Asset Finance  through peer Lending

Introduction

We aim to provide a first class service to our clients, but in some circumstances we are going to fall below some clients expectations. We will attempt to rectify any issue you have with the Platform or our company as soon as possible, but if you feel the issue needs to be escalated to a complaint, these are the procedures we will follow.

These procedures are based on the requirements of the Financial Conduct Authority who we are regulated by.

The Ablrate rules apply to all staff, all areas of activity and all complainants.

Definition of a complaint

The Financial Conduct Authority defines a complaint as:

“An expression of dissatisfaction whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about a firm’s provision of, or failure to provide, a financial services activity.”

We extend this to also mean where an individual has failed to meet our client’s expectations or where we have done something, or omitted to do something, that has caused our service to fall below those expectations.

Who can complain?

Anyone who has either:

(a) Any customer, or potential customer who is, or is potentially, a borrower or lender

(b) Those who may have an indirect relationship with the firm, such as an intermediary or a professional working on behalf of a customer or potential customer

A complaint may also be made by:

(c) someone authorised and appointed by a customer to complain on their behalf

(d) someone authorised by law to complain on behalf of the customer, this could be a lawyer, an executor of an estate, accountant etc.

We would require relevant copies of authorisation before we could release any information or deal with the complaint lodged by a third party.

Publicising our complaints procedure

We will publish our complaints procedure on this section of the website and may update it from time to time without notice to our customers.

Complaints can be lodged via our online support ticket system (if you are a registered member) and as such you will be able access the logs of the complaints, who has responded etc. You will receive notifications via your registered email with updates to that ticket.

You may complain by telephone and we will provide an electronic record of that complaint.

You may complain by email.

You may complain by post and we will (if we have an email address on file) provide you with electronic copies of the complaint.

Initial point of contact.

The initial point of contact for complaints received is support@ablrate.com. This applies to direct complaints and email complaints.

Sources of complaint Direct Complaints

E-mail

E-mail complaints should be directed to the dedicated mailbox:

support@ablrate.com

The e-mail will be logged in and the details entered into the complaints register as well as being routed to our ticketing system. Each entry will note the person making the entry and the date it is made.

Mail

Although we would expect most communications to be by email, there may be some complainants who will want to use Mail

All written complaints should be directed to the dedicated address as follows:

Ablrate Customer Services, Scotts Sufferance Wharf, 5 Mill St, City of London, Greater London SE1 2DE

All written complaints will be date stamped, scanned and emailed to support@ablrate.com at which point they will have the details entered into the Complaints Register.

Complaints received within the business

This type of complaint may arise when receiving a telephone call or from a direct email, or via our support ticketing system. Telephone complaints will immediately be written up and forwarded to support@ablrate.com with any relevant details.

Telephone conversations include online equivalents such as Skype etc.

Complaint handling process

Emails to support@ablrate.com are delivered to

• The Head of Compliance (HOC)

• The Head of Customer Service (HOCS)

• The Complaints Administrator (TCA)

The Head of Compliance will be the person responsible for ensuring that this Complaints Procedure is followed and adhered to. The HOC will oversee and have responsibility for compliance aspects and the HOCS is responsible for complaint handling and administration of complaints.

If in the opinion of the HOCS the complaint is straightforward then it will be dealt with by the Next Day Process. If for any reason this is not possible, then a more formal written procedures will follow.

Next Day Process

This allows that if the complaint can be resolved to the satisfaction of the person making the complaint:

• by the end of the next business day following receipt of the complaint.

• with no written correspondence being required.

If this is the case then no further interaction with the complainant is necessary with regard to the complaint. This implies that the complaint will need to be discussed by telephone with the complainant.

If the Next Day Process is appropriate to the complaint a summary of the complaint will be passed to the relevant Department Head who will contact the complainant to discuss an acceptable outcome. If an acceptable agreement can be concluded a note of the discussion and outcome will be noted into the complaints register. No further action will then be necessary once remedial action has been taken.

If this is not possible (e.g. the person cannot be reached or an agreement cannot be achieved) this information will be fed back to the support@ablrate.com team who will reroute the complaint through the formal complaints handling process.

Formal complaint process Within 24 hours

The Complaints Administrator will add the details of the complaint to our Complaints Register and advise the Head of Customer Services, the Head of Compliance and the relevant Head of Department.

The Complaints Administrator will email the complainant acknowledging their complaint, which will include setting out our understanding of the complaint if it has arisen within the business and attaching a copy of our Complaints procedure

Complaints made by third parties

Where a complaint is made by a third party (A) on behalf of a complainant (B), we need to ensure that:

- B has authorised A to complain on B’s behalf and

- B gives their consent for us to provide A with details and

- B gives their consent for us to record information provided by A

We cannot therefore provide any further details to A until we have made sure that he or she is authorised to make the complaint.

We do this by sending an acknowledgement email to B requesting that they confirm that they have authorised A to complain to us and to receive and provide information. A Letter of Authority should be enclosed. A copy of this acknowledgement should also be sent to A with a covering email explaining why we have written to B.

We should not enter into any further correspondence with A until we have received a valid letter of authority.

If the complainant is deceased or mentally incapable

Where the complaint is made by a third party (A) on behalf of an eligible complainant (B) who has died or has become mentally incapable, we need to ask for proof that A is authorised by law to make the complaint on B’s behalf, unless we already hold a valid copy of the relevant documentation in our records.

- Where B has died, we need to see evidence that A has been appointed as B’s personal representative or executor

- Where B has become mentally incapable, we will need to see an Enduring Power of Attorney (EPA) or a Lasting Power of Attorney (LPA) giving A authority to act on B’s behalf.

The letter to be sent to A will request a copy of the relevant documentation and ask them to confirm our understanding of the complaint.

Unless we already have documentary evidence that B is deceased or is mentally incapable, we should also send a letter to B providing details of the complaint being made and asking them to contact us if they have any queries. This will alert the complainant if the complaint is being made without the necessary authority.

If we already have a copy of B’s death certificate we should not write to B.

If we already have evidence that B is mentally incapable, we will probably also have details of a person (X) authorised to deal with us on their behalf. If this is not the third party who has made the complaint, we should send a letter providing details of the complaint to X asking them to contact us if they have any queries.

We should not enter into any further correspondence with A until we hold copies of the relevant documentation authorising them to make the complaint on behalf of B.

Keeping the Complainant Informed

As soon as the investigation has been completed and the Final Response agreed, Ablrate will advise the complainant in writing.

Within 28 days (4 weeks)

If the investigation has not been completed within 28 days (4 weeks) of receipt of the initial complaint, we must send the customer a 4 week holding letter to let them know what progress has been made. We should tell the customer that we will write again within 4 weeks if we have not finished our investigation.

Within 56 days (8 weeks)

If the investigation has not been completed within 56 days (8 weeks) of receipt of the initial complaint, we must send the customer an 8 week breach letter to let them know what progress has been made.

We should also take the opportunity of updating the complainant before the above deadlines are reached if we have anything material to communicate.

Complaint Investigation and Progress

The complaint will be referred by the Head of Customer Service to the relevant Head of Department for investigation. They may delegate this responsibility but must ensure that the person concerned has sufficient expertise to investigate the complaint effectively

Where there is more than one area of complaint and these fall into different categories, the Head of Customer Service should ensure that a single response is sent responding to all areas of complaint.

The individual investigating will ensure that they email support@ablrate.com and the advising of all progress as it arises and in all circumstances on the last working day of each week if there has been no progress.

Complaint resolution – final response

The final response email should include:

• A summary of the complaint

• A summary of the outcome of our investigation

• A statement of whether Ablrate acknowledges any fault on its part

• Details of any offer made to settle the complaint

• Details of how long any offer to settle the complaint will remain open

The Complaints Register

The complaints database will be updated by either the Compliance Administrator or Head of Customer Service or delegated where necessary.

Record Keeping

Records of complaints will be kept for a minimum of three years. The record should include:

• The name(s) of the complainant(s)

• The substance of the complaint

• Any correspondence between the firm and the complainant including details of any redress offered by the firm.

Management Information (MI)

A review of all current complaints will be undertaken on a monthly basis by senior management.