International Private Finance Policy Statement on Treating Customers Fairly (TCF)
General risk assessment:
The firm is committed to the rules and general principles of the FCA and has close links with its clients. We have received zero complaints in the last 9 years. We have excellent recording and administrative systems and regularly review staff competence. We monitor levels of client care on a regular basis as we request client feedback at the end of every transaction and obtain electronic bi-annual client feedback questionnaires. This feedback is important as it helps us identify any areas which may require adjustments to our processes, practices or services. Good communication with our customers provides a better understanding of their requirements and ultimately builds trust between customer and firm. The firm’s remuneration structure is regularly reviewed to ensure that it does not cause any conflicts of interest. All of the above embodies TCF and why we assess our TCF risk as low. On an ongoing basis, we have the advantage of using The Compliance Factor as our outsourced compliance consultants. The Compliance Factor assesses our strengths and weaknesses in terms of TCF on an ongoing basis.
Financial promotions, correspondence and report letters:
It is the policy of the firm to attempt to make all correspondence and promotions with clients as clear, concise, simple, fair and not misleading. We attempt to make our ‘Reason Why’ letters as easy to understand as possible.
Advice and sales process:
We will at all times ensure that advice is appropriate and that due account has been taken of the client’s specific profile, needs, knowledge and attitude to risk. When assessing our client’s attitude to risk we will do our best to ensure that they understand what this means. We will always discuss the alternative methods of repayment, and selection criteria in detail with our clients. We will always obtain sufficient client information to understand their circumstances, needs and requirements. By completing fact finds in all cases, we will provide clients with suitable advice and an ongoing review of their mortgage requirements to ensure that they have access to competitive products. We will then give our clients the option to act upon these needs or reject them if they wish without pressure to proceed. We will always ensure that we disclose information in a way that is understandable to our clients whilst complying with FCA rules and requirements.
We will always ensure fair treatment:
If any policy exclusions or charges apply, we will bring these to our client’s attention without prompting and explain their effects during a phone conversation, client meeting, or where requested in writing. Flow of information between the firm and its customers: It is important that customers understand the nature of the services being offered by the firm and how they pay for them. The firm is an Independent Whole of market Mortgage Intermediary and operates on a selection of fee, non-fee and combination of both based options.
We will always be open with our clients and will, if relevant, communicate with them on any matters that might affect them.
Accurate and timely record keeping:
It is important that we keep accurate and adequate records of customer needs and instructions at each stage of the sales process. It is also important that the administration of a client’s transaction is carried out efficiently. Accurate records are kept to record all advice and information given and received. If a customer requires information, we will be open and responsive to their request, replying in a timely manner. We will be mindful of the need to review customer information to ensure its accuracy and to comply with the Data Protection Act. This will enable us to respond fairly to our customers in the unfortunate event of a customer dispute. At all times we will ensure that client data remains confidential.
Disputes and complaint handling:
We already have in place a written complaints procedure that every member of staff has read and understood. It is important that disputes are handled sympathetically and that the firm is open and honest about its mistakes. We recognise that a well-handled complaint can prevent a potentially difficult situation escalating and can ultimately retain customer loyalty.
We will be open in our complaint handling procedures and inform customers of areas outside of their complaint, if applicable, where we may have discovered errors of which they may not be aware. A complaint does not automatically lead to compensation, putting the matter right and offering an apology may often be more than enough. Customers readily accept that errors occur and in many cases are gratified that a firm will accept that they are fallible and keen to rectify the situation.
We acknowledge that the dealings of all the staff affect whether customers are treated fairly. Having members of staff who are adequately trained and mature enough to acknowledge whether a task is outside their expertise is important in this regard. Continuous professional development is important for all members of staff to maintain skills and competence. We also encourage our staff to obtain professional examinations.
Information from Lenders, Insurers & Providers:
It is important that staff understand and consider documentation supplied by Lenders, Insurers & Providers, to ensure that they fully understand the features and risks associated with the product being recommended. Staff should also be in a position to make an informed judgement on the content and opinions ex[pressed in any Lenders, Insurers and Providers.
Keeping up to date:
The Directors and The Compliance Factor will continue to monitor further FCA guidance, to ensure that TCF is consistently built into the overall culture of the business, at all times.
Your home or property may be repossessed if you do not keep up repayments on your mortgage. We can be paid by commission, a fee or a combination of both. Our typical client fee is £250 upfront and a percentage of the loan amount on completion of the client’s property purchase.