Tiltproof Incorporated Document No.

Effective Date Revision Date Approval

Chargeback Repayment

01/04/2008 5/01/2008 GN SM

1.0 Purpose:

This document establishes how to handle emails regarding chargebacks.

2.0 Persons Affected:

1) Fraud Analysts (FAs)

3.0 Forms, Checklists, Flowchart:

1) Printable version: \\tpfs1nw\workflow$\HANDBOOK-FRAUD\Print Versions\Fraud Handbook\Chargeback Repayment.doc

4.0 Policy:

1) If a player has a debt with Full Tilt Poker (FTP) they must repay the full amount owed before we will reopen their account. 2) A chargeback is incurred by FTP when a player disputes a debit for a deposit appearing on their credit card statement and the card issuer reverses the funds. A) Handling Closed Account Inquiries Player is Unaware of the Chargeback. 1) Determine the fraud risk of the account by reviewing the following in WAT: a) Play history (look for evidence of chip dumping). b) Previous use of other payment processors. c) How long the player has been on the site. 2) If the chargeback appears to be unintentional based on the assessment of the above factors, send the player frd.chargeback. 3) If the chargeback appears to be deliberate based on the assessment of the above factors: a) Determine the players serials as per 2.4.2.9.8 Login Details Tab (Know101). b) Trap the players account and serials as per 3.3.23 Trapped, Paused or Closed Accounts.

5.0 Procedure:

Tiltproof Incorporated c) Notate the account with: TRP: Player is trapped because they initiated a Credit Card chargeback. Trapped serials: [List serials here]. Player is banned from FTP, unless Fraud management reverses the decision.

d) Send the player frd.cb.guilt. B) Handling Responses to frd.chargeback. 1) If the player does not want to repay the chargeback, inform them their account will remain closed until they repay their debt. 2) If the player wants to repay their debt, review their transaction history as per 2.4.2.9.3 Transaction History Tab (Know101) to verify if any funds have been seized from their account for the chargeback. a) If we seized an amount less than the amount of the debt, proceed to C) Handling Requests to Deposit Funds Owed. We seized $50 from their account, but their debt is $200. b) If we seized an amount greater than the amount of the debt, request a deposit as per 5.17 Requesting a Seizure or Deposit. We seized $200 from their account, but their debt is $50. c) If no funds have been seized from the account, compare the account balance to the amount of the debt. i) If the account balance is less than the amount of the debt, proceed to C) Handling Requests to Deposit Funds Owed. Their account balance is $50, but their debt is $200. ii) If the account balance is more than the amount of the debt, request a seizure as per 5.17 Requesting a Seizure or Deposit. Their account balance is $200, but their debt is $50. C) Handling Requests to Deposit Funds Owed 1) Under the Security and Limits tab in WAT, click on the following rights to disable them: No Chat No Mix No Ring Games No Tourn 2) Ensure that the following rights remain enabled: No Txfr No Dep 3) Notate the note box with your initials. 4) Select Save. 5) Under the Accounts and Limits tab in WAT, locate the Player to Player account listed under Account Type. a) Select the Edit button corresponding to this account.

Tiltproof Incorporated b) Reduce the Withdrawal Amounts (d/w/m) limit to $0/$0/$0. c) Notate the note box with your initials. d) Select Submit. 6) Notate the account with: UNPAUS: Unpaused and placed restrictions on account. Player wants to repay debt of $_____. Once player has deposited and emails in, pause account and route email to the Credit Card Dispute queue in Kana. Notate the Alerts section with: DO NOT APPROVE ANY OUTGOING P2P TRANSFERS. Alert Fraud team member should this player attempt and outgoing P2P.

7)

8) Unpause the account in WAT as per 3.3.23 Trapped, Paused or Closed Accounts. 9) Send the player frd.cb.repay. 10) When the player confirms that the funds are in their account: a) If the funds are sufficient, request a seizure as per 5.17 Requesting a Seizure or Deposit. b) If the funds do not cover the amount owed, email the player to inform them more funds must be deposited. Seizure Confirmation Received 1) Send the player frd.cb.open. 2) Under the Security and Limits tab in WAT, click on the following rights to enable them: No Chat No Mix No Ring Games No Tourn 3) Notate the note box with your initials. 4) Select Save. 5) Under the Accounts and Limits tab in WAT, locate the Player to Player account listed under Account Type. a) Select the Edit button corresponding to this account. b) Increase the Withdrawal Amounts (d/w/m) limit to $150/$300/$600. c) Notate the note box with your initials. d) Select Submit. 6) If the players account was trapped: a) Untrap the account and serial(s) as per 3.3.23 Trapped, Paused or Closed Accounts.

Tiltproof Incorporated b) Notate the account with: UNTRP: Player has repaid chargeback and is currently in good standing. Untrapped serials [List serials here].

7) If the players account was paused: a) Unpause as per 3.3.23 Trapped, Paused or Closed Accounts. b) Notate the account with: UNPAUS: Player has repaid chargeback and is currently in good standing.

8) Remove the note in the Alerts section. 9) If the amount was paid in full, enter the following in Chargeback-NSF Repayment list.xls in [S:\FTP_Fraud_Department\DAILY DEPS+SEIZURES]: a) Player ID b) Amount of repayment Full amount c) Date of repayment d) Fraud Analyst 10) Log into <https://admin.iesnare.com/index.php>. Subscriber: FullTilt Poker. 11) Under Account Search, enter the Player IX.

12) Expand Chains To Evidence.

13) Select the evidence. Evidence will need to be retracted this way for all devices listed.

Tiltproof Incorporated 14) Select Retract Evidence.

15)

Notate: Chbk Repaid

16) Select Retract. Wait to see the final confirmation screen.

17) Retract evidence for all devices blocked by Iovation/IE Snare. 18) Go to <http://cs.intbiz.dubtilt.local/iesnare.php> a) Enter the appropriate information: Player Key: FTP Player index# Evidence Type: Choose 1-1 or 1-4, depending on the evidence type entered for the original NSF/CB. If there is no evidence in IE Snare for this CB/NSF, choose 1-4 for ACH Intabill NSFs, and 1-1 for all others. The type of evidence originally entered for the CB/NSF can be found by clicking on the link IeSnare-View Player. Action Taken: Retracted Admin User: First initial and last name of agent entering

Tiltproof Incorporated information. jslade or gnguyen Comments: Reason for the retraction. CC CB repaid, eChecks NSF repaid b) Select Submit. E) Deposit Confirmation Received 1) Send the player frd.cb.open. 2) If the players account was trapped: a) Untrap the account and serial(s) as per 3.3.23 Trapped, Paused or Closed Accounts. b) Notate the account with: UNTRP: Player has repaid chargeback and is currently in good standing. Untrapped serials [List serials here].

3) If the players account was paused: a) Unpause as per 3.3.23 Trapped, Paused or Closed Accounts. b) Notate the account with: UNPAUS: Player has repaid chargeback and is currently in good standing.

6.0 Definitions:

7.0 Revision History:

May 1/08 Proc D) info to submit to dubtilt iesnare added Feb 26/08 Proc D) update spreadsheet and retract evidence from devices Jan 9/08 Proc C) notate the Alerts section Proc D) remove the Alerts note