Treating Customers Fairly

Scope 

Purpose 

Background 

TCF outcomes 

What is TCF 

TCF and Jigsaw 

Scope

This policy has been adopted by our Compliance Committee on behalf of the Board and applies to everyone involved in our business. For the avoidance of doubt, this includes all officers and beneficial owners of the as well as all employees (i.e. permanent, contract and temporary staff). 

This policy also applies to our Appointed Representatives (ARs). In all our dealings with our ARs we manage their compliance as they are all “in house” and are subject to regular audit. 

If anyone covered by the scope of this policy has any queries, these should be raised with the Director of Compliance. 

The Directors and Senior Management of Jigsaw Finance Limited are committed to ensuring that the FCA principle of treating customers fairly (TCF) is applied in all areas of our day to day business activities. 

This policy is to outline Jigsaw Finances responsibilities towards our customers to ensure we treat them fairly under the FCA’s principle. 

Background

All firms regulated by the FCA have to support the FCA Sourcebook’s principle that a firm ‘must pay due regard to the interests of its customers and treat them fairly’. The TCF (‘treating customer fairly’) principle aims to raise standards in the way firms carry on their business by introducing changes that will benefit consumers and increase their confidence in the financial services industry. 

Specifically, TCF aims to: 

• Help customers fully understand the features, benefits, risks and costs of the financial products they buy. 
• Minimise the sale of unsuitable products by encouraging best practice before, during and after a sale. 
• All firms must be able to show consistently that fair treatment of customers is at the heart of their business model and above all, customers expect financial services and products that meet their needs from firms they trust. 

TCF Outcomes

Firms are responsible for making sure customers are treated fairly. The FCA’s principles apply to all business behaviour and in particular Principle 6 says: ‘A firm must pay due regard to the interests of its customers and treat them fairly’. 

The FCA have defined 6 outcomes in which they expect business to strive to achieve, to ensure the fair treatment of customers. 

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. 

What is TCF?

Treating customers fairly is not just about offering the same rates, products and services to all customers or treating every individual the same, it is about the customer; having choice, clear and transparent information, confidence in the providers they are buying from, being offered suitable and appropriate products, having freedom to leave if required and knowing the products and services will work exactly how they were lead to believe.

Firms must ensure they are able to demonstrate that they are consistently delivering fair outcomes to consumers and that senior management are taking responsibility for ensuring that the firm and staff at all levels, deliver the consumer outcomes relevant to their business through establishing an appropriate culture. 

It is expected that as a business we can: 

• demonstrate that senior management have instilled a culture within the firm whereby they understand what the fair treatment of customers means; where they expect their staff to achieve this at all times; and where firms promptly identify (a relatively small number of) errors, put things right and learn from them. 
• be appropriately and accurately measuring performance against all customer fairness issues materially relevant to their business and be acting on the results. 
• be demonstrating through those measures that they are delivering fair outcomes; and 
• have no serious failings that have been reported to the FCA or have been identified through management information (MI). 

TCF and Jigsaw

Jigsaw’s stance on TCF 

S – Suitable products – Outcome 2 
T – Transparent information – Outcome 3 
A – Appropriate advice – Outcome 4 
N – No post sale barriers – Outcome 6 
C – Confidence in our culture – Outcome 1 
E - Expectations fulfilled – Outcome 5 

As a business we need to ensure TCF is bred in our culture and in our values, we will achieve this through: 

Suitable Products 

• Carrying out income, expenditure and suitability checks to ensure affordability and sustainability. 
• Manually underwriting all customer applications to ensure the most suitable and appropriate funder is selected based on the customers credit profile, employment and vehicle, to reduce the negative impact on the customer credit history. 
• Ensuring the Standard European Consumer Credit Information (SECCI) document is provided before entering the customer enters into any agreement, ensuring the customer fully understand what they are committing to. 

Transparent information

• Offer a transparent and professional service to help customers make an informed choice. 
• Making sure that any promotional material is clear, compliant, jargon free and appropriately targeted. 
• Ensuring Sales Executives and all customer facing Employees have thorough training on all products, so they have a full understanding of the features and benefits to be able to pass this information on to the customer. 
• Providing customers with clear accessible literature and product information. 
• Making the customer journey as easy as possible and getting it right first time. 

Appropriate advice

• Providing ongoing feedback, coaching, developing and training for all our staff. 
• Training non-sales staff to implement TCF in their day to day business activities to improve the culture within the businesses. 
• Ensuring Employees are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers. 
• Holding TCF focus groups where staff can provide feedback on the customer journey and processes and encouraging staff to submit process improvements and feedback on documents, criteria and the customer journey. 
• Keeping staff informed of issues identified through monitoring, recording of complaints and dissatisfaction. 

No post sales barriers

• Having a process in place to record dissatisfaction and complaints and having a fully trained complaints handler to deal with these. 
• Keeping customer records of all conversations before and during the application and recording relevant information on company systems so we can deal with any complaints that may arise swiftly and fairly. 
• Making sure customer complaints are assessed fairly, promptly and impartially, and in line with FCA deadlines and rules. 

Confidence in our culture

• Having processes in place to identify and combat money laundering and fraud. 
• Only proposing each customer with a maximum of 3 lenders. 
• Keeping TCF prominent alive by putting posters up in all rooms. 
• Continual monitoring and quality checks through call, case and process monitoring. 
• Implementing sales remuneration packages that promote the TCF culture and customer satisfaction, rather than awarding sales volumes. 
• Department Managers to Complete monthly reviews as well as coaching/training sessions with all Employees. 
• Having strong ethical Values that are evidenced in the workplace. 

Expectations fulfilled

• Having and encouraging a solution (process) in place for customers, dealers and funders to provide feedback. 
• Ensure we implement a contact questionnaire with clients after a deal has been concluded to help or improve on the service already offered. 
• Monitoring and reporting on all of the above TCF activities as part of the company’s monthly statistics/MI, to assess TCF performance across the businesses. 
• Ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way.