Compliance posture
Onboarding, monitoring and reserves are designed around one idea: every participant's conduct affects the whole program. These are the rules each one is built to and the thresholds it is measured against.
Request early accessFor card funding, which follows launch, BlackOak is being designed as the merchant of record. In that structure sub-merchants have no individual identifier of their own, so dispute and monitoring ratios attribute at portfolio level. One participant's conduct is therefore everyone's exposure, which is the reason per-participant monitoring exists at all: it protects the whole book rather than policing a single account.
Applications are assessed against named rules rather than an opaque score. An applicant is told why an application needs review, except where the law does not allow us to say. Automatic decline is reserved for two hard gates: a prohibited business category and a confirmed synthetic identity. A sanctions or other list match goes to compliance review and our banking partner; it is never an automatic decline. Everything else reaches a human.
Beneficial ownership is collected to the 25% threshold with a named control person, and percentages must reconcile. Non-documentary verification is used where it is permitted and held to the same standard for owners as for applicants, with document capture as a step-up rather than a default.
Visa's VAMP and Mastercard's Excessive Chargeback program both publish their thresholds and both report about a month late. The design is to carry BlackOak's own daily estimate beside the network's own figure, so a participant learns where they stand before the network tells them.
A reserve is computed from measured exposure — delivery lag, dispute and return history, refund rate, concentration, and time on book — rather than from a category label. Each input is shown with the participant's own current value, and a material change carries advance notice naming the input that moved.
Compliance decides what BlackOak is obliged to collect and monitor. Security decides what happens to it afterwards, and who is able to see it.
Diligence · Partners · Program sponsors
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