Promise T&C Plan for Advisers

Document Reference: PM-TCP-001 Version: v1.4 Owner: Compliance Team — Promise Money Next Review Date: [To be confirmed]

PROMISE TRAINING & COMPETENCE PLAN FOR ADVISERS

MINIMUM STANDARDS FOR THE ROLE

Adviser employees will be fit and proper for the role they are undertaking.

Adviser employees are required to inform the Firm of any Notifiable Event e.g. bankruptcy, CCJs, charges or convictions for fraud, dishonesty, violence etc, disqualification as a director, dismissal from previous employment, investigation, censure or withdrawal of approval by a previous regulatory body, Government body or agency etc.

Credit checks will be undertaken and satisfactory explanations obtained for any irregularities e.g. defaults – Self certification of credit status (and potential credit referencing ) will be carried out thereafter annually.

CV to be retained by the firm with any gaps in employment explained.

Details of the employees last 5 years employment history will be held and references obtained for last 3 years employment – in the absence of employer’s references not being obtainable due to the Company no longer trading, the firm will accept references from a previous line manager / work colleague / professional person. The firm will make an informed decision in the event of personal references having to be relied upon.

References for self employed persons will be expected from appropriate professional persons.

Sight of original industry examination certificates will be required with copies retained by the firm.

COMPETENCE ASSESSMENT

All individuals will have a Training and Competence (T&C) file created which will record their progress through 1 to 1’s, CPD records, file reviews, competence tests and observations / role-plays.

This file will be kept up to date by the individual and the supervisor and in the event of the individual leaving the firm; this will be retained for a minimum of 3 years.

Individuals will be assessed taking into account their past industry experience and qualifications achieved.

The firm will ensure that an employee’s training needs are assessed at the outset and at regular intervals. Appropriate training and support will be provided to ensure that any relevant training needs are identified and satisfied.

The firm will regularly review training methods to ensure they remain effective and appropriate.

The firm will not assess an employee as competent to carry out an activity until the employee has demonstrated the necessary competence to do so and has passed each module of an appropriate assessment as required for the designated role.

The firm will ensure that employees are appropriately supervised at all times. The level and intensity of this supervision will be significantly greater in the period before the firm has assessed the employee as competent.

The firm will ensure that an employee does not carry on an activity (other than overseeing / contributing to that activity) for which there is an examination requirement without first passing the relevant regulatory module of the appropriate examination. For example a trainee adviser who is working towards being able to advise on regulated mortgage contracts, may be deemed competent to carry out fact finds and research but not give advice without sign off from a qualified adviser who will take responsibility for the advice and work carried out by the trainee.

Once an individual has demonstrated that all KPI’s have been met and the supervisor is satisfied that the individual has achieved an acceptable standard , the individual will be signed off as competent and reduced monitoring and supervision will follow according to the experience and development needs.

SUPERVISORS

Due to the size of the firm the Principal (or designated Supervisor) is responsible for his own training and competence standards and that of any other employees.

The following assessment process will we ongoing for all Adviser employees:-

ASSESSMENT PROCESS

Random checking of ‘in progress’ and completed cases, assessing quality of advice, persistency rates,, file management and compliance standards.

Regular assessment of an individual’s development needs attainment to competence status and continuing competence standards.

Monitoring of Management Information to identify potential risk area from any one individual / monitoring spread of business / persistency rates.

Competence testing will be undertaken at least annually.

Observed interviews, call reviews or role-plays will be undertaken as a minimum standard annually.

Regular 1 to 1’s for employees not yet competent and quarterly 1 to 1’s for competent Advisers.

Ongoing feedback on a case by case basis

Regular product knowledge training both in house and through product providers.

Regular training and refresher training on systems, policies and procedures.

Recording all activities undertaken on the CPD log with a minimum expectation of 30 – 40 hours per year for competent Advisers and 50+ hours for trainee Advisers.

Minimum standards / Key Performance Indicators ( KPI’s) to achieve and maintain competence status.

Ability to demonstrate an understanding of the regulatory framework and in particular MCOB & ICOB’s.

An understanding of the firms systems, controls and reporting lines.

Understanding GDPR/Data Protection & Anti Money Laundering requirements.

Ability to gather appropriate and adequate information in order to demonstrate the “Know your Customer” requirements

Ability to demonstrate product knowledge and remain up to date with product knowledge and criteria changes.

Ability to demonstrate appropriate completion of all required paperwork accurately and fully and in accordance with internal procedures.

Ability to check of products offered or advised.

Ability to recognise potential complaints and deal with this in the appropriate manner.

Ability to demonstrate the treating customers fairly principle and demonstrate a consistent and positive attitude to treating customers fairly.

Provides a high level of service to client’s, maintains contact with clients and responds to clients needs appropriately.

Able to identify any areas of personal development or where additional training support is required and demonstrate continuous improvement.

Attainment of full CeMAP qualification (or equivalent) where appropriate for the employees role.

Able to supervise the advice of others and provide in accordance with the procedures

MINIMUM ACHIEVEMENTS TO ATTAIN COMPETENT STATUS

All advising employees will be expected to have full CeMAP (or equivalent) or to pass full CeMAP qualification within the timescales set – normally within 6 months of commencing the specific role.

In addition to this the following will be set as a minimum requirement for ALL staff involved in giving advice:-

Communication skills - verbal communication skills will be assessed through a satisfactory observation or role-play, and call recordings demonstrating ability to communicate effectively, build rapport and client confidence.

Sales process – will be assessed during the observation / role-play ensuring this is followed in a compliant manner and in accordance with the prescribed sales process for the firm.

File checks - these will be carried out on the paperwork to ensure all information has been collated in order to give the appropriate advice to meet the client’s needs and circumstances, cases will be checked for quality of advice.

A minimum of 3 fully completed cases will be reviewed for a satisfactory standard of completion prior to being signed off as competent – (this may be extended on the individual’s experience, skills, knowledge and progress.)

Written skills - will be assessed through completion of all paperwork, to include fact find, affordability assessment, insurance paperwork (where applicable) and mortgage recommendation letter.

Mortgage product knowledge - to be evidenced by the ability to explain the details of various mortgage products e.g. variable rate, fixed rate, capped rates, capital repayment mortgages, endowment mortgages, etc and various repayment vehicles also the ability to match suitable products to the clients circumstances.

Insurance product knowledge (where applicable) - to be evidenced by the ability to explain the key features and benefits and key exclusions and all disclosure requirements as required under the ICOB’s rules. Explanation of all product types i.e. term assurance, critical illness, family income benefit, buildings & contents and mortgage payment protection insurance.

Legislation - demonstrating an understanding of relevant legislation, including Money Laundering Rules and the potential risks faced within the industry by financial crime and GDPR/Data Protection Act and their impact on mortgage lending.

Feedback - case by case. Advisers will be given feedback quickly on cases which are compliance checked – good or needs improvement – to maintain a level of at least compliant with development. Such feedback will normally be recorded as CPD unless there are compliance issued needing to be addressed to prevent customer detriment which should then be considered as a trigger to move the advisor to a state of non compliant for the relevant task.

Feedback – formal. Advisers not deemed competent will have formal1 to 1’s normally monthly. Advisers deemed competent will have quarterly formal1 to 1’s - these will provide an overview of the individual’s progress to date and report on any training / development needs with set objectives.

CPD hours - will be monitored by the supervisor/ line manager on a regular basis to ensure quality and recording of appropriate CPD hours.

Reduced supervision - a minimum of 10% of all individuals cases will continue to be checked once signed off as competent. Certain higher risk areas ( such as interest only / debt consolidation / adverse / lending into retirement, vulnerable customers) may involve higher volumes of checks being carried out.

Individuals will be monitored for persistency, complaints and assessed against management information reports for spreads of business.

In the event of the supervisor not being satisfied with an individual’s standards, competent status will be reviewed and a training plan will be affected and agreed with the individual placed back on a higher level of supervision until standards have been met. This will be documented within the individuals T & C file.

Individuals will be encouraged to continue their development and where appropriate study towards additional qualifications that will benefit their role within the firm.