• Give the customer what they have paid for – ensure that the customer fully understands the product(s) offered
  • Do not take advantage of the customer

a) Avoid pushy sales tactics

b) Do not sell inappropriate products

c) Do not allow the priorities of any third party suppliers to unduly influence the sale of a product

  • Offer the customer suitable products/services
  • Do our best to resolve problems/mistakes as quickly as possible
  • Show flexibility, empathy and consideration in dealing with customers
  • Use plain English and be clear, ensuring the customer understands exactly what they are being offered:

a) Terms and conditions should be as clear and easy to understand as possible

b) Significant exclusions/terms should be highlighted

c) Use plain English

Using these principles, we understand that we are expected to meet the FCA’s 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.

Process Controls and Record Keeping

Keep records to demonstrate that:

  • Sales processes have been established
  • Training undertaken to ALL customer facing sales staff and updates as appropriate
  • Each sale has evidence to show a good process took place

Promotional material

  • Ensure all marketing material (digital copy, ads, brochures, posters, direct mail) are written using plain English
  • Ensure all jargon terms (e.g. ‘APR’) fully explained
  • The APR provided to the customer must in usual circumstances be the same as that advertised on-line or in adverts. If this is not the case, why not? Are they a customer with a poor credit record for example?
  • All the charges must be made clear
  • Promotional marketing material should be tested with a non-expert

Sales Process

  • All product training is provided and recorded for the products we’re offering, to all relevant staff
  • We must be clear about any customer group these products wouldn’t be suitable for
  • All relevant finance product options should be discussed with the customer
  • Be satisfied that your customer can afford the product now and in the foreseeable future
  • Check that the customer understands the documents provided
  • Ensure that the customer understands the benefits and risks of the product they’re buying and the associated costs
  • Customer agreements must be clear and understood
  • Commissions (where applicable must be within the relevant guidelines).