Issuance of credit card with revolving limit
We acted as sole counsel in the end-to-end launch of a revolving-limit credit-card product for a small payment-institution and one of the market’s most prominent consumer-lending brands. The mandate began at concept stage and extended through commercial go-live.
We first confirmed the product’s regulatory perimeter, aligning its structure with the Polish Payment Services Act, the Consumer Credit Act and all pro-consumer provisions issued by the Office of Competition and Consumer Protection, then remodelled the institution’s internal document to accommodate card issuance, credit-limit management, and card managing operations. Our team drafted client-facing documentation (credit-card agreement, tariff, marketing disclaimers, pre-contractual information, complaints procedure).
Operational roll-out required detailed mapping of every stage of the customer lifecycle: remote on-boarding, card personalisation, transaction authorisation, monthly statements, debt-collection triggers and dispute resolution. We designed those flows and prepared the supporting policies. In parallel, the company negotiated technology and data processing agreements with the card service provider, settlement agreements, and agreements with the card organization, ensuring compliance with statutory restrictions on outsourcing and data protection, as well as with the expectations of the financial supervisory authority in Poland.
The project culminated in a coordinated launch plan that enabled the client to issue its first credit cards on schedule while preserving full compliance with local regulatory standards. Our advice enabled the client to structure a future-proof business model.
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We continue to work with the client – a small payment institution, providing payment services: issuing credit cards and providing payment credit to consumers.
We continue to work with the client – a leading payment institution. Due to changes in the legal environment and the commencement of application of Regulation (EU) 2022/2554 of the European Parliament and of the Council of December 14, 2022 on the operational digital resilience of the financial sector and amending Regulations (EC) No. 1060/2009, (EU) No. 648/2012, (EU) No. 600/2014, (EU) No. 909/2014 and (EU) 2016/1011 (the DORA Regulation), the client asked us to prepare the necessary documentation and adapt its operations to the requirements of the DORA Regulation.