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My interpretation of the policy is that this is going to be the way that it works for most SAS merchants now
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My interpretation (and I'm not compliance for SAS...and I'm not speaking for SAS) is that the current FW toolbar would NOT meet the new SAS policy unless no SAS merchant was promoted through it. If that happened, then yes FW could remain in the SAS network. If that didn't happen, then FW could face termination from SAS. Personally, I think Tim would be smart enough to just not do any SAS merchant promotion through the toolbar.
If SAS merchant's are not promoted via the toolbar, then you are protected with your SAS merchants no? Maybe not CJ, LS, GAN..but SAS? I don't think that CJ, LS and GAN policy is SAS's responsibility.
Although you will have 2 very glaring different policies to show your merchants on those networks now.