First Data 2008 Annual Report Download - page 22

and foreign laws and regulations, which may include laws and regulations related to consumer and data protection, licensing, escheat, anti-money laundering,
banking, trade practices and competition and wage and employment. These laws and regulations are evolving, unclear and sometimes inconsistent and subject
to judicial and regulatory challenge and interpretation, and therefore the extent to which these laws have application to, and their impact on, FDPS, First Data
International, financial institutions, merchants or others is in flux. At this time the Company is unable to determine the impact that the clarification of these
laws and their future interpretations, as well as new laws, may have on FDPS, First Data International, financial institutions, merchants or others. These
services may also be subject to the rules and regulations of the various international, domestic and regional schemes, Networks and Associations in which
FDPS, First Data International and the card issuers participate. These schemes, Networks or Associations may, generally in their discretion, modify these
rules and regulations and such modifications could also impact FDPS, First Data International, financial institutions, merchants and others.
Regulation of the payments industry in the U.S. and abroad that is applicable to the Company's customers could impact the Company as well. For
example, the Board of Governors of the Federal Reserve System Federal Reserve Board has issued rules amending Regulation AA (Unfair or Deceptive Acts
or Practices) and Regulation Z (Truth in Lending Act) that impose new restrictions on certain credit card practices and require increased consumer disclosure
effective July 1, 2010. In addition, the Housing Assistance Tax Act of 2008 included an amendment to the Internal Revenue Code that requires information
returns to be made for each calendar year by merchant acquiring entities and third party settlement organizations with respect to payments made in settlement
of payment card transactions and third party payment network transactions occurring in that calendar year. This requirement to make information returns
applies to returns for calendar years beginning after December 31, 2010. These new regulations may require the Company to incur additional costs to modify
its systems so that the Company may provide compliant services but may also provide opportunities for the Company to offer additional revenue producing
services to its customers.
21