In reply to Philip Cohen.

Correct - if a merchant chooses to not upgrade to support EMV and processes a fraudulent EMV card the merchant is liable after 10/2015 - but what happens if the card is non EMV is a fraud and is processed on a non EMV enabled terminal - then what? Kind of intersting question. My point is that the liabilty in general is bening transfered from the issuer to the merchant - that is one of the "new" points.