Treating Customers Fairly

We hope that you will find these pages useful and that you will gain an insight into how Complete FS feel that TCF can be integrated into best working practices for both ourselves and our introducers.

If Treating Customers Fairly is not to be confused with good customer service, then what is it?

This has been a common response since the FCA first announced its initiative of TCF. On the face of it, it seems a reasonable enough question, but TCF is much more than simply good customer service and the FCA have specified some clear aims and desirable outcomes to help with the distinction;

AIMS

  • To help customers fully understand the features, benefits, risks and costs of the financial products they buy.
  • To minimise the sale of unsuitable products by encouraging best practise, before during and after a sale.

OUTCOMES

Consumers should be sure that;

  • They are dealing with firms where the fair treatment of customers is a key part of the corporate culture.
  • They are marketed and sold retail products that are designed to meet their needs and have been marketed accordingly.
  • They receive clear information and are kept suitably informed, before, during, and after the point of sale.
  • They receive suitable advice which takes account of their personal circumstances.
  • They receive the product performance and standard of service that they have been led to expect from the firms they deal with.
  • They do not face unreasonable post-sale barriers imposed by firms when they want to change product, switch provider, submit a claim or make a complaint.

The Complete commitment to Treating Customers Fairly is evident throughout the entire Company. From the directors, through to all staff who contribute to our "Care Values" philosophy.

Complete customer service

Attitude & Awareness.

Respect for customers and fellow employees

Exceptional expectations.

In addition to our CARE values we also have a number of keystone policies aimed at helping our introducers to treat customers fairly;

  • Although we do not give advice our helpdesk will always aim to provide you with multiple options aimed at helping you satisfy your customers needs.
  • We will give all of our introducers access to 24 hour online case updates aimed at helping you assist your clients at a time which is suitable to them.

TCF Objectives

The Directors and Senior Management of Complete FS Ltd 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. Where our function is to purely to package a mortgage on behalf of a regulated broker we will apply the principles to our dealings with that broker 'our customer'.

In adopting the TCF principle we recognise that fair treatment of our customers is about adding value to the service we offer by aiming to:

  • Protect the interests of our customers at each stage of the product life cycle, from promotion right through to after sales service
  • Meet as best we can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing our service to identify areas for improvement

In practical terms for the different areas of our business this means:

  • Ensuring that promotional material is clear, compliant, jargon free and appropriately targeted.
  • Ensuring that sales staff (both on and off-site) have thorough training on all products they advise on or sell, understand who they are and aren’t suitable for, and are encouraged to challenge product providers where they spot inconsistencies, ambiguities or potential unfairness in the product literature or product features.
  • Operating sales remuneration systems which assure fairness to the customer as well as customer satisfaction, rather than only rewarding sales volumes.
  • Finding ways to encourage non sales staff to implement TCF in their day to day business activities.
  • Ensuring that customer complaints are assessed fairly, promptly and impartially, and in line with FSA deadlines and rules.
  • Encouraging staff to recommend improvements to service following customer complaints – and monitoring the outcome.
  • Ensuring that staff 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.
  • Offering regular training in the principle of TCF at all levels of the business.
  • Regularly monitoring and reporting on all of the above TCF activities as part of the company’s monthly statistics/MI, in order to assess TCF performance across the business and recommend changes where appropriate.
  • Ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way.
  • To encourage all staff to actively participate in our C.A.R.E values programmes to continually encourage and highlight best practice.

Treating You Fairly

The following pages are examples of adviser good practice and fit well with our ethos of TCF. We are happy for all of our introducers to adopt them.

 

When you do business with us we want you to feel confident that you are being treated fairly. We want you to understand all the parts of the product you are buying. If you are not sure about something we want to make it easy for you to ask for an explanation.

Remember To Give Us Full Information

  • We need to know all your clients financial commitments so we can accurately source on lenders criteria
  • If your client needs a mortgage on which they only pay the interest (an ’interest only’ mortgage), we need you to tell us how they plan to repay the balance.
  • If you are not giving us proof income , we need you to be accurate and realistic when you tell us how much your client earns

Our Aims

We want to make it Absolutely clear what we are offering. For example, the conditions of the business, including rates, charges, likely timescales and so on

We want to deliver what we say we will deliver. We want you to get exactly what you are expecting without surprises

We want to sort out any problems that may arise along the way. If anything goes wrong, we want you to feel confident that we will do everything we can to put it right

We want to be fair and not take advantage. We will make sure you understand the product before you buy recommend it

Our Duties To You

  • We will only suggest products which most closely fit your clients needs. We will not source products based on how much money they will make us, but on how suitable they are for your client
  • We will only suggest products which are affordable. We will not suggest a product if we do not think your client can realistically keep up with the payments
  • We will make it easy for you to complain if you are not happy. We encourage all customers to give us feedback, whether it is good or bad. We want to be the best we possibly can be and can only improve if you tell us when we get it wrong

Interest Only Mortgages

What is an interest only mortgage?

As its name suggests an interest only mortgage is one where you only repay the interest each month. This means that you never reduce the amount outstanding. For example; if you borrow £100,000 over a 25 year period and keep up to date with all of the interest payments you will still owe £100,000 at the end of the 25 year term.

How do I pay off my interest only mortgage at the end of the term?

Here are some typical options but by no means all.

A. Endowment Policy

You can take out an investment policy with an insurance Company known as an “endowment policy”. You will have to pay a monthly premium; the amount will depend on various things including the size of your mortgage, your health and your age. The premium you pay will be used by the Insurance Company in 3 ways:

 
  1. For life insurance so that your mortgage will be paid off if you die.
  2. Administration charges to the Insurance Company.
  3. To make investments on your behalf in order to grow the policy value.
 

There is no guarantee that the value of the policy will be enough to pay off your mortgage at the end of the term.

B. Changing to a Repayment Mortgage at a Later Stage

A repayment mortgage is one on which you pay the interest due each month and in addition an amount towards paying off the balance. Changing to a repayment mortgage at a later date will mean your payments will become higher than if you had started with a repayment mortgage from the beginning.

C. Inheritance/Investments

Some people rely on inheritance they may be due to receive or other investments such as stocks and shares.

Whatever your own circumstances it is important that you have a plan for how you intend to pay off your mortgage at the end of the term. All of the above options carry an element of risk and you should discuss all of your circumstances with your financial adviser so that you can make an informed choice on what is best for you.

How to Complain

YOUR GUIDE TO THE COMPLETE FS COMPLAINTS PROCEDURE

If you have a complaint about our service, please tell us. We want to put things right ideally first time. With the help of your comments we can continually improve our services.

Our complaints procedure has three steps for you to follow when you make a complaint. Our internal complaints procedure is registered with the Financial Conduct Authority and the Financial Ombudsman Service. Whilst we are not regulated by the organisations we have decided to follow these best practices This 3-step approach is recommended as best practice within the mortgage industry.

The 3 steps are as follows; -

STEP 1

You are asked to contact Complete at the location which has given you the service you want to complain about. They can usually sort out the complaint straight away. If they cannot they will acknowledge your complaint in writing within 5 days of receipt, and tell you how long it will take before they can give you an answer unless :

a) the complaint is resolved within 24 hours to your satisfaction

b) the Final Response can be issued within this timeframe.

Normally your complaint will be resolved within 28 calendar days, however if this is not possible you will be sent a letter stating when you will receive a response and also explaining your rights to take your complaint to the Financial Ombudsman Service should this be necessary.

STEP 2

If the complaint cannot be resolved satisfactorily within Step 1

You can elevate your complaint to the Complete FS Compliance Director to request a review and seek resolution.

If you want to put your complaint in writing please address it to :

          Mr T Salentino
          Complete FS Ltd
          9 Compass Point
          Ensign Way
          Hamble
          Southampton
          Hampshire
          SO31 4RA

STEP 3

If you are not satisfied with the response to your complaint, the Financial Ombudsman Service may be of assistance. You must take your complaint to the Financial Ombudsman Service, if you are not satisfied with the Complete's response within 6 months of the issuing of a Final Response Letter. We will supply you with a leaflet explaining the role of The Ombudsman and how they will address your complaint.

The Financial Ombudsman Service can be contacted at:

           South Quay Plaza
           183 Marsh Wall
           London
           E14 9SR

Telephone: 0845 080 1800

Website: www.financial-ombudsman.org.uk