Financial Promotions and Client Communication | Qualifying Credit and Selling | Mortgage and Home Finance Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

6.9 Financial Promotions & Client Communication

The company has strict policies, procedures and audit checklists for all financial promotion materials and client/customer communication. Please refer to the promotions and communications section of the manual for our procedures and controls in this area.

6.9.1 Qualifying Credit Financial Promotions

Where any firm or person makes a real time financial promotion of qualifying credit on behalf of the Company, we always ensure via our contract terms, remote audits, telephone recording checks and physical audit checklists, that: –

• They make the purpose(s) of the financial promotion clear at the initial point of communication, and identify themselves and as being a representative of the company
• If the time and method of communication were not previously agreed by the recipient:
  • They check that the recipient wishes them to proceed
  • They terminate the communication if the recipient does not wish them to proceed (but may ask for another appointment)
• They recognise and respect, promptly, the right of the recipient to:
  • End the communication at any time
  • Refuse any request for another appointment
  • They give any person with whom they arrange an appointment a contact point
• They do not communicate with a person:
  • At an unsocial hour, unless the person has previously agreed to such a communication
  • On an unlisted telephone number, unless the person has previously agreed to such calls on that number

Our own business practices follow the guidance set out in MCOB 3A.4.1R, which recognises that an unsocial hour usually means on a Sunday or before 9am or after 9pm on any other day. It could also mean other days of the week or other times if the firm knows that a particular customer would not wish to be called on that day or at that time for reasons of, for example, religious faith or night shift working.

6.10 Advising & Selling

The rules and regulations found in MCOB 4, emulate the FCA’s Principle 6 (Customers’ interests), Principle 7 (Communications with clients) and Principle 9 (Customers: relationships of trust). The company has developed its Advising & Selling Policy based on the rules, requirements and obligations imposed on a firm who is regulated under MCOB 4.