V12 Procedure Guide - Flipbook - Page 29
Product + 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.
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 iden琀椀fy 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 0330 303 0564.
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.
• You should implement training procedures
on vulnerability.
• You should be familiar with your 昀椀rm’s
vulnerability policy.
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