Your Obligations as an IAR

Responsibilities and Boundaries for IARs Introducing Black Horse FlexPay

Black Horse FlexPay is a regulated credit product. Merchants must be authorised by the Financial Conduct Authority (FCA) to carry out credit broking activities and hold the appropriate permissions to introduce customers to Black Horse FlexPay.

If you are a merchant who is operating as an Introducer Appointed Representative (IAR) of MBNA Ltd, you may carry out limited credit broking activities under the regulatory permissions of MBNA Ltd as your appointed principal.

This page explains how you may safely introduce customers to Black Horse FlexPay as an Introducer Appointed Representative (IAR) of MBNA Ltd and where your involvement in the finance journey must end.

How you can introduce finance safely (as an IAR of MBNA Ltd)

You may:

• Inform customers that finance is available
• Tell customers who the lender is and provide lender contact details where appropriate
• Direct customers to the Black Horse FlexPay website or finance page on your own website to apply or obtain further information
• Direct customers to Black Horse FlexPay Customer Support if the customer has questions about applying for finance.
• Promote finance through non-interactive marketing channels, using the approved material we provide, including:
  • Websites
  • Emails or letters
  • Social media
• Please refer to the relevant sections of the Communications Guide for detailed guidance on compliant marketing and customer communications or speak to us about your specific needs.

Where your involvement in the finance journey must end (as an IAR of MBNA Ltd)

You must not:

• Assist customers with a finance application or complete an application on their behalf
• Discuss or explain finance product details, including (but not limited to) APRs, repayment terms, or eligibility
• Promote or invite customers to apply for finance during real-time interactions, including:
  • Telephone conversations
  • Live chat or chatbot interactions
  • Sales or click-and-collect discussions
• Answer customer questions about the Black Horse FlexPay product or the application process.

Marketing, Advertising and Financial Promotions

To ensure you communicate about FlexPay in a compliant way, only use the approved marketing materials and wording we provide. If you need something in a different format or size, please contact us and we'll be happy to help.

If you need to include Black Horse FlexPay in any marketing or customer communications, please email [email protected] and we'll provide the correct approved materials.

Even when using approved materials, you are responsible for ensuring your communications are used correctly and comply with applicable requirements.

You must:

• Only use communications about Black Horse FlexPay that have been approved by MBNA
• Ensure all communications are clear, fair and not misleading
• Comply with FCA rules, ASA requirements and all applicable advertising standards
• Comply with CAP Code
• Publish any required information about your credit broking activity using the wording we provide, and make sure it appears on your website and in relevant customer communications. If you're unsure what needs to be included, please speak to us for guidance
• You must submit any communications to us for approval before publication.

Support

Account Managers are on hand to provide further support or answer any questions you may have. Please email: [email protected]