Legal Disclosures

Your credit broking permissions

Black Horse FlexPay is a regulated credit product. To offer this product on your website, you must retain your credit broking permissions for the entire time you offer the product and display the details on your website and emails. Your credit broking permission may have been obtained in one of the following ways:

• You may be a regulated credit broker with permission obtained directly from the Financial Conduct Authority (FCA).
• You may have permission as an appointed representative (AR) or as an introducer appointed representative (IAR) of a third party, your principal, who has extended their credit broking permission to you.
• In some instances, you may be an IAR of MBNA Limited.

Credit broking disclosures

If you are a regulated credit broker or AR/IAR of another principal, we would encourage you to seek your own legal advice or speak to your principal to ensure that the content and presentation of the disclosures comply with applicable law and regulations, including the FCA Handbook.

Your credit broking disclosure must be visible on all webpages and emails where you are promoting Black Horse FlexPay.

If you are an IAR of MBNA Ltd, we will tell you separately what disclosure wording to use, what it should look like on the webpage or email, and where it should be placed. The disclosure will include a statement that you are an appointed representative of MBNA Ltd who is authorised and regulated by the FCA.

Offering multiple credit or finance options

If you promote or advertise any other credit or finance options in addition to Black Horse FlexPay, you must ensure:

• That there is no confusion between those options and Black Horse FlexPay, and that you keep Black Horse FlexPay separate from them.
• That the Black Horse FlexPay banners are not used or placed in a way that could confuse or mislead the customer, i.e. you must avoid the risk of a customer misunderstanding what the Black Horse FlexPay product is because of banners or information about other credit products.
• That you tell Black Horse FlexPay if you receive any queries or complaints from customers or regulators regarding the advertising of Black Horse FlexPay, or how you advertise or disclose information generally which could also negatively impact customers who are introduced to Black Horse FlexPay.

 Mandatory disclosures on your emails

For all email communications containing a banner or information about Black Horse FlexPay, you must make the appropriate disclosures regarding your credit broking activities, as well as information about Black Horse, a trading style of MBNA Limited.

Please include the following wording in the footer of all emails promoting Black Horse FlexPay:

Black Horse is a trading style of MBNA Limited. MBNA Limited Registered Office:
Cawley House, Chester Business Park, Chester CH4 9FB. Registered in England and Wales number 02783251. Authorised and regulated by the Financial Conduct Authority. MBNA Limited is also authorised by the Financial Conduct Authority under the Payment Services Regulations 2017, register number 204487, for the provision of payment services.