AFFORDABILITY AND CREDITWORTHINESS
1.
This procedure sets out the
Firm’s approach to lending with regard to affordability and creditworthiness.
2.
Loans issued by the Firm will be
repayable in accordance with their term. In order to ensure that the loan is
affordable to the borrower the Firm must make an assessment of the borrower’s
creditworthiness and affordability.
3.
Creditworthiness must be
undertaken by way of sufficient information from the borrower and a credit
reference agency check where required and is used to determine whether the
borrower is a credit worthy individual.
4.
Affordability requires an
assessment of the borrower and a decision as to whether the credit is
affordable for the duration of the product.
5.
Creditworthiness and
affordability assessments will be made on every application including repeat
customers.
6.
Loans must not be issued by the
Firm unless it is clear as a result of the creditworthiness and affordability
assessments that the borrower is both worthy of credit and is able to afford
the repayment of the product for its duration.
6.1. Such
decisions should be based upon:
6.1.1.
Any adverse information known or
discovered about the borrower including that relating to anti-money laundering
or financial crime.
6.1.2.
The borrower’s current income and
expenditure
6.1.3.
The borrower’s likely profile of
income and expenditure over the term of the product
6.1.4.
Any liabilities of the borrower
which will become repayable during the term of the product
6.1.5.
Any redeemable assets of the
borrower from which income will be obtained during the term of the product.
6.1.6.
The borrower’s historic record of
repayments on credit agreements
LENDING DECISIONS
7.
The majority of lending decisions
are programmed within the Firm’s lending software system and no decision to
lend must be made unless the borrower meets the criteria or a manual decision
to lend has been made by a nominated individual.
8.
The nominated individual is a
nominated underwriter.
9.
As members of the Consumer Credit
Trade Association, we will allow customers to appeal any decision to refuse
credit if the customer believes that refusal to be unreasonable. We will ensure
that customers are informed of this right on our website and when the decision
to decline is communicated to them.
RECORD KEEPING
10. A record of
all information used in the making of the lending decision must be retained by
the Firm for a duration of six years after the repayment of the product.
PUBLIC INFORMATION
11. The Firm’s
website will contain the following information about its Responsible Lending
Policy:
Here at
WageDayCash we take our responsibility towards you seriously. This means
providing you with all the information you need so that you can decide whether
the loan is suitable for you before you decide to complete the application. Our
loans are designed to assist you with short term financial needs and that they
can become expensive over the longer term. That’s why there are warnings on our
website and information about gaining access to free forms of money advice. At
the bottom of this section, we include other options for you to consider if you
are in financial difficulties.
It also
means that we will conduct extensive checks on your creditworthiness and
ability to repay your loan on time without causing you significant financial
difficulties. These checks will be based on information you provide us within
the application process and extra information we take from other sources such
as credit reference agencies, fraud prevention agencies etc. You can see our
Privacy Policy for more information on the type of information we collect, how
we collect it and who we share it with.
As members
of the CCTA, we also have specific responsibilities towards you. Please click
here to read more information about the CCTA and what it means to you that we
are members.
Our
commitments to you:
·
We will provide you with adequate
information for you to assess whether the loan is suitable for you;
·
We will assess your application
fairly based on information provided by you and from other sources;
·
We will communicate our decision
to you in writing as soon as it has been made; and
·
We will allow you to appeal any
decision to refuse you credit to a senior risk manager if you believe it to be
unreasonable.
When making
our assessments as to creditworthiness and affordability we consider a large
amount of information which will include:
·
How much you want to borrow and for
how long;
·
Your income and expenditure
information’
·
Your credit history, for example
whether you have been meeting your bills as they fall due;
·
Any existing financial
commitments you tell us of or we can see via a credit report; and
·
Any information which might
indicate whether you are in financial difficulty or are vulnerable.
Please find
below a list of organisations you can contact if you are in financial
difficulty:
·
Money Advice Service: For free,
unbiased and easy-to-access money tools, information and advice, visit www.moneyadviceservice.org.uk or phone 0300 500 5000 to speak
to a Money Advisor.
·
Advice UK: Member centres offer
debt advice including specialist advice for minority communities and people
with disabilities – www.adviceuk.org.uk or phone 0300 777 0107.
·
Christians against Poverty (CAP):
For free debt advice in your home, check post code coverage at www.capuk.org then call 0800 328 0006.
·
Citizens Advice: For advice and
information on debt and other topics, visit your local Citizens Advice Bureau
(address in the phone book) or go to www.adviceguide.org.uk.
·
National Debtline: If you live in
England, Wales or Scotland phone 0808 808 4000 or visit www.nationaldebtline.org for debt advice and information.
·
StepChange Debt Charity: For debt
advice throughout the UK Phone 0800 138 1111 or visit www.stepchange.org
6.
This information will be reviewed
every six months and/or updated as necessary.
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