Introduction
The Directors and Senior Management of Close Credit Management Limited are committed to ensuring that the FSA principle of Treating Customers Fairly (TCF) is applied in all areas of our activities.
We recognise that in successfully delivering the six TCF outcomes we are paying due regard not only to our own regulatory standing but also that of our clients. Furthermore we will add value to our service by:
- Gaining a full understanding of the circumstances under which a customer has been referred to us.
- Defining the best resolution to their situation having regard to their true ability to complete the proposed solution.
- Balancing these with a recognition that TCF does not absolve the customer from the responsibility to carry out their side of the bargain and taking the most appropriate steps in each case to enable this to occur.
TCF is a cultural issue. In order to ensure that TCF permeates our entire business we have considered how the six outcomes apply specifically to our activities and have taken the steps necessary to align our working practices with them.
How The Out Come Applies To Us?
1. Customers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Our cultural commitment to TCF begins with leadership at the most senior (Board) level of the business and extends through all grades of management and supervision to create an environment where TCF is normal working practice.
This level of consistency is achieved firstly by ensuring our leaders understand the meaning of TCF and, secondly by continued development and training of our employees, including implementation of reward systems which promote TCF-compliant behaviour.
By monitoring all our customer interfaces, over the telephone, by correspondence and face to face, we will continually develop measures of the proficiency of our management and staff in consistent delivery of the fairest available solutions for the individual circumstances we encounter.
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.
In order to ensure our solutions best match the specific needs of the customer it is essential for us first to understand the events that have resulted in their being referred to us, secondly the customer’s true current financial circumstances (for example by a statement of means) then, thirdly, the range of solutions which could apply.
Detailed understanding of our client’s activities and the customer’s means enables us to develop and propose the most appropriate arrangements to satisfy our client’s requirements in a manner which is also fair to the customer.
3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
We recognise that we come into contact with customers who are often in circumstances of considerable financial distress. It is therefore imperative that our activity brings maximum clarity to the situation.
Our collections activity encompasses letters, telephone calls, home visits and legal action. From the outset we will verify that the information upon which we are working is accurate, communicate in plain language and clearly describe the options available and their consequences.
The processes involved in dealing with a matter may be complex, for example where legal action or the disposal of an asset is involved. Communications will continue to be developed to aid clarity in these situations and will be updated with the latest statutory and regulatory implementations.
We will treat customers fairly by maintaining their account records with us up to date at all times.
Additionally we will seek confirmation of customer understanding by post-activity surveying of the customer experience.
4. Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Our objective at all times is to achieve the most appropriate resolution to a debt in line with all the relevant circumstances.
This responsibility has to take into account the overall financial circumstances and prospects of the customer. Our role, once a proper understanding of the circumstances has been achieved, is to know the available options and their consequences (including those if the customer is unwilling to cooperate) and then to negotiate the appropriate implementation.
To that end we consistently sample correspondence, telephone calls and field visit reports to confirm that the correct information has been communicated and that decisions taken are the most suitable for the individual case.
5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect.
Close Credit Management is a negotiator and facilitator of solutions to a wide variety of debt problems.
A key measure of the effectiveness of these solutions is our data on performance of the arrangements we set up.
We have an ongoing programme of measurement and development of these solutions, with positive and negative feedback used to modify them.
Additionally, our complaints management procedures look at root causes in order to drive continual improvement of the solutions we apply.
6. Consumers do not face unreasonable post sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Our intention is to ensure that our activities meet the reasonable expectations of the customer at all times. The steps outlined in 1-5 above are designed to that effect.
Beyond this, CCM is contactable via a wide range of media and expressions of dissatisfaction are given thorough consideration and detailed response.
Our aim is to ensure that escalation is the exception to the rule both by the promptness and thoroughness of our responses, willingness to acknowledge when processes fall short of our high standards and application of root-cause cures to avoid repetitive issues.
Conclusion
Close Credit Management will treat customers fairly by:
- Embedding an understanding of TCF at all levels of its corporate structure.
- Ensuring we fully understand the customer’s circumstances before negotiating a solution.
- Conveying the solution and all its implications in clear language.
- Constantly monitoring our communications and actions for continuous improvement.
- Measuring the effectiveness of our solutions and modifying them in line with feedback.
- Always seeking to provide the best solutions and responding promptly and thoroughly when this is questioned
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