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Sales Procedure Guide

3.4 // Affordability

Sales Procedure Guide

3.4 // Affordability

Affordability

Evolution and our dealers must have processes in place to meet the FCA requirements for credit brokers, found in CONC 5.4, relating to affordability.

These include CONC 5.4.2R:

(1) In giving explanations or advice, or in making recommendations, a firm must pay due regard to the customer’s needs and circumstances. (2) In complying with (1) a firm must pay due regard to whether the credit product is affordable and whether there are any factors that the firm knows, or reasonably ought to know, that may make the product unsuitable for that customer.

DealerZone has been designed with CONC 5.4 in mind and includes:

Steps in the application process to check customer affordability designed to capture crucial information that our lenders require to make responsible lending decisions.

Our dynamic data capture solution that profiles a customer’s application as you key in critical data and adjusts the required mandatory fields accordingly.

Enhanced capture of settlement details. Whilst not mandatory, the details of the settlement funder and the monthly repayment on the settlement loan can be entered. This useful information can assist Evolution and our lenders in the underwriting process and affordability assessment.

Finally, customers are asked before submission to confirm that the loan they are applying for is, in their assessment, affordable for them. They must give details of any reasons why the loan may not be affordable throughout the duration of the loan.

If they select this option, a free format box allows them to give details that will be transferred to our underwriters. Please note that all applications of this nature will be referred to manual underwriting and will not go through the automated decision systems.

We also ask that you not use this as a general notes section. It is specifically for capturing information about affordability and will only appear if the customer selects to say they believe the loan may not be affordable.

If you become aware of this information after your customer has been proposed, you should contact our underwriting team as soon as possible.

More information on the role and responsibility that Evolution and our dealers have in assessing customer affordability can be found in CONC 5.4.

Next // 3.5 Vulnerable Customers