Insert your favorite Vince Lombardi cliché here, but a successful marketing campaign really is a team effort.  So what should a payment processor or other service provider do if they spot signs that something’s amiss with a client’s promotion?  There’s no one-size-fits-all answer, but as savvy members of the industry will tell you, it’s never a good practice to look the other way.

That’s the lesson of a recent FTC settlement against a payment processor and two of its corporate officers.  According to the FTC, the company continued to process payments for merchants even though an astronomical percentage of the transactions were rejected and returned by consumers' banks.  For one merchant, more than 83% of total attempted debits were sent back.  For another, the return rate topped 70%.  With rates like that, the FTC alleged that the processor “knew, or should have known, that its client merchants routinely fail to obtain the consumers' authorization for such debit."

The upshot for the company:  a hefty financial settlement, a lifetime ban from offering certain types of payment processing services, and a court order requiring them to monitor their remaining clients closely.  So what should payment processors and others do to remain on the right side of the law?

Be accountable with accounts.  When you spot the telltale signs of trouble, it’s unwise to bury your head in the sand.  Don't ignore information that would raise the eyebrow of a reasonable businessperson.

Keep an eye on return rates.  High return rates for payments you process — whether it's the total number, the percentage returned, or the percentage designated by a consumer as unauthorized or "stop payment" — should trigger warning bells, signaling a need to take a closer look at what's going on with the merchant.

Take an interest.  Familiarize yourself with your clients and monitor their practices.  This may include periodically reviewing their websites, checking what’s being said about them on consumer sites, and doing other routine diligence into their products and practices.  Ask the questions that need to be asked.  Legitimate businesses don't mind your interest.  If you’ve ever been in the middle seat next to an ebullient entrepreneur, you know that executives at most reputable companies are only too happy to talk shop.

Consider the company you keep.  If a business’ dealings with consumers are on the questionable side, it stands to reason their B2B practices may merit scrutiny, too.  If something appears amiss, take immediate action to protect consumers — which in turn, could protect your business, your reputation, and your bottom line.

Lesley Fair is an attorney with the FTC’s Bureau of Consumer Protection.