Typical questions the FCA ask following an application submission for Full Permission
Below is a list of typical questions FCA case-handlers are asking retailers following receipt of a full permission application. Most of the information should have been included within the business plan you submitted as part of your application, but please be aware case-handlers may still ask and you will still need to respond.
- Are your customers aware that finance will be offered to them before they are visited in the home?
- Please could you give details of the process by which finance is offered? How are your sales pitched?
- Do you target low income consumers?
- How do you recognise vulnerable consumers or consumers in financial difficulty and how would you deal with offering them a financial product?
- Which Finance Provider other than the Green Deal Finance Company are you planning to use. What role does the lender play in ensuring suitability of the sale?
- Do you make unsolicited contact with potential customers, i.e. cold calling/door knocking?
- Who in your firm undertakes the sales in the home?
- Are your staff offered any performance incentives or payments for making sales?
- Where agreements are signed in the home, are customers given time to consider the fees, charges and nature of the finance agreement? If so, how long are customers given?
- How do you plan to make customers aware of variable prices for the same goods?
- Do you undertake an affordability assessment before offering finance to your customers? If so, what does that entail?
- Does your firm undertake any advertising or marketing of its products?
- What checks do you plan to make on your staff that are visiting clients in the home, e.g. Criminal Convictions?
- Please send a copy of the following:
- Pre-Contract Information;
- Details of what fees, if any, are charged to the customer when broking;
- If fees are charged, details of how the customer is able to obtain a refund of those fees;
- Information on how the customers is made aware of their cancellation/withdrawal rights;
- Your firm’s complaints procedures.