1.1 Kudos Commercial Finance Ltd is committed to the fair treatment of customers. Our Treating Customers Fairly (TCF) framework is developed around the core six outcomes set by the Financial Conduct Authority (FCA). By placing our clients at the centre of our business ensures that fair outcomes are achieved. This has been extended further to reflect the introduction of the Consumer Duty.
1.2 Staff at all levels of Kudos Commercial Finance Ltd are trained to understand the six TCF outcomes and the cross-cutting rules and four consumer outcomes of the Consumer Duty. Kudos Commercial Finance Ltd promote this culture through our organisation, using a ‘message from the top’ approach to set the right standards from the offset.
1.3 The FCA’s six TCF outcomes are derived from their key Principles of Business. The six outcomes are;
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.
1.4 Kudos Commercial Finance Ltd understand that simply learning the six TCF outcomes is not sufficient to demonstrate that they have been effectively embedded into our business culture, below we set out how each outcome is implemented and achieved throughout our business.
Outcome 1 – “Can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.”
2.1 Each member of Kudos Commercial Finance Ltd understands the importance of fair treatment of customers, our clients are essential to our business model and TCF supports our developing and crystallised relationships with our clients.
2.2 Kudos Commercial Finance Ltd is a developed commercial business and our management team is directly involved with our activities. Monthly meetings are held with TCF as standing, fixed agenda item for discussions.
2.3 Employees at Kudos Commercial Finance Ltd are all regularly trained on the fair treatment of customers and Kudos Commercial Finance Ltd has a ‘tone from the top’ mentality, consistently promoting TCF throughout the business.
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.”
3.1 We ensure any marketing material developed is proportionally targeted to the needs of our clients, for example we do not send material regarding mortgage finance arrangements where the client requires vehicle finance. Kudos Commercial Finance Ltd makes it clear that we are a broker and not a lender of financial products.
3.2 We do not tend to issue financial promotions. Our static website contains information about what we do, as well as generic information relating to some of the types of services which we provide advice on and complies with the FCA’s financial promotion requirements set out in the FCA’s Handbook CONC 3. Amendments to the website are signed off by our Jonathan Tait prior to issue to certify compliance.
Outcome 3 – “Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.”
4.1 The nature of the products and services that we offer are such that we are required to interact closely with all our clients. As part of this process, we become aware of any need to provide further information in a different way.
4.2 Kudos Commercial Finance Ltd website holds clear, simple advice on our processes along with how to contact Kudos Commercial Finance Ltd. www.kudoscf.co.uk
Outcome 4 – Where consumers receive advice, the advice is suitable and takes account of their circumstances.
5.1 Kudos Commercial Finance Ltd acts as an Broker of finance for our clients. We tailor our introductions specifically based on the needs and suitability from a robust KYC/Fact find process.
5.2 Kudos Commercial Finance Ltd continues to have an obligation to ensure that any recommendation that we give is suitable given our clients’ individual situations based on the information provided. We use (‘statements of suitability’), which provide granular detail on the clients’ circumstances, the options Kudos Commercial Finance Ltd considered, the final decision, including the rationale behind the decision, emphasising the clients’ circumstances and the suitability of the product selected.
5.3 We conduct annual reviews of the clients, requesting updated data of their circumstances and objectives to ensure the services we provide, remain relevant, adequate and suitable for their needs.
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.”
6.1 We provide clear information to our clients. We are ever mindful of non-disclosure risk, for example; if we fail to mention a specific feature of a: Minimum term lease, Agreement Fees or other charges as they become applicable. Kudos Commercial Finance Ltd uses simple, clear disclosure documents which the client must read, and sign to confirm understanding, prior to commencement of our duties.
6.2 Fact sheets are produced and provided which highlight, in clear intelligible writing, the terms of an agreement and how it is to perform. Kudos Commercial Finance Ltd have an ethos of no small print and are as open and transparent to our clients as possible, ensuring full disclosure.
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.”
7.1 We have in place a complaints procedure and policy in place which comply with the FCA’s Regulatory Handbook (DISP) Dispute Resolution section. We apply these standards to all complaints received that fall within the definition of “eligible complainant”. Details of how a client or business can make a complaint is clearly listed on our business website, we provide a non-premium rate contact number and allow for electronic communications to be received regarding any dissatisfaction displayed.
7.2 Kudos Commercial Finance Ltd is a member of the National Association of Commercial Finance Brokers (NACFB) and adheres to a code of conduct.
8.0 Consumer Duty
8.1 The FCA’s Consumer Duty, the 12th Principle of Business sets out the expectations on regulated firms when engaging with retail customers. It is made up of an overriding principle:
“A firm must act to deliver good outcomes for retail customer”
8.2 In support of the Principle the FCA have created three cross-cutting rules requiring regulated firms to:
1. Act in good faith towards clients;
2. Avoid causing foreseeable harm to clients;
3. Enable and support clients to pursue their financial objectives.
8.3 To support firms to comply with the rules the FCA have set out four consumer outcomes. Firms are expected to ensure:
1. Products and services offered meet the needs of the firms target market
2. That the price of products and or services represent fair value to the firms target market
3. That the firm has appropriate measures in place to ensure consumer understanding, enabling target markets to make an informed decision.
4. That appropriate consumer support is available to the target market at all stages of the relationship.
8.4 Under the Duty, Kudos Commercial Finance Ltd will provide customer with products and services that meet their needs and offer fair value. Our customers will receive communications they can understand, and they will get the customer support they need, when they need it.
8.5 Kudos Commercial Finance Ltd recognises that the Consumer Duty extends beyond the 6 TCF outcomes and places an onus on regulated firms to evidence they are actively achieving the four consumer outcomes for retail customers. Kudos Commercial Finance Ltd has appropriate systems and controls in place to monitor consumer outcomes and where we identify potential harm to our target markets, we will ensure we act swiftly.
8.6 Kudos Commercial Finance Ltd will ensure all people within our firm are appropriately trained to understand and deliver against the expectations placed in relation to the Consumer Duty.
8.7 Kudos Commercial Finance Ltd will ensure it reviews and adapts its policies and procedures to reflect the most up to date information to support the application of the Consumer Duty as set out within PRIN 2A.1.
