TREATING CUSTOMERS FAIRLY (TCF) POLICY
Purpose and Objective
At Outset Finance, we are committed to offering our customers the highest possible standards of service. In so doing we are pleased to support the Financial Conduct Authority initiative ‘Treating Customers Fairly’.
As part of this endeavour, Outset Finance is committed to continually reviewing and improving both its offering and the way this offering is delivered.
This approach has been developed in accordance with the principles and requirements outlined by the FCA, which specifies that ‘All firms must be able to show consistently that fair treatment of customers is at the heart of their business model.’ The FCA does not set down a standard approach for how TCF should be assessed and implemented; that said, demonstrating TCF is not difficult or onerous and Outset Finance does this in a number of ways. These are detailed in this policy and incorporated in other policies such as the Complaints Handling Policy, Privacy and Data Sharing Policy and Collections Policy.
The FCA has developed six TCF consumer outcomes that firms should strive to achieve, to ensure fair treatment of consumers. The six TCF outcomes are outlined below:
- Outcome 1: Consumers can be confident 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.
The objective of this Policy is to provide a broad overview of how Outset Finance seeks to apply these outcomes in every day practice.
FCA principles focus on a conduct culture – a culture of fairness, where a demonstrable commitment from senior management is evident, and extends well beyond the first point of contact with customers.
The fair treatment of customers is as much about employee behaviour and the overall approach of a firm, as it is about its systems and controls. How employees are engaged, appraised, trained and motivated plays a key part in the culture of fairness.
In embedding TCF, Outset Finance endeavours to:
- Provide appropriate guidance that is suitable to each customer;
- Take into account customer circumstances and, where appropriate and with their consent, obtain further information about our customers to better understand individual circumstances;
- Treat customers with dignity and respect;
- Provide customers with appropriate information, such as adding our policies to our website and referencing where customers may obtain further information from the FCA;
- Never mislead customers;
- Ensure staff are trained appropriately to demonstrate TCF outcomes; and
- Perform risk assessments of TCF non-compliance.
What TCF does not mean
TCF does not mean delivering identical levels of service to every customer. Each customer should be treated as an individual, taking into consideration their own personal circumstances, rather than adopting a “one-size-fits-all” approach.
“Dissatisfied” customers may have been treated fairly. For example, if a Loan application is declined due to low personal affordability, poor credit worthiness or the customer’s inability to satisfactorily demonstrate the viability of their business.
“Satisfied” customers may not always have been treated fairly. For example, if a Loan is approved where there are concerns of affordability, then the customer may have been unnecessarily burdened with debt.
Delivering the TCF Outcomes
TCF forms part of the company culture of Outset Finance and is embedded throughout our processes. Outset Finances management recognises its responsibility towards treating customers fairly and ensures this is a focus for all Outset Finance employees. As a result, several monitoring initiatives are embedded into Outset Finance ways of working.
Our commitment to you
- Respond to you within 48 hours of you contacting us, whether via phone, email or SMS.
- Ensure that all promotional and marketing materials are not misleading and do not target individuals that are clearly ineligible or not suitable for a Start Up Loan.
- Provide you with clear information about the products and services we offer, including any fees and charges. Please note that there are no fees attached to applying for a Start Up Loan via the government-backed Start Up Loan scheme, administered by The Start Up Loans Company. As a Delivery Partner of this scheme, Outset Finance will not charge you any fees related to applying for a Start Up Loan. Should you choose to pay a third party to provide you with support either pre- or post-application, you do so entirely at your own discretion and this will have no bearing on our review of your loan application.
- Make a range of pre-start support available to you to give you the best chance of success with your application, including access to our start-up support tool, Outset Online; phone, online (or if possible, face to face) consultations with our business advisors; regular email communications with tips and advice related to the application process; customer service during standard business hours; and where possible, workshops and events (locations determined subject to demand and we cannot commit to hosting these in all locations).
- Consider your individual needs, preferences and circumstances and any other information provided by you, before offering advice or recommendations.
- Thoroughly assess your loan application, including all supporting documentation before arriving at a decision regarding your loan outcome and contact you if we require any additional information or clarification regarding your loan application to ensure we can make an accurate loan assessment.
- Use best endeavours to complete an initial review of your loan application within 5 working days of receipt (via or online form, or the post). We will notify you immediately if this will not be possible in order to keep you informed about your progress. Please note, only fully completed application are eligible for review and we will contact you within 48 hours if
- we identify that you are missing any documents so that you can amend your application accordingly.
- Not approve a Start Up Loan if we have reasonable cause to believe that you will not be able to make the payments. All loans will be reviewed by a second loan assessor to ensure a fair and reasonable outcome.
- Offer you 12-months of complementary mentoring support once you have successfully secured your loan.
- Encourage you to ask if there’s something you don’t understand.
- Give you access to a formal complaints procedure should you become unhappy with our service. You can see a copy of our complaints policy here.
How you can help us
To help us deliver you the best service, we will ask you to:
- Accurately complete our registration form when you decide you would like to work with our service to ensure we have sufficient information on file to help you determine your eligibility and next steps.
- Take care to submit a fully completed and accurate application form, including detailed business plan, cash flow forecast and all supporting documents (including any additional, non-mandatory documentation or information that supports your plans) so that we can make a full assessment of your situation.
- Understand that while we endeavour to provide sound advice based on years of professional experience, any actions you take based on advice provided is done so entirely at your own discretion and you accept all responsibility based on the outcomes.
- Be aware that like other credit commitments, failed Start Up Loan repayments can affect your credit score and formal action may be taken if you miss your loan repayments.
- Immediately contact GC Business Finance, our Finance Partner who has issued the funding for you loan if at any point you are concerned about your financial situation or your ability to meet your loan repayments. If you prefer, please provide us with the best contact details so that we can pass this on and ask them to contact you.
- Let us know if you are no longer interested in any aspect of our services, including applying for a loan, proceeding with your application or accessing post-loan mentoring support.
- Let us know if there is any aspect of our service, or of a product we have discussed or recommended that you don’t understand.
- Tell us if you think there are ways we can improve our service.
For more information about the Financial Conduct Authority ‘Treating Customers Fairly’ initiative please visit the Financial Conduct Authority website.