Payment processing for direct response, continuity offers, and free-trial-to-paid funnels. Built for the ROSCA-compliant billing stack the bank wants to see.
Free-trial-to-paid and continuity offers are the highest-dispute payment models on the card networks; Stripe, Square, and PayPal treat the trial-to-paid mechanic as elevated risk and pull accounts on a portfolio review once the dispute pattern surfaces. The fix is a direct merchant account at an acquirer that openly underwrites direct response, with the consent flow rebuilt to ROSCA standards (clear disclosure before billing, express informed consent captured, one-click cancellation), the billing descriptor restructured for renewal recognition, and Verifi RDR plus structured representment configured at boarding.
Direct response marketing runs on continuity offers, infomercial-driven sales, telemarketing, and the free-trial-to-paid conversion that is responsible for an outsized share of every payment processor's chargeback volume. The FTC Restore Online Shoppers Confidence Act (ROSCA) sets the rules for the trial-to-paid handoff and the cancel-anytime flow. The card brands set the rules for billing descriptor clarity, recurring authorization disclosure, and dispute ratios. Generalist processors classify direct response high-risk on day one and most aggregators prohibit it outright. We place the file at acquiring banks that underwrite the vertical with documented policy, build the recurring billing stack to ROSCA standards so the consent record is defensible, and run representment evidence packages tuned to the disputes a continuity program will actually see.
The Restore Online Shoppers Confidence Act is the federal law that governs online negative-option enrollment, including free-trial-to-paid continuity offers. It requires clear disclosure of material terms before billing information is collected, express informed consent before charging, and a simple cancellation mechanism. Continuity programs that do not meet ROSCA generate disputes the bank will not defend, so the billing flow gets built to ROSCA standards from the start.
Sometimes for a short window and rarely for long. Both Stripe and PayPal's restricted-business policies make continuity, free-trial conversions, and direct response marketing difficult to operate, and most operators get terminated when the model becomes clear on a risk review. The cleaner path is a direct merchant account at an acquirer that underwrites continuity openly.
Three layers. First, Verifi RDR and Ethoca pre-dispute alerts pull eligible disputes back before they become chargebacks, with auto-refund and resolution rules tuned to the program. Second, representment with subscription-specific evidence packages on every dispute the alerts do not catch. Third, upstream policy and disclosure tuning so the structural ratio drops over 60 to 90 days. The combination keeps a clean continuity program under the VAMP dispute threshold.
Telemarketing campaigns get a compliance review against TCPA, the Telemarketing Sales Rule, state telemarketer registration where required, and the National Do Not Call Registry where applicable. Inbound campaigns triggered by TV or short-form video get reviewed against FTC claims standards. The review happens before the bank sees the file because telemarketing exposure is one of the fastest ways a continuity merchant account gets denied or pulled.
Standard merchant packet plus offer creative, sales page or video, terms of service with auto-renewal and cancellation language, refund policy, dispute history, processing statements if any, telemarketing scripts if applicable, and the consent record flow showing how the customer agrees before billing. We pre-review every file so the first version sent to the bank is the version that gets approved.