Treating Customers Fairly

This Agreement was last modified on 10th August 2017

The FCA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative. These are:

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 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.

What TCF is not

  • Creating satisfied customers; a satisfied customer could still be treated unfairly and not know it
  • That every firm must offer an identical level of service – the FCA recognises that businesses have different resources and ways of doing things
  • That the FCA has the final say on which products consumers should want or be sold
  • That customers are no longer expected to make decisions or take responsibility for them


  1. At HomeSmile, we believe that the FCA’s Treating Customers Fairly (“TCF”) principle based initiative is complementary to our approach for all of our customers, providing a framework by which we can work with our customers to achieve positive outcomes.
  2. This philosophy has been considered at length by the company to ensure that the TCF initiative is deeply embedded in company life, reviewed and tested by the company, and spread through the business using training and development as a key educational tool for its maintenance and progressive stronghold on company life.
  3. HomeSmile’s fundamental starting point is to ensure that the fair treatment of customers is an ideological wave that flows through all of company life.
  4. The products that we offer, the suitability of those products, and the cost of those products are also marketed and provided to customers to ensure that TCF is observed at the start of a customer’s lifespan with us.
  5. Most of the products provided by HomeSmile will suit a large customer base with diverse financial capabilities.
  6. We ensure that when we target potential customers, the language used is clear and not convoluting, the services that we offer are transparent; the representative loan example is present and dominant on all marketing information, and that before publication our marketing gets approved by The Consumer Credit Association (CCA) to ensure maximum compliancy and consumer suitability.
  7. HomeSmile also ensures that products are suitable to each customer’s individual financial circumstances.
  8. Agents at HomeSmile are trained to complete comprehensive affordability assessments, to ensure that customers are in a position to receive a product that best suits their lifestyle.
  9. We observe TCF by ensuring that customers are treated fairly by receiving a product that will not lead to high risk over indebtedness, or a product that may conflict with their way of life.
  10. Agents at HomeSmile take time to talk to customers to build the best picture possible in regards to the customer’s environment.
  11. This, coupled with understanding a customer’s financial capabilities, will ensure that the guidance, and subsequent products, are appropriate to each customer, with the customer’s best interests central to the decision making process.
  12. Agents at HomeSmile also ensure that customers understand all of our pre-sale literature.
  13. We ensure that our agents sit with our customers and adequately explain the key features of the agreement, any associated costs that may occur during the agreement, and all the terms and conditions related to the agreement.
  14. We ensure that their rights, and the company’s responsibilities, are outlined before a commitment has been made by the customer to enter any agreement.
  15. We inform customers that no decisions has to be made immediately, and that they are entitled to take away all of our pre-sale literature to ensure that the product on offer is 100% suitable for them.
  16. We ensure that all communication lines are clear and transparent.
  17. All customers are given a direct office number to speak with a representative of HomeSmile, the company email, and the personal mobile telephone number of their local agent.
  18. Customers are also actively encouraged to provide the company with feedback during the term of their loan via a customer survey.
  19. This helps formulate qualitative feedback on the services and products we provide, and helps require management data that is reviewed and used to enhance business performance.
  20. Customers are also outlined of their right to make a compliant.
  21. They are provided with the direct office number to submit a compliant, and the company email.
  22. All staff of HomeSmile are trained on the complaints procedure, and we ensure that this process is clear and transparent for the customers.
  23. All complaints are handled by the Operations Director and customers are given clear feedback during the complaints process by either telephone, or email.
  24. Customers do not hit any post sales barrios when they are using HomeSmile.
  25. All products provided by HomeSmile operate the same way after the point of sale, as they did during the pre-sale adequate explanation.
  26. Forbearance is used for customers that are in arrears, and payment plans are provided to customers that validate that their financial circumstances have changed.
  27. Treating Customer Fairly testing is completed by HomeSmile to access if any weaknesses may crystallise.
  28. Regular management meetings are held and minutes taken to discuss TCF and consider any possible policy changes.
  29. We strive to always improve the service and products we provide.