educational

Billing: Underwriting Inconsistencies

Do you ever wonder why your experience can be so different when working towards the same goal with two different financial partners?

When you are looking for banking or merchant services you might assume that you are going to be faced with nearly the same requirements from financial partner to financial partner. After all, the banks are heavily regulated and their exams are all based off of the same requirements.

The bank will have policies that cover credit risk, know your customer, anti-money laundering, suspicious activities, lending limits, reputation risk, etc.

But you and I know that consistency is not the case. As a merchant seeking processing, you will be asked for different underwriting documents, be given different reserve requirements, be charged different fees, be allowed different capabilities and be given different requirements for your offering to be “compliant”.

So what is it that makes bank requests and their outcomes so different for the same account?

There are a lot of factors that drive this diversity. The leading factor is that regardless of the uniformity of the rules, it is people that ultimately make the account decisions and those people are driven by many different factors.

The people who are at play in this decision are numerous. To name a few, they are your sales rep, the ISO underwriter, the bank underwriter, the bank’s regulators, the bank’s officers and the bank’s board of directors.

Each of these individuals have different risk tolerances, definitions of morality, perceptions of risk and personal gain at stake for either approving or denying your account. Honestly, it’s a wonder anything gets approved at a bank —ever.

You likely do not know that each bank has a unique bank charter and individual policies that support that its charter. For instance, some banks explicitly state that they will not support certain industries or that they support certain categories of clientele and will be granted permission to operate only so long as they adhere to their charter.

Banks have numerous policies in place to protect the bank and the banking system from identified and perceived risks. The bank will have policies that cover credit risk, know your customer, anti-money laundering, suspicious activities, lending limits, reputation risk, etc.

Banks have regulators that seem to always be arriving at the bank for various exams. These regulators have a set exam that they perform and they will ask the bank personnel for Know-Your-Customer files on anyone holding an account at that bank. In fact, regulators are known to pinpoint a particular transaction and ask for all of the information about it. Years ago at a bank I was asked by a regulator about a wire that was sent to Canada each month. I knew all about it so by quickly answering their questions, the regulator was happy that we knew what was flowing through our bank.

When it comes to bank regulators you have to realize that they are there to ensure that the banks in their jurisdiction are not posing a financial risk to the entire banking system and are not participating in anything that would pose a risk to the bank’s reputation. Regulators, in general, are very conservative people and will encourage their banks to be ultra conservative as well to ensure that a bank does not fail on their watch.

Outside of the people that make these decisions there are outside factors that are continually being introduced that are interpreted, discovered and otherwise reacted to differently by these individuals. These outside factors include recent regulatory opinion letters, proposed rule changes, new actions against other banks or companies or simply a new person in the chain of decision makers that look at your deal.

The good news is with these inconsistencies almost everyone is able to find a bank that will work with them. Because no matter how highly regulated each bank is and even by the same set of regulators so much compliance is still left to the interpretation and subjective opinions of everyone involved in the process starting with the examiner or regulator themselves. One thing that will be consistent is that the individuals involved in your account will need the information that they ask for to adhere to their organization’s policies. These policies are driven by keeping each player in the chain mentioned above comfortable that the business they are supporting is consistent with the laws and policies that are currently in place.

Melody L is chief operating officer for L3 Payments.

Related:  

Copyright © 2026 Adnet Media. All Rights Reserved. XBIZ is a trademark of Adnet Media.
Reproduction in whole or in part in any form or medium without express written permission is prohibited.

More Articles

opinion

Key Strategies for Adapting to Stricter PCI Compliance Standards

When it comes to PCI compliance, the days of simply filling out some paperwork and answering a few questions are gone. A casual approach is just not viable anymore.

Jonathan Corona ·
opinion

How to Maximize Value From Your Payment Processing Fees

Regulatory requirements are putting more and more pressure on the adult industry. To stay compliant, merchants need tools that help with content moderation, age verification and fraud solutions. Unfortunately, the fees for those tools are hitting merchants’ bottom lines — including fees charged by payment services providers.

Cathy Beardsley ·
opinion

Understanding Sin Taxes and the Legal Roadblocks Ahead

As of this writing, a bill sits on the desk of Utah’s governor, awaiting his signature to make it state law. That bill includes a provision imposing an excise tax of 2% on adult sites operating in the state.

Corey D. Silverstein ·
profile

LoyalFans' Anastasia Pierce Bridges Creator Education, Empowerment and Ownership

Anastasia Pierce beams when she talks about her 26 years in the industry. Full of passionate energy, she clearly doesn’t just work in adult; she loves it.

Women In Adult ·
opinion

Growing Site Revenue Under Ever-Changing Compliance Rules

Over the past year, many merchants have reported earnings that were flat or even a bit down. This is due to three main factors: age verification regulations, click-to-cancel rules, and banks backing away from cross-sales due to regulatory requirements and the rollout of the Visa Acquiring Monitoring Program (VAMP).

Cathy Beardsley ·
opinion

AI Safeguards for Platform Compliance and Trust

If your platform hosts user-generated content (UGC), then you already know protecting your brand is not merely a matter of good design or strong community guidelines. It requires systems that can verify who your users are, filter what they upload and ensure your business stays on the right side of regulators, payment processors and public opinion.

Christoph Hermes ·
opinion

How to Eliminate User Redirects and Improve Checkout Retention

Running an adult site, you work hard to create traffic and make sure your funnel is optimal, with the end goal of getting users to make a purchase. Then, right at that critical moment, what do you do? You send them somewhere else. Not good.

Jonathan Corona ·
profile

Stripchat's Jessica on Building Creator Success, One Step at a Time

At most industry events, the spotlight naturally falls on the creators whose personalities light up screens and social feeds. Behind the booths, parties and perfectly timed photo ops, however, there is someone else shaping the experience.

Jackie Backman ·
opinion

Inside the OCC's Debanking Review and Its Impact on the Adult Industry

For years, adult performers, creators, producers and adjacent businesses have routinely had their access to basic financial services curtailed — not because they are inherently higher-risk customers, but because a whole category of lawful work has long been treated as unacceptable.

Corey Silverstein ·
opinion

How to Build Operational Resilience Into Your Payment Ecosystem

Over the past year, we’ve watched adult merchants weather a variety of disruptions and speedbumps. Some even lost entire revenue streams overnight — simply because they relied too heavily on a single cloud provider that suffered an outage, lacked sufficient redundancy and failover, or otherwise fell short when it came to making sure their business was protected in case of unwelcome surprises.

Cathy Beardsley ·
Show More