In brief
Epoch is a California payment intermediary that in the late 1990s accepted card payments for sites with a heightened risk of payment reversals and signed contracts with acquiring banks itself, acting as an agent for sites that, by its own account, numbered in the thousands. The payment brand on the paycom.net site lasted at least until the end of 2004; the "Epoch / Paycom" pairing as a single company is documented in a joint notice from 2002 estimate. Its history is the history of the price paid by a processor that stands between a site and a card network: a commission of about 15% (according to the press in 2003), a chain of banks that either turned it down or held back payouts, chargeback fines, and an unsuccessful antitrust suit against Mastercard that dragged on from December 2003 to October 2006.
The main takeaway for this installment: rules for high-risk and for cross-border acquiring existed long before 2010, and Epoch itself was a party to the main court dispute over those rules.
How it started
The primary source on the beginning is the self-description on the site, which says that Paycom.net had helped thousands of online stores since 1996 and calls it one of the largest internet transaction gateways in the world. Modern profiles of Epoch also give 1996 and Santa Monica, while other aggregators date the legal entity Epoch.com LLC to 2004 estimate; in 2003 the business press described the company as based in Marina del Rey. In the season, the dossier sits in the 2000–2006 era because of its main storyline (the IPSP rules and the suit against MasterCard), although the payment business already existed in 1996–1998.
The business model as described in the court documents: the sites had no merchant account of their own; Paycom signed contracts with acquiring banks and acted as agent for the web merchants, crediting them with revenue minus its own fees; all purchases were card-not-present. The founders are not named in the primary documents unverified. From December 1998 to May 2001, according to Paycom itself, an intermediary ISO introduced it to various banks and, each time the latest relationship went sour, found a new bank.
Year-by-year timeline
- 1996: by its own description, Paycom.net has been serving sites since 1996 fact
- 1998-12 to 2001-05: an intermediary ISO introduces Paycom to several acquiring banks; the relationships with the banks sour one after another estimate
- 1999-07-25 and 2000-06-30: two Paycom contracts with the bank AmTrade (Georgia) fact
- 2001-11: Paycom.net in an archived snapshot is a general-purpose e-commerce gateway with no mention of its category of clients; the snapshot of the epoch.com domain is titled "EPOCH PARTNERS," so it does not look like a payment service estimate
- 2002-06-03: a ruling by a district court in Michigan on Paycom's suit against the intermediary and a bank describes the business model and five schemes involving banks fact
- 2002-09-30: Perfect 10 files suit against several billers, including Paycom Billing Services fact
- 2002-11-01: Visa introduces special rules for IPSPs; the notice is signed by iBill, CCBill, and "EPOCH / Paycom" estimate
- 2003-05: according to the press, Paycom files a $23 million suit against MasterCard in federal court for the Central District of California; a connection with the New York case is not confirmed by any document estimate
- 2003-10-01: Visa's chargeback threshold for the US drops from 2.5% to 1.0%; for international transactions, a 2.0% threshold takes effect later, from 2004-01-01 fact
- 2003-12-05: Paycom files an antitrust suit against MasterCard in the Eastern District of New York fact
- 2005: the district court dismisses the suit; the month, April 2005, comes only from search results estimate
- 2005-12-21: the Ninth Circuit decides the appeal in Paycom's suit against the intermediary, banks, and IBM (only as regards IBM); the defendants include companies and banks from the Bahamas, the British Virgin Islands, New Jersey, and Costa Rica, as well as IBM Denmark fact
- 2006-10-27: the Second Circuit affirms the dismissal of Paycom's suit against MasterCard fact
- 2010-10-15: an edition of the Visa rules with a separate section on high-risk IPSPs: a fine of $25,000 a month per merchant or IPSP, and after three violations in a year, $100,000 for every 30 days or a ban on signing high-risk merchants; a separate monitoring program with 100/100/1.00% thresholds for merchants from the list of high-risk categories
Lesser-known but significant facts
- The processor was itself a merchant of the network. The court describes Paycom as a purchaser of MasterCard's services that had signed a contract with an acquiring bank directly, not as an intermediary with no contractual relationship. The suit foundered on something else: the fines are assessed on banks, not on Paycom, and it was found to be an indirect payer.
- 2002: three storylines at once. In June a court in Michigan hears Paycom's own suit against an intermediary and a bank; on 2002-09-30 the rights holder Perfect 10 files suit against several billers, including Paycom; by 2002-11-01 Visa's IPSP rules take effect. In a little over a month, the processor came under pressure from two sides: the rights holder and the card network.
- Visa's 2002 fees were charged per company, not per URL. $750 at registration and $375 a year for each Sponsored Merchant (of which $500 and $250 go to Visa through the acquirer); reporting, meanwhile, went down to the URL level.
- The court noted that Visa's terms for CNP merchants were slightly better than MasterCard's, but competition did not affect MasterCard's policy. For a merchant, the choice of network was a lever, but a weak one.
Legend vs. the record
- Legend: the rules for high-risk were invented after 2010. The record: in 2002 Visa introduces separate rules for IPSPs with registration of every merchant, screening against TMF/MATCH, and reporting by URL; from 2003-10-01 the chargeback threshold for the US is 1.0%, and from 2004-01-01 it is 2.0% for international transactions; Paycom's suit against MasterCard over its policies on CNP merchants was filed in 2003. By 2010 all that appears is a codified edition with specific fines ($25,000 a month, $100,000 for every 30 days after three violations in a year) and 100/100/1.00% monitoring for merchants from the list of high-risk categories. Verdict: refuted. The rules did not appear after 2010; they were rewritten and tightened.
- Legend: cross-border processing was a loophole without rules. The record: in 2002 an IPSP could register a Sponsored Merchant only in a country where the merchant had a presence; MasterCard had Cross-Border Acquiring Rules, which Paycom called market division and challenged in court; Visa's 2010 edition provides for a $25,000 fine for illegal cross-border activity and narrow regional schemes. The price of getting around the rules is also documented, albeit in the plaintiff's version: the 1998–2001 chain of banks with refusals, incorrect registration, and late payouts. Verdict: refuted as far as the absence of rules goes; there were rules, and cross-border processing was a loophole only where they were not applied estimate. We did not obtain the text of the MasterCard rule itself, so the details of its wording are unknown.
- Legend: a processor can use the courts to force the card networks to change their rules. The record: Paycom's suit was dismissed at first instance and, on 2006-10-27, in the Second Circuit; the court pointed out that fines are assessed on acquirers, that Paycom is an indirect payer with no right to bring an antitrust suit, and that MasterCard has more than 20,000 member banks. Verdict: refuted.
- Legend: the processor pays the networks' fines. The record: the network fines the acquiring bank; passing the fine down the chain is common practice, but the claim that this happens almost always is the plaintiff's position, not an established fact. Visa's 2010 fines are also addressed to the acquirer. Verdict: partly true: the chain pays, and the processor is its middle link estimate.
The first growth lever
Epoch's lever was not the site and not its pricing but the ability to take on risk that banks turned down. According to the press in 2003, Paycom called itself the second-largest player in the niche, took an average of 15% per transaction, and claimed that MasterCard had debited more than $2.5 million from its account in a year in fines that it considered unjustified estimate. Growth here came at the price of risk: the higher the sites' chargeback rate, the higher the commission and the greater the need for capital and for banks willing to look at such a portfolio. The company covered this through several banks and jurisdictions (the US, the British Virgin Islands, the Bahamas, Denmark, Costa Rica, judging by the list of defendants in the suit; the banks and offshore companies themselves are named as parties, not as proven partners), and when Visa applied pressure in 2002 it acted together with its competitors. In 2003 the company told the press that it limited risk by selecting its clients and by the geography of the cards it accepted estimate.
The figures visible in the documents: $750 at registration and $375 a year; a 1.0% threshold versus the previous 2.5%; the $23 million suit is stated only in the press. Our estimate estimate: with a commission of about 15% and a 1.0% threshold, a processor survives as long as its clients' chargebacks stay within the network's thresholds.
The paired story
The pair is Segpay, a processor in the same market that entered it only after the IPSP rules had been introduced.
- Contrast in era: Epoch dates from 1996 by its own description, that is, from before the 2002 IPSP rules; Segpay, according to the company, launched in June 2005 as a European IPSP, when the registration regime was already in force.
- Contrast in jurisdictions: Epoch built a chain of American and offshore banks and argued with MasterCard over the cross-border rules; Segpay entered US acquiring only in March 2008, set up a British legal entity in 2011, received its first British payment institution authorization in 2013 (the regulator at the time was the FSA), and obtained a license from the Central Bank of Ireland in 2020 estimate.
- Litigating versus fitting in: Epoch sued MasterCard and lost (2006-10-27); Segpay invested in compliance and licenses.
- The common thread: both companies are processors for sites with elevated risk, dependent on the same chargeback thresholds and the same networks.
Parallels today
- PaymentKit (
paymentkit): multiple processors and automatic failover to guard against losing an acquirer; the trigger is Visa's monitoring programs. Epoch followed the same logic, only manually and through banks. view this project's dossier → - Senzia (
senzia): payments for high-risk merchants and geo-arbitrage, that is, picking a jurisdiction where a bank is willing to take on the risk. A direct heir of the multi-jurisdiction scheme. view this project's dossier → - SMM Growth Panel SaaS (
smm-growth-panel-saas): a merchant from a category that processors are afraid of, with the same question of who holds the chargebacks and at which level. view this project's dossier →
What a builder can take from this in 2026
- Read the network's rules, not retellings of them. The notion that this was invented recently is cured by a single PDF. Set up a table of Visa and Mastercard thresholds for your category and check it once a quarter.
- Count chargebacks by level. The fine goes to the acquirer, then to the processor, then to you; before launch, write into the contract who pays when the threshold is exceeded.
- Do not build a business on a single bank. The 1998–2001 chain shows the price of dependence: a change of bank means both refusals and delayed payouts (according to the plaintiff).
- Do not count on beating the network in court. Paycom's suit showed that a processor has no right to sue over fines paid by the bank. It is better to invest in reducing chargebacks than in lawyers.
- Register and report. Since 2002 the network has required merchant registration and reporting by URL; today monitoring programs do the same.
Discrepancies and what we could not verify
- Year of founding: the Paycom.net site and some of the profiles say 1996; the era in the season was chosen for the main storyline of the 2000s.
- The link between Epoch and Paycom: only the joint 2002 notice, the year 1996, and California; there is no document on a renaming. The 2001 snapshot of epoch.com is titled "EPOCH PARTNERS" and does not look like a payment service; that it was a different project is our inference from the title estimate.
- The amount of the suit ($23 million), the fines, and the 15% commission: only the 2003 business press, with the page opened in full; these sums are not in the court ruling. The article speaks of a filing in the Central District of California, while the 2d Cir. ruling concerns a case in the Eastern District of New York from 2003-12-05, so these may be different suits.
- The date of the first-instance dismissal: April 2005 comes from search results; the documents show only that appeal No. 05-1845 was opened in 2005.
- The year the legal entity Epoch.com LLC was founded: 1996 according to some profiles, 2004 according to others; the founders and a document on the Paycom → Epoch transition were not found.
- The claim that it was the first company in the world to pass an independent PCI DSS audit, in 2002, was not found on the epoch.com page rumor.
- Not obtained: the text of MasterCard's Cross-Border Acquiring Rules and the year they were introduced; MasterCard bulletins from 2000–2006; a document on partner banks after 2005; the fate of the 2003 suit in California.
- The description of the banks in 1998–2001 consists of the plaintiff's allegations; the court did not examine them on the merits.
Sources
Primary:
- 2d Cir. ruling, Paycom Billing Services v. MasterCard, 467 F.3d 283, 2006-10-27: https://www.courtlistener.com/opinion/8439517/paycom-billing-services-inc-v-mastercard-international-inc/
- W.D. Mich. ruling, 212 F. Supp. 2d 732, 2002-06-03: https://static.case.law/f-supp-2d/212/cases/0732-01.json
- 9th Cir. ruling, Paycom v. Phillips, 160 F. App'x 596, 2005-12-21: https://static.case.law/f-appx/160/cases/0596-01.json
- Visa International Operating Regulations, 2010-10-15: https://www.merchantservice.com/wp-content/uploads/2022/02/rules_for_visa_merchants.pdf
- 8-K/A Penthouse International, 2004-04-08: https://www.sec.gov/Archives/edgar/data/1164123/0000930413-04-001729.txt
- 10-K InterCept Inc for 2003: https://www.sec.gov/Archives/edgar/data/1054930/000119312504042388/d10k.htm
- Joint notice from the billers, 2002 (a thread with the full text): https://www.webhostingtalk.com/showthread.php?t=78510
- Snapshots of paycom.net from 2001-11-30 and 2004-12-31, and of epoch.com from 2001-11-09: http://web.archive.org/web/20011130064508/http://paycom.net:80/
Secondary:
- Business press, 2003: labusinessjournal.com
- Finextra, dismissal of the suit (from search results): https://www.finextra.com/pressarticle/3931/judge-dismisses-claims-brought-against-mastercard-by-paycom-billing-services
- Profiles of Epoch and Segpay (aggregators, from search results): https://paymentpop.com/merchant-accounts/epoch-payment-solutions-reviews/