Short Term Lending Code
Our main aim is to treat all customers fairly and use forbearance in all of our
dealings with you.
PiggyBank is authorised and regulated by the Financial Conduct Authority and as such, is committed to following the rules and guidance laid down by them as well as all associated laws and regulations such as the Consumer Credit Act. We have also taken it upon ourselves to follow the key issues outlined in the Customer Charters and Lending Codes of the FLA, BCCA, CFA and CCTA and to this end have devised our Short Term Lending Code.
A Good Practice Customer Charter should set out in a clear, concise and user-friendly format what customers of payday and short term loans should expect from their lender.
Our Short Term Lending Code will:
- highlight our key commitments to you, including providing clear information about how the loan works, the price per £100 borrowed as well as the APR, and any charges incurred as a result of missed or late payments and default;
- explain how we will communicate with you and how you can contact us;
- explain how we assess if you can afford a loan; and
- explain how to complain if there is a problem and signpost you to sources of free and independent debt advice and relevant helplines.
Lending to new or existing customers
In addition, we will:
- Act fairly, reasonably and responsibly in all our dealings with you.
- Comply with all relevant legal requirements and have regard to relevant rules and guidance produced by the Financial Conduct Authority especially with regard to responsible lending.
- Make sure all advertising and promotional material is clear, fair, not misleading and complies with relevant advertising regulation.
- Give you the full name and contact details of our company providing the loan.
- We will not pressurise you into taking out a payday or short term loan.
Extending/Deferring the term of your loan
We will only extend/defer the term of your loan if we believe it is in your best interests and after conducting an affordability assessment:
- We will not pressurise you to extend/defer the amount you owe.
- Only consider extending/deferring the term of your loan if you ask us to and after we have reminded you of the risks of extending a short term loan. If you are in financial difficulties, you should let us know as soon as possible and we can explore new arrangements with you for paying off your debt.
- Carry out a sound, proper and appropriate affordability assessment before the term of the loan is extended.
- Clearly explain any additional costs of extending/deferring the term of your loan.
Robust credit assessments
As responsible lenders, we will:
- Tell you that a payday or short term loan should be used for short-term financial needs and is not appropriate for long-term borrowing or if you are in financial difficulties.
- Check whether the loan is suitable for you, taking account of your circumstances.
- Make sure that all loan applications go through a sound, proper and appropriate affordability assessment and credit vetting which includes your ability to repay your loan in a sustainable manner.
This assessment may look at a combination of:
– the amount of credit requested;
– your income;
– your age;
– how you have handled your financial affairs in the past;
– information from credit reference agencies;
– your personal circumstances and any changes in the future you have told us about;
– the results of credit assessment techniques: for example, credit scoring; and
– information you have supplied, including proof of your identity.
We will explain in general terms what types of information we will consider in making a decision, if you ask us to.
We will not provide you with a payday or short term loan if you have told us you are in financial difficulties or our credit assessment indicates that you may not be able to repay the loan.
Increased transparency about loan repayments to help customers make better informed decisions and making sure that continuous payment authority is not used inappropriately for those in financial difficulty.
- Explain clearly how continuous payment authority works and how payments will be deducted from your bank account. This will help you decide whether this type of repayment is acceptable to you before you take out the loan.
- Make clear to you your rights to cancel a continuous payment authority before you take out a loan. We will remind you that if you cancel, you will still owe any outstanding debt and will need to provide an alternative method of repayment on the due date to avoid going into default. We will give you a contact point should you want to cancel the payment authority directly with us.
- Always notify you by email, text or phone at least 3 days before attempting to recover payment using continuous payment authority on the due date. This communication will ask you to let us know if your circumstances have changed and you have difficulty in repaying the loan.
- Send you further regular reminders when a continuous payment authority is being used and where you have not made repayment on the due date. These reminders will give you a contact point so you can tell us if you are experiencing repayment problems or if you want to cancel the payment authority.
- Repay any amounts we have taken via the continuous payment authority where this has caused you to get into financial difficulty, and you have told us about this.
Help for customers in financial difficulty
We are committed to using forbearance in all of our dealings with you. To this end we have a dedicated Forbearance Team. If you are in financial difficulty, we will:
- Deal with you empathetically and positively and do what we can to help you manage what you owe. This may include making new arrangements about how you will pay off your debt. In doing so, we will consider other debts that you owe.
- Freeze interest and charges if you make repayments under a reasonable repayment plan or after a maximum of 60 days of non-payment.
- Not contact you or take any action to recover the money you owe us for 30 days, if you are making a genuine effort to agree a repayment plan using either a debt-counselling organisation or a ‘self-help’ approach (for example, you are suggesting a repayment plan). If you or your adviser provide us with clear evidence that real progress is being made in reaching a repayment plan, but work has not yet concluded, we will extend this ‘breathing space’ for an additional 30 days.
- Tell you about free and independent debt-counselling organisations. These include: Citizens Advice, Step Change, National Debtline or the Money Advice Service.
- Not allow you to borrow further from us until all outstanding loans with us have been repaid.
- Deal with people whom you have asked to act on your behalf, with your authority, unless those people behave unreasonably.
Data protection and marketing
- Follow all relevant privacy and data protection law.
Not reveal information we hold about you unless:
– we have your permission to do so;
– we have to by law;
– we have a public duty to do so; or
– there is a good reason for us to do so (for example, legal reasons such as fraud)
- Not specifically target our marketing on groups of people known to be financially vulnerable or credit-impaired.
Rigorous complaints procedures
When you take out a loan, we will tell you about our complaints handling procedure. We will do this:
- in writing – at or immediately after the point of sale (Pre Contract Information (SECCI) and Loan Agreement);
- by giving you a copy of it, if asked to do so; and
- by giving you a copy of it, if you send us a complaint
This information is also available on our website.
If you want to make a complaint, you should contact us first using our complaints procedure. We will acknowledge your complaint promptly and in any case within five days of it being received by our Complaints Department. If we need to investigate your complaint further to respond fully, we will tell you and keep you regularly updated.
If you are still not satisfied after receiving our Final Response, you may refer the complaint to the Financial Ombudsman Service and we will give you their details.
Updates and twelve month review
A review of the effectiveness of the Short Term Lending Code will be undertaken in Spring 2018.
It may be updated sooner if rules or legislation governing our business requires us to.
Why Choose Us?
- Direct Lender
- No Payout Fee
- No Hidden Costs
- Fast Online Application
- Multiple Repayment Options
- 100% UK Based
- Fully Authorised by the Financial Conduct Authority