Pretty much all of the allegations with respect to Visa come...

Pretty much all of the allegations with respect to Visa come back to ISX not disclosing to the market about "violationof VISA Rule ID #0000652 and VISA’s seriousconcerns...."

Given that Visa is a commercial, for profit business, and as others have pointed out, is not a regulator and could have a conflict of interest, I'm really not sure how much weight Visa listing rule XXX carries. So it all comes down to whether of not ISX should have disclosed the market about Visa rule ID #0000652 or just have said "we're not in business with Visa anymore" as they did.

Either way, I think it's on the lower end of disclosure breaches scale, thus my surprise that it takes up 50% of the contents of SOC. That's if it even is a breach as the court will first need to agree that the Visa suspension was material to ISX.