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If Orbital is unable to explain what changes you need to make to be compliant, maybe you should soft-drop them?
Lower them in your cascade billing rotation to keep your rebillers alive and maybe process a few sales a month to keep some activity. When they ask why the drop in volume, just tell them that traffic has dropped (or any other reason you can think of).
Personally, I'd be weary of continuing with a processor that can't communicate what needs to be done to keep your account alive.
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