As most of you in the world of PCI already know MasterCard once again threw another grenade this past week with several PCI enforcement rule changes, this article is not about those changes (see MasterCards 2 Step) for that discussion. I want to discuss the card brands communication/dissemination of PCI rule changes, or lack thereof! I know this is an area we are all in agreement.For example when any of the card brands do make rule changes in how they enforce PCI, they do not seem to have a defined process on how they disseminate it, just throw it up on some small corner of our website and everyone will figure it out approach. I only found out about it the day it came out on MasterCard’s PCI merchant web page only because I have many news alerts (Google, ect.) and monitoring applications that watch for these things.

Prior to bringing this significant change to my upper management, I wanted to get as much clarification on the changes and how they affected my organization as possible. Of course when contacting my acquiring bank they had no idea about the change, let alone an interpretation of it. And of course having discussion with colleagues in my field, they were in some cases as much in the card as I was, this is of course with the exception of one (you know who you are).

After getting some clarification from one of closest professional friends “the PCI Guru“ I decided to take this information to my director, after speaking to some of the changes I was asked to provide supporting links and/ or official documentation that could support all of my statements. And other than MasterCard’s website (with the horrible layout and merchant table) the only other reference that I could show was a another blog.

My director found it odd this information was not on the PCI-SSC website, our acquiring banks PCI portal (which I think just redirects to the PCI-SSC site) or any other official website at all. And that MasterCard’s website went into little detail about the changes.

This takes me into my main discussion of why in 2009 5-6 years after PCI was born, can’t the card brands have some sort of formal defined process to manage the dissemination of PCI enforcement rule changes. I understand they all act independently (particularly now with MC co-driving the PCI bus now with VISA) and that’s cool, but how hard is it to create one.

Case in point to my knowledge the card brands when making an enforcement rule change have never given a warning ahead of time, or explained the changes in great detail, many times leaving  unanswered questions that the QSA’s, banks and PCI compliance officers have to figure out as the months go by.

I would like to see some agree upon (heck they could do this independently, just do it) process on how these enforcement rule changes are communicated. For example I think that both acquiring banks and the QSA firms should be made aware of these changes first and non-publicly and in the case of the banks by direct channels.

After a 30-60 day period where both the banks and the QSA’s obtain a clear an accurate understating of these changes, through both dialogue and supporting documentation from the card brands, then the merchants and service providers should be notified directly by their acquiring banks. In my opinion that is the information communication flow I would like to see and think would serve us all best.

With regards to posting of this information once it is public; first I would like to see all the credit card brands build well defined PCI portals on each of the websites that contain their own specific supporting documentation on their rules with regards to PCI enforcement. Second and I would like to see the card brands work with the PCI-SSC website and have links on the PCI-SSC website that would point to the card brands individual web portals (come on how hard is it to keep a link up to date!

Hopefully one day I will click my heals and PCI RSS feeds will suddenly appear on the card brands websites . . . . . . ok it didn’t work!).