges. To that note, Visa will not be dictating a minimum/maximum number of “clicks” to effect a cancel, and that merchants may require consumers to log into their online account to cancel.
More when the FAQs arrive ..