Reporting and compliance
Reporting and compliance intro
As the issuing bank and BIN sponsor, Cross River provides card network access and regulatory oversight for card programs. Cross River maintains full responsibility for regulatory and network compliance for all partner-managed Issuing programs.
You must submit regular reporting to Cross River to maintain compliance with regulatory requirements, credit risk management obligations, and card network operating rules. Reporting lets Cross River fulfill its role as issuing bank and BIN sponsor. This maintains oversight of partner program activity and risk exposure.
To meet these obligations, submit regular reports to Cross River.
You must submit these reports:
- Daily transaction, card balance and network settlement files for transaction monitoring and reconciliation
- Daily servicing tapes for servicing events monitoring and reconciliation
- Monthly credit risk metrics for credit card programs and chargeback metrics for all programs
- Quarterly card network reports for Visa and Mastercard compliance
Submit timely and accurate reports to maintain a compliant card program under Cross River’s sponsorship.
Daily reporting requirements
Daily files
You or your processors must deliver three types of daily files:
- Transaction master file: Captures all balance-affecting transactions you or the processor posted into the ledger during the previous business day. This file supports transaction monitoring, fraud detection, and settlement processes.
- Daily balance file: Provides the ending balance and status for each issued card at the end of each business day. This file supports account reconciliation, negative balance monitoring, and charge-off reporting. It also supports other Cross River operational and compliance oversight functions.
- Network settlement file: Provides network settlement details to reconcile against daily payments to the network.
- Servicing data: Captures all servicing data on a daily basis. This is required for credit cards issued by Cross River. The data includes principal/interest breakdown, next due date, and delinquency info. The data is submitted via SFTP.
Balance visibility for FDIC compliance
For partner-managed programs using the FBO account model, the daily card balances file is critical for FDIC pass-through insurance compliance. In this model, Cross River holds customer funds and you maintain the external ledger. This file lets Cross River ascertain beneficial owner identity and ownership interests as required by federal banking regulations.
Without this visibility, individual customers would not benefit from up to $250,000 FDIC pass-through insurance coverage. The balance file must accurately represent each customer's ownership interest in the pooled FBO account.
For more information on balance visibility requirements and the three partner-managed balance models, refer to Balance and ledger models.
File delivery
Daily files must be securely delivered via Cross River’s SFTP (Secure File Transfer Protocol) server. Encrypt them using PGP (Pretty Good Privacy). Format them according to Cross River’s data exchange specifications.
Once a partner is set up for SFTP, they must ensure they have a PROD\CreditCardProcessing\DailyReports\ subfolder. This goes in their Cross River SFTP folder. This is where they will place the files. Partners should review the Cross River Card Files specification and data dictionary and submit sample files for validation to Cross River prior to launching their card program.
The Card Files monitor money movement and key data elements. These elements relate to compliance and BSA/AML. They also let Cross River and their partners to reconcile card program operation and account balances.
Files format
The Cross River Card Files must be formatted in a specific way. Cross River prefers comma-separated value (.CSV) files. The partner or their processor delivers them via Cross River's SFTP. Encrypt files with PGP using Cross River’s public key. File naming convention is flexible, but we advise Partners to include the date in the name. Append .pgp to encrypted file names. Lastly, make the file names unique.
Cross River can work with you to discuss adjustments to the files if your processor already has files that fulfill the same purpose. Once you and Cross River agree on the files, the project for data ingestion can begin.
Monthly reporting requirements
Credit card programs only
Monthly reporting is mandatory for credit card programs to maintain portfolio transparency and meet regulatory obligations.
If your program issues credit cards, you must also deliver credit risk data reports on a monthly basis.
- Purpose: To provide Cross River with credit risk indicators daily transaction monitoring doesn't show, supporting risk management and regulatory oversight.
- Required data: Metrics such as application volumes, approvals, declines, credit limits you assigned, delinquency rates (30/60/90+ days past due), charge-offs, fraud losses, recoveries, and collection activity.
- Format and delivery:
- CSV file format according to Cross River’s specification.
- Delivered to the /ClientCredit subfolder on Cross River’s SFTP server.
- All required metrics must be reported, with zeros for metrics that don't apply.
All card programs
All programs must submit monthly dispute and chargeback reports including summary data per the below
- Includes summary dispute and chargeback indicators across the partner’s program portfolio.
- Must include number of disputed transactions and amounts, and the dispute rate as a percentage of disputes to total transactions and program spend.
- Must include number of chargeback transactions and amounts, and the chargeback rate as a percentage of chargebacks to total transactions and program spend.
Monthly files must be securely uploaded to Cross Riverʼs SFTP server, encrypted using PGP.
Quarterly reporting requirements
All card programs
All programs must submit quarterly network reports to ensure compliance with Visa and Mastercard operating rules.
- Visa Quarterly Operating Certificate (QOC):
- Reports Visa-branded card activity associated with the BINs Cross River provided to the partner.
IMPORTANT: Submit to Cross River no later than the 5th business day following the end of each calendar quarter.
- Mandatory file format: Visa-provided Excel template.
- Mastercard Quarterly Mastercard Report (QMR):
- Reports Mastercard, Maestro, and Cirrus-branded card activity associated with the BINs Cross River provided to the partner.
IMPORTANT: Must be submitted to Cross River no later than the second Friday after each quarter ends.
- Mandatory file format: Mastercard-provided Excel template.
Quarterly files must be securely uploaded to Cross River’s SFTP server, encrypted using PGP.