re: Process4 Aug 2020 10:20
We're hooked up on the level of interest but that won't be the issue, it'll be the process and whether the advice given was treating customers fairly and whether the process complies with the rules.
For example,
An advisor has to make a customer aware of other products, even if they don't sell them, so that the customer understands the alternative routes to borrow
They must have a 7 day gap between asking for the loan and then being recontacted (called a cooling off period)
Advisors have to be approved persons by the FCA
There are a myriad of other rules particularly around debt restructuring and also extending facilities to people who want to borrow more.
Its not about affordability this is a total red-herring. It's the SALES PROCESS where this is broken.
The FCA has ordered them to pay compensation and there will be a formula to determine how much.
The danger is very simply down to whether the risks and controls became lax over time and with new management, or whether the sales processes were always over-stepping the mark in which case the same rule applies to all previous loans.
What we really need to understand is what Amigo and other guarantor lenders are falling foul of?? What are the things that have systematically been done wrong to the detriment of customer. If we knew that we could make a better judgement. There is much more to this than affordability even when JB tweets about using Transunion like the other Banks, even he, I suspect is throwing a red herring out.
How are Sales guys compensated/insentivised?
Who are the risk and compliance guys in the business - in fact do they even have one??
There is an awful lot we don't know and that we can't no which is why this is a highly highly speculative punt.
One that;s worth taking but there's lots more to this and it won't be an easy fix - its highly possible that Amigo is left to unwind in an orderly fashion and pay out what it can before going into receivership. I'm sure I'll get lots of haters for saying it. But its a version of events that is still highly possible.