Treating Customers Fairly

Intent

Treating Customers Fairly (TCF) is central to financial regulation for consumer credit within the UK. The FCA has made it clear that the principles within TCF guidelines have high urgency in terms of monitoring and application. The FCA requires that all businesses it regulates to comply with their provisions on Treating Customers Fairly (TCF) and on focusing on good consumer outcomes within all parts of their business culture and that management are expected to lead on treating customers fairly.

Orchard Lease and Finance Ltd © ( OLAF)©and its subsidiaries including Leasetree © and Leasewiz © are a broker and not a lender and are committed to following these principles.

Introduction to FCA Principles

TCF is about putting responsibility on companies – particularly financial service industry companies to deliver a fair outcome to consumers. It is not however, intended to be restrictive on the business or overly onerous to implement.

TCF is designed to ensure the business puts the interests of the customer at the heart of their business and that decisions and actions are based on the central principles.

TCF is key to 5 of the principles found in the Financial Conduct Authority (FCA) Handbook :

Principle 1 – A firm must conduct its business with integrity
Principle 6 – A firm must pay due regard to the interests of its customers and treat them fairly
Principle 7 – A firm must pay due regard to the information needs of its clients and communicate information to them in a way that is clear, fair and not misleading
Principle 8 – A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client
Principle 9 – A firm must take reasonable care to ensure that the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement

TCF is not a bolt on and neither is it a check box to be completed – its designed to be part of the fabric of your business and important to all aspects all of the business. The concepts of TCF should be in every step of sales process, from staff training to the clear information and the financial products offered and supplied to the customer, as well as resolving any issues which a customer may have.

OLAF Ltd is limited to supplying information to prospects and customers and effecting contact between end customers and brokers or lenders. We do not take or retain customer’s money, nor are we lenders. OLAF is designed to sift through our partners offers and provide the best deals available in order to introduce customers to potential brokers and lenders. While the nature of OLAF’s business by definition restricts how much OLAF is responsible for outcomes through the entire buying chain we seek to uphold and apply the principles of TCF in all that we do.

In essence we seek to take the core messages of fairness, honesty and integrity and to apply them to any customer interactions.

How did the FCA design TCF and what outcomes are required?

The FCA established a framework of outcomes which are designed to give businesses guidance on what principles to apply, what behaviours to encourage and entrench and what outcomes from a consumer perspective should be enjoyed.

Essentially the FCA want businesses to:

Give the customer what they have paid for whilst ensuring that the customer fully understands the product(s) offered

Does not take advantage of the customer
Avoid pushy or unethical sales tactics
Not sell inappropriate products
Do not allow Finance and Insurance suppliers to unduly influence the sale of a product
Offer the customer suitable products/services that meet their needs
Show empathy and apply their knowledge in a helpful manner when dealing with customers
Fix issues and problems as quickly as possible
Use plain English, be clear and ensure customers understand what they are being offered:

Terms and conditions need be as clear and easy to understand as possible

Significant exclusions/terms should be highlighted

Using these principles, the FCA expect six outcomes for consumers:

Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Our commitment

OLAF Ltd commits to using appropriate management information, staff training, process controls, documentation and standards in order to meet both the principles and the desired outcomes in order to Treat Customers