Visa 2013 Annual Report Download - page 25

•Regulation of the price of credit. Many jurisdictions in which Visa-branded cards are used have
regulations that could increase the costs of card issuance or decrease the flexibility of issuers
to charge market-based interest rates and fees on credit card accounts. These include the
Credit CARD Act of 2009 in the United States and other proposed regulations under it.
Proposed changes to the Truth in Lending Act of 1968, if implemented along with regulations
required to be promulgated under the Credit CARD Act, could result in a decrease in our
payments volume and revenues.
•Increased central bank oversight. Several central banks around the world have increased, or
are seeking to increase, their formal oversight of the retail electronic payments industry, in
some cases considering designating them as “systemically important payment systems” or
“critical infrastructure.” Any such oversight may lead to additional regulations by central banks
and other government regulators. These could include new settlement procedures, cyber
security requirements or other operational rules to address credit and operational risks. They
could also include new criteria for financial institution client participation and merchant access
to our payments system.
•Safety and soundness regulation. Recent banking regulations enacted in the United States
and elsewhere may make some financial institutions less attracted to becoming an issuer of
Visa-branded cards, because they may be subject to increased risk management or higher
capital requirements.
•Regulation of Internet transactions. Proposed legislation in various jurisdictions may make it
less desirable or more costly to complete Internet transactions using Visa-branded cards by
affecting the legality of those transactions, the laws that govern the transactions, their taxation
or the allocation of various intellectual property rights.
•Money transfer regulations. As we expand our product offerings, we may become subject to
U.S. state money transfer regulations, which could increase our regulatory oversight and
compliance costs.
Complying with these and other regulations increases our costs and can reduce our revenue
opportunities. Our programs and policies are designed to comply with anti-money laundering, anti-
terrorism and sanctions regulations, and we continue to review and enhance them. But, as regulations
continue to evolve and regulatory oversight continues to increase, we cannot guarantee that our
programs and policies will be deemed compliant by all applicable regulatory authorities. The impact of
such regulations on our clients and on us may increase compliance costs and reduce the volume of
payments we process. Moreover, such regulations can limit the types of products and services that we
offer, the countries in which Visa-branded cards are used and the types of account holders and
merchants who can obtain or accept Visa-branded cards. Any of these occurrences could materially
and adversely affect our business, prospects for future growth, financial condition and results of
operations.
Litigation Risks
Our retrospective responsibility plan may not adequately insulate us from the impact of
settlements or final judgments.
Our retrospective responsibility plan addresses monetary liabilities from settlements of, or final
judgments in, the covered litigation, which is described in Note 3—Retrospective Responsibility Plan to
our consolidated financial statements included in Item 8 of this report. The retrospective responsibility
plan consists of several related mechanisms to fund settlements or judgments in the covered litigation.
These include an escrow account funded with a portion of the net proceeds of our IPO and any
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