Cobrand teams: a lot of pre-2024 agreements just changed economic effect on April 18
This is the Level 2 sunset colliding with Level 2/3 carve-out language. Pull the agreement and the April Visa invoice detail before the next quarterly true-up.
(Part 2 of 5 in the April 2026 Visa Package series)
A lot of cobrand revenue share agreements explicitly excluded Level 2 and Level 3 incentive rates from the share calculation. The drafters didn't anticipate Visa retiring those programs. Now Level 2 is gone, CEDP has replaced Level 3, and what the exclusion language actually applies to has shifted. Depending on how the agreement was written, you're either pulling volume into the share calculation that used to be excluded, or carving volume out that used to be included.
The pattern we've seen: legal didn't flag this because legal isn't tracking interchange program changes. Finance didn't flag it because finance isn't reading cobrand contract language. It falls in the gap between functions.
The exposure can be meaningful. On affected commercial transactions, the rate economics can move by hundreds of basis points, even when the total program impact is smaller. The quarterly true-up surfaces it, and by then the partner conversation is reactive.
This week: pull your top 10 cobrand agreements and search for "Level 2," "Level 3," "enhanced data," and "incentive rate." Cross-reference what the language actually says against current CEDP economics. Document the gap.
If you want a second set of eyes on how your agreement defines the exclusions post-April, happy to compare notes.
