Does the description disclose side effects, auth requirements, rate limits, or destructive behavior?
With no annotations, the description carries the full burden. It does disclose the shape of the data (windows broken down by five named gateways and three card networks), which tells the agent this is static reference content rather than per-merchant data. It says nothing about freshness (whether it reflects current network rules), jurisdiction variance, or return format.
Agents need to know what a tool does to the world before calling it. Descriptions should go beyond structured annotations to explain consequences.