Moneyway Welcome Pack - Procedure Guide - Flipbook - Page 22
Procedure Guide
Commission disclosure
In addition to including information regarding
昀椀nancial arrangements with lenders in customer
communications, you must disclose that you will
receive a commission from Secure Trust Bank
PLC before the customer submits an application
for 昀椀nance.
You must disclose the amount of commission
where the customer requests this information.
Whilst you are not currently required to disclose
the amount of commission unless the customer
requests, you may choose to disclose the amount
in any case so the customer is in a fully informed
position. You should retain a record of such
disclosures for future reference.
Vulnerable customers
The FCA de昀椀nes a vulnerable customer
as “Someone who, due to their personal
circumstances, is especially susceptible to
harm, particularly when a 昀椀rm is not acting with
appropriate levels of care.” As a distributor of our
Product and as the 昀椀rst point of contact with the
customer, your duty is to recognise the signs of
vulnerability before submitting a
昀椀nance application.
Your obligations as a distributor
of our Products
• You should be able to identify a possible
vulnerability as part of the credit application
process and take time to consider it for
every application.
• You should implement training procedures
on vulnerability.
• You should be familiar with your 昀椀rm’s
vulnerability policy.
What to do if you identify a
vulnerable customer
If, after applying your own vulnerability policy,
you identify a customer is potentially vulnerable,
you will need to alert us. If you think a customer
may have, or is currently experiencing, a particular
vulnerability which may affect their ability to enter
into a credit agreement, we have dedicated staff
who can help in these situations.
If you identify an issue, you should:
1. Discuss with the customer how best to meet
their needs. It may be that before being
referred to the lender or entering into a credit
agreement, the customer would bene昀椀t from
taking more time to consider whether they are
able to fully understand the commitment*.
2. Where you feel it’s appropriate to discuss a
customer’s circumstances with us, you can
contact our New Business Processing Team on
0345 111 7125.
3. Remember to ask the customer for explicit
consent and respect UK GDPR when informing
us about an identi昀椀ed vulnerability.
4. Advise the customer that a member of
our Specialist Support Team (see next
section) will contact them regarding their
application in order to establish any
additional support requirements.
The New Business Processing Team opening
hours are Monday to Friday 9am to 7pm.
Saturday 9am to 5pm, Sunday and Bank Holidays
10am to 4pm.
*You must not continue with any application
for 昀椀nance where you have concerns regarding
the customer’s mental capacity. For example,
if they appear unable to understand 昀椀nancial
information presented to them. If this situation
arises, please contact our New Business
Processing Team for advice before proceeding.
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