Responsible Lending Policy
Evergreen Finance London Limited is a high cost short term instalment lender offering loans of £200 – £1,500 for a duration split over up to 2 – 6 months (instalments). The minimum instalment duration for the first instalment is 5 days.
The maximum loan for new customers is limited to £800. Existing customers (that is, previously approved customers who have already had at least one loan with the Company) have a max loan limit of £1,500.
We hold a valid license with the Financial Conduct Authority in order to provide credit services in the UK and we are regulated by the Consumer Credit Act 1974 and all relevant and applicable consumer credit legislation and regulations.
We are a responsible lender and our policies, practices and procedures comply with the previous regulator, the OFT’s Guidance on Responsible Lending (as issued in March 2010, and amended and updated in February 2011). The Guidance ensures that we act fairly and responsibly in all our dealings with you, the borrower, in any agreement pursuant to which we lend you money.
We are here to provide small, short term instalment loans to help you through in the event that you are running short or have an emergency cash-flow issue. We offer very flexible repayment terms as well as transparent charges and a completely confidential process from beginning to end. We actively encourage our customers to repay the loan as quickly as possible thereby saving you money in interest and at the same time allowing manageable payments. We emphasise that we wish customers to repay the loan as agreed to avoid any late fees.
Our loan process is straightforward, clear, transparent and flexible. Throughout the application process we will give you all the information you need to make a sound borrowing decision, and during our open hours we always strive to be available to deal with and resolve any queries you may have.
Before approving you for a loan we will undertake an assessment of your credit worthiness. We will consider the potential for the commitments under the loan agreement to adversely impact your financial situation and also take into account your ability to make repayments as they fall due over the life of the regulated credit agreement.
We believe that financial responsibility is a 2-way process. Whilst we aim to act responsibly in all our dealings with you and at whatever stage (whether you are contacting us with an initial enquiry or you have already completed a loan agreement with us), it is important that you understand the way we work and what you can expect of us, because in order for us to act responsibly we need you to also be responsible, honest and open with us in all our dealings. In this way, we can then deal with you in a manner that is best suited to your needs, requirements and circumstances.
For us to be able to act responsibly, we need you to act responsibly, and to provide us with all the accurate information that we require in order to make an informed decision as to how we can best meet your needs. We will in any event carry out our own checks and safeguards, including a credit search carried out through a third party credit reference agency on every application for credit (even if you are an existing customer – since we recognise that your circumstances can change swiftly, sometimes (unfortunately) for the worse).
We trust you to be responsible and to make the best and most sensible decisions before entering into a loan agreement with us, and we expect and trust you to enter such an agreement with us only on the basis that you are confident that you can meet your obligations under the agreement and repay any loan as agreed.
We will never force or pressure you to borrow money, or to borrow more money then you had intended. In the event that a member of staff is found to be behaving (or have behaved) inappropriately in their dealings with you, this may be deemed misconduct, serious misconduct or gross misconduct. Such misconduct will lead to disciplinary proceedings being instigated against (and potentially, disciplinary sanctions being imposed against) that member of staff. We have procedures and strict policies in place to deal with such occurrences.
Such inappropriate conduct may include the following:-
- unfairly encouraging you to increase or “roll-over” your loan, or otherwise agree to a loan that is likely to be beyond your means;
- repeatedly refinancing an existing credit commitment in a way that is unsustainable;
- allowing you to enter into a number of separate short-term agreements, where the overall effect is to increase your indebtedness in an unsustainable manner;
- failing to ensure that, as far as possible, information on an application is true and correct;
- encouraging or creating false information on an application;
- inserting or including information on your application without your consent;
- accepting your application for credit where it is believed that you may not have been entirely accurate with the information provided in support of your application;
- dealing inappropriately with you where you may be in a vulnerable position;
- pressuring or harassing you to take one or more of our products;
- not allowing you sufficient time to consider your options and reach a decision;
- encouraging you to agree to a higher loan than may be appropriate or affordable;
- falsifying signatures or documents.
High cost short term loans are not appropriate for long term borrowing and can be an expensive way of borrowing in relation to other larger and longer term loans available on the market.
Thus, we have a maximum limit of £800 on loans to new customers, and a maximum duration on all loans of 6 months.
We will determine the amount you can borrow based on your incomings and outgoings and upon the assessment of our underwriters, who will review your credit report to assess your financial position before we agree to advance you a loan.
We always carry out a credit search via a third party credit reference agency, so as to satisfy ourselves that you can afford to repay the loan for which you have applied (i.e. that you can repay the loan amount and the interest we charge thereon).
We also recommend that you consider your financial situation carefully before making any decision on borrowing money. The repayments due under any loan agreement may place you under additional financial pressure and we would urge you therefore not to apply for a loan if you feel that you may not be able to make your repayments in full and on time.
The amount payable by you under the loan will be shown clearly on the pre-contract information we provide to you, together with on the credit agreement, so that you can make an informed decision prior to entering into the agreement with us. Our charges and fees are also displayed on those documents and are also set out in all relevant correspondence to you from us (normally sent by email) and on our website.
You will always be encouraged to settle your debt as soon as you can to avoid accumulating additional interest charges and/or any other late payment charges or fees.
If you comply with the terms of your loan agreement with us, and make all repayments on time and as agreed, you will only be required to repay the amount in the loan agreement – namely, the sum advanced, the interest thereon and any fees notified to you and agreed with you on your pre-contract and consumer credit loan agreement. You will not be required to pay any other fees, whether hidden or otherwise.
You will only pay additional late charges in the event that you miss a payment or fail to make a payment in full in accordance with your agreement with us, and your account falls into arrears. These charges are clearly set out in the pre-contract information we provide to you, the credit agreement, all relevant correspondence to you from us (normally sent by email) and on our website.
If you are experiencing financial difficulties and finding it hard to make repayments in full and/or on time, we will ensure that we do everything we can to help you, and we will act reasonably, fairly and responsibly in all our dealings with you.
We will try to find an alternative way for you to settle your liability to us, such as placing a cap on further interest accruing (that is, more interest then originally agreed on your credit agreement) and paying by way of smaller, more manageable instalments, if and where appropriate.
As a business we are determined to treat borrowers in default or arrears difficulties with understanding and due consideration. If it becomes apparent that you are moving towards a situation in which you are “unable to pay” (as opposed to “can pay but won’t”) we will always endeavour to treat the matter with forbearance until your circumstances improve.
Our staff training provides that borrowers in default or arrears are treated with understanding particularly if a borrower’s mental capacity is (or may become) an issue. Training of staff concerned with Collections also incorporates the provisions in the Office of Fair Trading Debt Collection Guidelines and Financial Conduct Authority Consumer Credit Sourcebook rules.
Our procedures in this area ensure that you are:
- not placed under any physical or psychological harassment;
- given every opportunity to resolve the situation;
- given proper and suitable consideration if your mental capacity is in doubt;
- not asked for unreasonable charges;
- allowed alternative affordable payments when a reasonable proposal is made;
- informed of any additional charges or interest if applicable; and
- not required to pay arrears in one payment, or within a very short period, unless it would be reasonable to do so;
- not subject to excessive or unreasonable charges (or, indeed, hidden charges).
We do not work on the notion of increasing loan amounts to you as you pay off your loans as this would be classed as irresponsible lending.
It is very rare that we will allow interest only payments and always actively encourage you to pay off as much as the loan as possible each month.
We will not charge you unreasonable fees for late payment or other default under the agreement, and we will not harass you if your account is in arrears. Our charges are capped, so that you will not be subject to excessive or unreasonable charges or to charges that you were not expecting and/or not previously aware of.
We will inform you if you go into arrears and will send you a notice of the sums in arrears and provide the required Financial Conduct Authority information sheet to accompany this notice. We will also notify you if you incur a default sum (by way of a notice of default).
We operate a fair collections’ policy and we will always endeavour to give you adequate time to resolve any financial difficulties you experience in repaying the loan.
We do not immediately sell debts on to third parties in order to allow you the opportunity to arrange a repayment plan quickly and easily.
We consistently undergo strict procedures (and a periodic review of the same) to ensure our continued commitment to responsible lending for the benefit of our customers and our business model.
We encourage you to raise any issues with us by telephone or in writing. We will of course discuss any complaints you may raise with us regarding our service and will seek to resolve any such complaints or concerns you may have. If we cannot resolve them we will advise you on how to take your concerns further should you remain dissatisfied.