Financial Promotion

In the UK, the consumer credit industry is highly regulated by the Financial Conduct Authority (“FCA”), who authorise and monitor all firms involved in providing or even simply introducing customers to credit products (known as credit broking). This may include software platforms or merchants who offer their customers finance within their experience.
Platform partners using Deko's technology to offer customers finance to buy goods or services, will be introducing them to a credit provider. While some finance products are currently exempt from regulation, it is important that you know what legal and regulatory obligations you will have - including when you're promoting finance.

Deko is regulated by the FCA. By integrating the Deko Wallet, you have the possibility to embed finance into your site without any additional regulatory obligations of your own, provided that you do not publish any messaging in your experience which explicitly introduces or promotes the availability of regulated finance products.
Not Finance Promotion
- Start Checkout or open the Deko Wallet using a link or button natively on your site with non-finance specific messaging such as "click here to explore alternative payment options" or "find out more about alternative ways to pay"

Finance Promotion
- Using the Deko Wallet to promote finance natively in your site or experience by showing the tile
- Using the Deko Wallet to show finance offers natively in your site or experience showing a tagline
- Any other text, images or banners you implement natively in your site or experience that promote finance

Lender ApprovalIf you want to remain outside regulatory scope and avoid finance promotion requirements then the lender (or lenders) providing the finance offers in your platform may enforce other requirements for how you present finance on your site. Even if your platform is FCA authorised, the lender or Deko may need to approve any finance promotions you publish.
Why Financial Promotion is important
Platforms and businesses offering credit to customers must be clear about the costs and risks involved in taking out a loan or other forms of finance to pay for goods or services. The FCA recently focused on how firms advertising finance help their customers understand these costs and how the financial product works.
Therefore if you are presenting financial promotions, you must be authorised by the FCA and you will need to ensure your financial promotions are FCA compliant. This includes accurately representing the available finance and terms and not using misleading text such as ‘no credit check’, ‘guaranteed loan’ and ‘pre-approved’.
For regulated finance products, promotional text or images must include the Representative APR (typical rate of interest offered) or Representative Example (typical loan terms offered) where necessary. Deko can provide further guidance should you decide to seek the necessary FCA authorisation to promote finance.
Regulation by Finance Product
Only a limited number of finance products are currently exempt from FCA authorisation and associated regulatory obligations, including adhering to the guidance on Financial Promotion outlined in this guide:
Interest Rate | Repayment Term | Finance Product |
---|---|---|
0% | Up to 12 months | Exempt from regulation |
0% | Over 12 months | Regulated by the FCA |
Not 0% | Up to 12 months | Regulated by the FCA |
Not 0% | Over 12 months | Regulated by the FCA |
White labelling
Larger software platforms and partners have the option to co-brand or even white label the Deko Wallet embedded finance solution. It is not possible to fully white label Deko's technology unless you are fully authorised by the FCA and not relying in some part on Deko's FCA credit broking permission.
For other partners we can co-brand the Deko Wallet. This means finance can be presented under your own target credit brand (and this can appear alongside links on your site - even non financial promotion) provided it shows as "Powered by Deko" and includes a clear disclosure about Deko as the credit broker.

Options to be Authorised
To maximise the success of your embedded finance, you may decide that FCA authorisation gives you more freedom to promote finance and tailor the proposition under your brand. You have the option to apply for authorisation direct from the FCA, or to be an "authorised representative" of an FCA regulated partner.
If you're authorised as a credit broker and introducing customers to Deko or any of our lenders, it’s also vital that you include a clear credit brokering disclosure alongside promotions to ensure that customers understand the nature of the regulated service you are performing, your FCA permission and firm reference number.
Your Deko Account Manager can advise you of your options.
Updated 8 months ago