James DeLuccia IV noticed that Discover has officially matched their merchant levels to Visa (sorta). While this is a big step for Discover, I think most will find that they become Level 1 merchants of Visa before they become Level 1 merchants of Discover.
There are exceptions. Some merchants are exclusively Discover. Those merchants will have to double check their levels (if Discover has not already told them they are a Level 1) to see if they have new compliance requirements.
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