Updated: 01. 03. 2024.

NACFB assured

Policies and procedures

We conduct a proportionate assessment of a firm’s policies, procedures, and governance, demonstrating firms have adequate systems and controls to manage their business effectively. The NACFB sets an equal assessment against regulated and unregulated firms, in which we expect to see evidence that a client is treated fairly with TCF embedded by design into a firm’s framework.

Definition

The broker has a Complaints Policy in place.

Requirement

Complaints policy is in place, it is appropriate and in line with regulation.

Observation

An internal Complaints Handling Procedure has not been provided.

Action required

Please implement an internal Complaints Handling Procedure. A template can be found in the NACFB document library.

Financial promotions

This segment of our AP is to evaluate the firm’s financial promotions against the relevant rules and guidance of the FCA. The Association’s Code of Practice states that ‘members must at all times comply with prevailing legislation in the area of Financial Promotions and recognised advertising standards.’

Definition

The website appropriately discloses the firm’s FCA status.

Requirement

FCA registration number and regulatory disclosure correct: Authorised and Regulated by the Financial Conduct Authority, stating ‘we are a credit broker, not a lender’, the breadth of lenders used, and the.

Observation

Your FCA number and commission disclosure is omitted from the footer of the website.

Action required

Our FCA registration number is 723310. We may receive commissions that will vary depending on the lender, product, or other permissible factors. The nature of any commission model.

Registered office: 33 Eastcheap, London, EC3MIDT, The National Association of Commercial Finance Brokers is a company limited by guarantee. Registered in England. Company no: 03305378. This letter is intended solely for the use of the individual or entity to whom they were addressed. The contents, opinions, and interpretations within this letter are based on information given to us and may not represent an opinion and interpretation that might otherwise be made in consideration of information not disclosed. The opinions stated are not intended for use in any legal proceedings and should not be disclosed to third parties without the consent of the NACFB. If you have received this letter in error, please advise us and destroy the letter. Any opinions expressed in this letter are views of the sender and do not necessarily reflect the views of NACFB.

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