Green Sheet interviews Boost Payment Solutions' Dean M. Leavitt

Visa's retirement of its Level 2 interchange program has accelerated a major shift in how enterprises manage commercial card payments, forcing providers and merchants to rethink long-standing approaches to transaction data, automation and interchange optimization. As the Commercial Enhanced Data Program, or CEDP, becomes the new standard for qualifying commercial card transactions, organizations are facing growing pressure to maintain validated invoice-level data across increasingly complex payment environments.

Dean M. Leavitt, founder and CEO of Boost Payment Solutions, has been closely involved in helping enterprises and payment providers navigate the transition. In this Q&A, he discusses the operational and financial implications of CEDP, why maintaining verified status is proving difficult for many organizations, and how stronger straight-through processing infrastructure can help improve interchange economics, cash flow predictability and broader payment operations.

Green Sheet: How significant was Visa's retirement of its Level 2 interchange program for enterprises relying on commercial card payments?

Dean M. Leavitt: CEDP represents a meaningful inflection point for commercial card payments. It changes not only how transactions are submitted into Visa's ecosystem, but how they are evaluated, validated and priced. Under CEDP, your data ultimately determines your rate.

More broadly, it raises the standard for data quality across the entire payment chain. The biggest shift is reduced tolerance for incomplete or placeholder data. Qualification now depends on validated, invoice-level data. If that data cannot be verified, the transaction does not receive the intended rate treatment.

The financial impact is meaningful. Visa structured the program to reward suppliers that consistently provide high-quality data with roughly a 15-basis-point reduction in interchange, partially offset by a 5-basis-point participation fee.

To realize those benefits consistently, providers need to ensure their merchants/suppliers can meet the standard over time. Those that cannot may see acceptance costs rise, in some cases by 100 basis points or more until verified status is achieved.

In B2B payments, where transaction values are high and margins can be tight, that difference has a direct impact across a provider's merchant/supplier base, affecting cost, cash flow, reconciliation activities and overall acceptance economics.

GS: Why are many organizations struggling to maintain CEDP verification even after initially achieving compliance?

DML: CEDP introduces two requirements that need to be managed together: transaction-level qualification and supplier-level verification.

Qualification is determined per transaction, while verification is established over time based on consistency. Without verification, even transactions with the right data may initially process at higher rates and be adjusted up to 90 days later, introducing timing and cash flow considerations.

This is where many providers run into challenges across their merchant base. Getting a few transactions right is one thing. Maintaining that consistency across real-world payment volume, across different buyers, invoice formats, ERP systems and processors, is much more complex.

In most cases, the issue is not that the data is unavailable, but that it is fragmented or tied to manual workflows. If that data cannot move cleanly across the payment chain, maintaining verification becomes difficult. Every participant plays a role. If data is lost or misformatted at any point, the transaction can fail to qualify.

CEDP is not a one-time compliance exercise. It requires ongoing data discipline.

GS: What operational or financial risks do enterprises face if they continue relying on legacy Level 2 data practices?

DML: The most immediate risk is a higher cost of acceptance across their merchant/supplier base. Under CEDP, the most favorable interchange rates are tied to qualified and verified transactions. If that standard is not met, transactions default to higher commercial rates, which vary by card type but can be materially higher.

In large-ticket scenarios, the gap between qualified and standard rates can be significant. Applied across meaningful volume, even modest differences quickly translate into incremental cost.

There is also a timing element. Merchants may submit qualifying data but remain unverified, which means transactions can process at higher rates and only be adjusted up to 90 days later, once validation is complete.

That creates working capital and reconciliation friction. Even if the benefit is eventually recovered, delayed reimbursement changes the economics compared to receiving the correct rate at the time of transaction. That stands in contrast to models where the correct economics are applied upfront.

Operationally, legacy approaches create more manual follow-up when transactions do not qualify. Merchant finance teams often need to investigate why data was rejected, where it was lost and when adjustments will be applied, reducing predictability and adding manual effort.

Over time, those cost, timing and operational issues can lead to merchant dissatisfaction, increasing the risk of attrition and portfolio instability for acquirers and merchant service providers.

GS: How does CEDP change the way enterprises must manage transaction data and payment workflows?

DML: CEDP effectively turns enhanced data from a supporting element into a pricing requirement. Historically, many organizations treated enhanced data as something that could be appended to the payment. Under CEDP, that approach is no longer sufficient. Data needs to be captured, structured and validated before the transaction is submitted.

This requires much tighter coordination across the payment chain, something providers are now expected to support for their merchants. The supplier and/or buyer (for straight through processed transactions) must provide complete and accurate data, the processor must transmit it correctly and Visa evaluates both the transaction and the supplier's consistency over time.

Any process that relies on manual intervention, whether emails, portals or file uploads, introduces risk. Many merchants still rely on AR teams pulling card details from emails or portals, entering information manually and reconciling afterward. That creates multiple points where data can be lost, truncated or misapplied.

This is why automation matters. The ability to consistently capture and transmit clean data determines who can reliably qualify and maintain preferred rates. In practice, that means moving toward straight-through processing, where data is automatically parsed, captured, validated and transmitted without manual intervention.

This is where payments-as-a-service models become critical. Rather than building and maintaining these capabilities internally, providers can leverage a CEDP-ready gateway that handles parsing, validation and submission end to end, ensuring every transaction meets Visa's requirements and helping drive qualification and Verified status across their merchant base.

By embedding STP capabilities directly into existing workflows, providers can get merchants CEDP-ready quickly without significant technical investment or disruption.

GS: What separates organizations successfully optimizing interchange costs in the post-Level 2 environment from those falling behind?

DML: The organizations performing well in this environment were already thinking beyond compliance. They had strong enhanced data capabilities built directly into their payment workflows before CEDP became a requirement.

As a result, this was not a significant operational reset for them. Their infrastructure was already designed to handle structured, validated data at scale. For merchant service providers, that often meant having the right infrastructure in place to support merchants consistently.

At Boost, this has been a consistent focus. We have been building capabilities to capture, enrich, validate and transmit invoice-level data well before these changes. CEDP was not a disruption, it was a continuation.

We are already seeing this play out in the data. Across more than $1.2 billion in qualifying transaction volume since last October, Boost has helped customers save approximately $14.7 million in acceptance costs since the CEDP program launched in October 2025. That equates to roughly a 44 percent reduction in interchange-related fees compared to standard card-not-present rates.

We have also consistently seen that 99.99 percent of transactions processed through our platform meet CEDP requirements. In short, we are delivering the optimization of Visa-branded card acceptance costs to suppliers that they are entitled to under the CEDP program.

Where organizations fall behind is by relying on legacy assumptions. Qualification under Level 2 or even level 3 data rates does not translate to success under CEDP. The standard is higher and requires consistency and a more automated approach.

More broadly, CEDP is not just a rule change, it is a signal of where commercial payments are headed.

GS: Beyond interchange savings, how can stronger commercial card data infrastructure improve working capital management and broader financial operations?

DML: Interchange savings matter, but they are only the starting point. The bigger shift happens when you move to a true straight-through processing model. When payments flow from invoice to settlement without manual intervention, you eliminate much of the friction that has historically made commercial card acceptance – especially e-mail based virtual cards - difficult to scale.

With the right STP infrastructure, payments can move directly from the buyer to the supplier's acquirer without relying on cumbersome and costly manual activities. Data is automatically parsed, organized per acquirer requirements and validated in real time, so every transaction is complete and compliant before it is submitted.

That has a direct impact on working capital and manual reconciliation activities. Transactions process cleanly the first time, at the right economics, without delays tied to exceptions or post-settlement adjustments. Merchants do not have to wait for reimbursements or chase down errors, so cash flow becomes more predictable.

It also changes the operating model. Instead of finance teams keying in data or reconciling transactions after the fact, those processes are handled automatically. That reduces manual effort, improves cost predictability and allows teams to focus on higher-value work.

There is also a security benefit. When sensitive payment data is captured and transmitted through secure automated workflows rather than being pulled from emails or portals, exposure is reduced and controls are stronger.

For providers, this ultimately enables them to deliver a better experience to their merchants without taking on the complexity of building and managing it themselves. CEDP is pushing the industry in this direction, but the broader opportunity is bigger than compliance. Organizations that adopt true straight-through processing are not just optimizing interchange, they are modernizing how payments move through their business.

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