First Data 2007 Annual Report Download - page 17

Because a number of our subsidiary businesses, including card issuer processing, merchant processing and STAR Network businesses, provide data
processing services for financial institutions, they are subject to examination by the Federal Financial Institutions Examination Council, an interagency body
comprised of the federal bank and thrift regulators and the National Credit Union Association.
FDR Limited ("FDRL") in the United Kingdom holds a license from the Financial Services Authority ("FSA"). The FSA is the licensing and regulatory
authority for all U.K. financial services, including banking, but FDRL's license is limited to acting as an insurance intermediary in connection with selling
card payment protection insurance to its issuer customers' cardholders.
TeleCheck Payment Systems Limited in Australia holds an Australian Financial Services License under Chapter 7 of the Corporations Act, which
regulates the provision of a broad range of financial services in Australia. The license, issued by the Australian Securities and Investments Commission,
entitles the Australian operations of TeleCheck to deal in and provide general financial product advice about its check guarantee and check verification
product (which falls within the definition of a risk management product under the legislation). The License and the Act requires that TeleCheck's Australian
operations issue product documents that comply with specific content requirements and follow prescribed procedures failing which penalties apply.
First Data Slovakia is registered with the National Bank of Slovakia as an authorized participant to the Slovak payment system.
First Data Polska S.A. is regulated as a settlement agent by the National Bank of Poland.
Association and Network Rules
FDLCC is a member of MasterCard International, Inc. in Canada and subject to MasterCard rules. First Data Cono Sur, S.A. is a member of
MasterCard in Argentina and Uruguay and subject to MasterCard rules. First Data Resources, LLC., First Data Merchant Services Corporation, FDRL, First
Data Deutschland, First Data Hellas, First Data Latvia, First Data Lithuania, First Data Slovakia, First Data Austria, First Data Resources Australia Limited
("FDRA"), BWA Merchant Services Pty Limited ("BWAMS"), Omnipay, Limited, First Data Acquisition Corp., First Data Merchant Services Mexico, S. de
R.L. de C.V., AIB Merchant Services, European Merchant Services, BNL Positivity, Merchant Solutions Private Limited, Merchant Solutions Pte Limited,
Merchant Solutions Sdn Bhd and STAR Network are registered with Visa and/or MasterCard as service providers for member institutions. In those situations
where we are serving as service providers to member institutions, we are not an acquirer under Visa's and MasterCard's rules. Two STAR Network entities,
Star Networks, Inc. and Star Processing Inc., are also processor level members of numerous debit and electronic benefits transaction ("EBT") networks in
connection with processing services and other services they provide to their customers. As such, we are subject to applicable card association and network
rules, which could subject us to a variety of fines or penalties that may be levied by the card associations or networks for certain acts and/or omissions by us,
our sponsorees, acquirer customers, processing customers and/or merchants. We mitigate this risk by maintaining an extensive card association and network
compliance function. We are also subject to network operating rules promulgated by the National Automated Clearing House Association relating to payment
transactions processed by us using the Automated Clearing House Network and to various state laws regarding such operations, including laws pertaining to
EBT.
Cashcard Australia Limited ("Cashcard") is a member of the Australian Consumer Electronic Clearing System ("CECS"), which is a debit payment
system regulated by network operating rules established and administered by Australian Payments Clearing Association Limited and which facilitates the
clearing and settlement of ATM and Electronic Funds Transfer at Point of Sale ("EFTPOS") payments in Australia. The network operating rules impose a
variety of sanctions, including suspension or termination of membership and fines for non-compliance. Cashcard also operates its own network of members,
regulated by rules promulgated by Cashcard, which facilitates access to CECS for Cashcard's member institutions. To enable Cashcard to settle in CECS
direct with banks and financial institutions, Cashcard maintains an Exchange Settlement Account ("ESA") which is supervised by the Reserve Bank of
Australia through its delegate, the Australian Prudential Regulatory Authority ("APRA"), and which requires Cashcard to adhere to conditions imposed by
APRA, such as maintaining a minimum balance in the ESA.
Our subsidiary in Germany, TeleCash GmbH & Co. KG ("TeleCash"), is certified and regulated as a processor for domestic German debit card
transactions by the Zentraler Kreditausschuss ("ZKA"), the German banking association. Failure to comply with the technical requirements set forth by the
ZKA may result in suspension or termination of services.
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