Treating Customers Fairly
TREATING CUSTOMERS FAIRLY POLICY
MediaBlanket Ltd is committed to providing a high quality service by working with our customers to meet their individual needs where possible.
As a business, we take the requirements of the UK's industry regulator the Financial Conduct Authority (FCA), very seriously, in particular the requirement to treat our customers fairly. We strive to do this in everything we do. We undertake that all our actions will be guided by the principle that the interests of our customers are paramount.
Our systems and procedures are designed to place our customers at the heart of our business.
These principles have been designed to ensure that we behave appropriately and to ensure that we are, and remain, customer-focused at all times and act in accordance to our regulators' expectations. We are committed to providing a high quality service by working with our customers to meet their individual needs. We will search our panel of lenders in real time to assist in identifying a lender that is interested in lending to you.
We will ensure that the service and products we provide are fair and appropriate to our customer's circumstances. We will always be diligent and work with our customers to understand their individual financial situation and needs. We will ensure that the products selected are in the best interests of the customer. We will ensure that our products and service comply with all regulatory requirements.
We will remain open with regulators. We will ensure that we provide all customers with clear and fair information which is not misleading. We will ensure that all our marketing products and services are clear, fair and not misleading. They will contain information which is honest, helpful and accurate. We will tell you about any conflict of interest that may arise between us as soon as we can, after becoming aware of this. We will be transparent about our services and relationships with associated partners or affiliates.
Treating customers fairly takes into account, not only how we use our customers' details, but how we deal with them at all stages of our business relationship.
Customers can be confident that they are dealing with a firm where the fair treatment of customers is central to the business culture
Customers will receive the best service possible and their details will be referred to a reputable firm who will look to provide them with a suitable product or service to meet their needs and requirements but only if the Customer chooses to take it up
Customers are provided with clear and non-misleading information and are kept informed of progress as appropriate
Customers receive a service which is of the standard expected by the regulators
Customers do not face unreasonable barriers in their dealings with us and are provided with clear communication routes and the ability to make a complaint should our service levels fall below those expected
CONDUCT RISK – DELIVERING TCF THROUGH OUR BUSINESS
MediaBlanket’s role is to introduce consumers to a product or service through its Broker Partners. GRP recognises that it has an obligation to meet the FCA’s principles for business in all its dealings with customers and trading partners to ensure that customers are treated fairly in the provisions of fair, clear and transparent information, which does not mislead directly or indirectly by content, format or omission to facilitate them making informed choices when using our services or the services of any lender or other financial services or product provider to which we may introduce them to.
The following areas are where MediaBlanket’s activities present particularly high risks and our controls and procedures to avert such risks:
Breach of Conduct of Business Standards for a Credit Broker
MediaBlanket is a credit broker which makes introductions to providers of credit products and services to consumers. To ensure the interests of the customer are always put first, MediaBlanket does not collect data from the consumer and will only display a selection of offers for the consumer to consider, without giving any guidance, advice and nor is there bias towards any product or service offered by the Broker Partners of MediaBlanket. The service is provided equally and fairly to all customers.
Risks exist in promoting one service over another, or guiding or suggesting that a product is suitable for the needs of the consumer, without firstly understanding the circumstances of the individual consumer. Accordingly, MediaBlanket has implemented the following mitigation procedures:
Personal Data collected, verified or collated shall be the minimum required
The data fields collected during any interaction between MediaBlanket and its Broker Partners and Service Providers will be regularly reviewed by the Director to ensure only the fields required are recorded.
Consumer Confusion in relation to Credit Brokers vs. Lenders
An adverse potential confusion is a consumer understanding the difference between a credit broker, lender, and other consumer credit based service providers. This generates a risk of unfairness and a lack of transparency as consumers may be confused and think that all promotions they receive are by direct lenders.
MediaBlanket will mitigate this risk of confusion by the following methods:
All financial promotions must be agreed by the Compliance Manager before they can be exposed to consumers on the MediaBlanket network to ensure they comply with the Financial Promotions Policy of MediaBlanket and the relevant regulations. All financial promotions will clearly state that MediaBlanket is a credit broker and not a lender.
In order to introduce consumers to financial service providers, MediaBlanket must make consumers aware of lenders, product and service providers that can provide these financial services.
Accodingly, MediaBlanket will be involved in financial promotions through its Broker Partner network and its own data sources.
There are specific advertising standards and regulations, in particular the consumer credit products or services to which MediaBlanket will promote to consumers, including CONC 3, governing financial promotions relating to consumer credit. MediaBlanket must ensure that its introductions are to regulated consumer credit lenders, product and service providers, and are suitable to the consumer’s needs. Therefore, the following procedures will be adopted:
Any entity seeking to become a Broker Partner, Lender, Product or Service Provider of MediaBlanket must be authorised by the Financial Conduct Authority.
MediaBlanket will collect the Affiliate’s FCA reference number and verify that the Broker Partner, Lender, Product or Service Provider is authorised by cross referencing the FCA’s Consumer Credit Register.
MediaBlanket’s Compliance Manager will sign off for approval of any Lender, Broker Partner, Product or Service Provider into the MediaBlanket network. This will be after a rigorous due diligence process.
Any financial promotion conducted by MediaBlanket or on behalf of MediaBlanket will be reviewed and approved by the MediaBlanket Compliance Manager prior to its use.
After a Broker Partner, Lender, Product or Service Provider has been integrated into the MediaBlanket network, the Director shall conduct audits of the promotional material at least once per month.
Records of the results of such audits will be kept in accordance with MediaBlanket’s Document Retention and Record Keeping Policy and failure to comply will lead to the termination of the MediaBlanket Network access.
All Broker Partners, Lenders, Product and Service providers will be required to enter into contractual arrangements with MediaBlanket which reflects their regulatory responsibilities. Non-compliance will be grounds for termination of the relationship and withholding any commission that is payable to that partner, in addition, the partner will be reported to the FCA in accordance with Principle 11 of PRIN.
This is version 1.3 of the policy. This policy shall be reviewed every 12 months or earlier, where any change in business or external environment requires it, in order to comply with rules or regulation changes affecting Treating Customers Fairly.
Date of version: 14/08/2018; reviewed 26/03/2020
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