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Treating Customers Fairly


Treating Customers Fairly (TCF) has been the cornerstone of financial regulation for consumer credit for some time. The Financial Conduct Authority (FCA) has made it clear that this principle will be given higher urgency in terms of enforcement. The FCA requires that all businesses it regulates comply with their provisions on Treating Customers Fairly (TCF) and on embedding good consumer outcomes into all parts of their business culture.

There are no tick boxes, no absolute guidelines – it is a business principle that the FCA expects regulated entities to adopt at a deep cultural level. This guide is a high-level overview of how to fulfil the FCA’s requirements on TCF.


TCF is not the same as treating customers ‘nicely’ or providing customer satisfaction. Instead, it is designed to ensure the business puts the interests of the customer at the heart of their business, as well as the integrity of the market.

TCF is found in Principle 6 of the FCA Handbook which explains that“a firm must pay due regard to the interests of its customers and treat them fairly.” TCF is also tied to 4 of the 11 guiding principles:

  • Principle 1 – A firm must conduct its business with integrity
  • Principle 7 – A firm must pay due regard to the information needs of its clients and communicate information to them in a way that is clear, fair and not misleading>
  • Principle 8 – A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client
  • Principle 9 – A firm must take reasonable care to ensure that the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement

TCF then is about far more than just the actual customer experience at Hippo Motor Group. It is an important aspect of all areas of our business. The concepts of TCF is in every step of the sales process, from staff training to the information and financial products supplied to our customers, as well as resolving any subsequent issues a customer may have.

What Does Hippo Do?

While it would be possible to compile a huge list of things Hippo could do to ensure TCF principles are followed, this is unnecessary. The best approach is to take a principled approach.

Hippo takes the core message of honesty, integrity and fairness and applies this to any customer situation.

Hippo ensures there are appropriate processes in place to make sure TCF is delivered and have a system in place to review TCF on a regular basis, identifying any shortcomings. These are important forms of Management Information (MI) and MI is a key part of the monitoring process that the FCA expects to be followed.

Key areas which are considered as forming part of a good TCF approach in our showroom are recorded to demonstrate that process controls are in place and being followed.

Application Submission

Hippo Motor Group currently sources most of its business via the internet, however other forms of marketing are undertaken as well as walk-in business. It advertises for both prime and non-prime customers looking to finance either new or used motor vehicles.

Due to the wide spectrum of customer applications, all Account Managers are trained to ensure they understand the needs and expectations of a range of applicants with vastly differing credit profiles.

Products on offer include Hire Purchase, Lease Purchase, Personal Contract Purchase and Personal Contract Hire. In addition, ancillary products, such as vehicle warranties and GAP Insurance are also provided.

All sales staff are SAF accredited.


Treating customers fairly is central to the company culture within Hippo and to this end, the process of buying a vehicle on finance has been refined to ensure that each and every customer gets the deal that is best suited to them in terms of:

  • The finance product offered
  • A wide selection of vehicles to choose from
  • The repayment is within their desired budget
  • Insurance products such as GAP and Warranty are offered

To ensure that the customer’s credit file is not adversely affected by numerous credit searches, an initial ‘soft’ credit search is completed to ascertain the most appropriate lender that best suits the applicant’s current financial circumstances.

Once it has been established, if the customer meets a prime funders lending criteria the application is sent to the company the underwriter feels is most likely to accept the application and also to the lender who can offer the customer the most appropriate facility in terms of meeting their monthly repayment expectation and maximum loan duration. For example, some lenders offer to finance older vehicles or accept higher mileages at end of term etc.

Currently, there are five prime funders who offer the same APR:

  • MotoNovo
  • Blackhorse
  • Mann Island
  • Alphera
  • Santander

If an application fails to meet the criteria set out by one of the prime lenders above, then Hippo has the facility to access a panel of sub-prime lenders who look to approve customers with varying levels of derogatory credit. The underwriter will review the application and credit file and make an informed decision (based on the customer profile and current credit circumstances) as to which lender the application is sent to.

Each of the funders has some kind of niche or area they accept business in, that’s the reason we have so many on our panel. For instance, Billing will accept provisional licence holders, Startline offer a non-prime PCP and Premium Plan and Moneybarn will accept people currently in an IVA.

The current panel of non-prime lenders is detailed below, and they offer rates varying from 12.5% APR up to 49% APR depending on the customer’s current financial circumstances.

The individual rate for the customer is set by these lenders.

Sub-prime lending panel:

  • Blue Motor Finance
  • Advantage
  • Moneybarn
  • Marsh Finance
  • Oodle
  • Startline
  • Billing
  • Premium Plan
  • First Stop

Representative Example of Credit

We expect more than 51% of our customers to achieve this rate.

Loan Amount Total Cost of Credit Representative APR 60 Monthly Payments Deposit Amount Loan Term Total Amount Payable
£7,500 £3831 19.1% APR £188.85 £0 60 Months £11,331

All offers are subject to change at any time, you must be 18 or over and finance is subject to status, vehicle availability and terms and conditions apply. We can introduce you to a limited number of finance companies, a commission may be received. Failure to maintain payments may result in termination of your agreement and the vehicle being returned, this could affect your credit rating and make it more difficult to obtain credit in the future. All prices correct at time of publication.

We purchase a wide variety of vehicles from all over the country to ensure the best quality and value for our customers, all of our cars go through a thorough inspection process and if they do not meet our standards we do not sell them. We endeavour to inform our customers (where possible) the provenance of the vehicle they are buying and as such we will always inform you if the vehicle has previously been either an ex fleet or hire car. Should your vehicle be an ex hire/fleet car please do not be concerned as we would never value this vehicle differently when you come to part exchange it and there is no difference to the CAP valuation either.

You should try and estimate the distance you will travel as accurately as possible to try and avoid excess mileage charges at the end of your contract.

All pictures and/or photos and car descriptions on this site are for illustration and reference purposes only and are not necessarily the vehicle on offer. All offers are subject to change at any time and are subject to finance approval and vehicle availability. All prices correct at time of publication. E & OE.

Hippo Vehicle Solutions t/a Hippo Motor Finance is authorised and regulated by the Financial Conduct Authority. FRN 658076. We are a Credit Broker not a Lender and can introduce you to a limited number of lenders. Subject to status and to UK residents only (excl. the Channel Islands). Individuals must be 18 or over. Guarantees and indemnities may be required. We typically receive a fixed commission calculated by reference to the vehicle model, product or amount you borrow, for introducing you to a lender but this does not affect the interest charged on the agreement, all of which are set by the lender. Images for illustrative purposes only. Hippo Vehicle Solutions t/a Hippo Motor Finance is an Appointed Representative of AutoProtect (MBI) Limited for insurance distribution purposes. AutoProtect (MBI) Limited is authorised and regulated by the Financial Conduct Authority. Its firm reference number is 312143. You can check this at

We endeavour to ensure that all information including the specifications and finance availability are accurate. Whilst we make every effort to display correct information we are aware that errors may occur occasionally. We are not able, therefore, to guarantee the accuracy of all information especially when given to us by third parties. If you do require clarification of some information you have seen on our website, please email us at . This does not affect your statutory rights.

We are a broker not a lender and our registered office is Unit 26 Trident Park, Trident Way, Blackburn, BB13NU.