Compliance Pack
Consumer Duty assessment and Appointed Representative oversight evidence — how Paylo defines its market, evidences fair value, and controls the one risk that sits outside our own four walls: what gets said by an introducer, in a conversation we're not in.
Important notice: Paylo Finance Ltd is not yet operational and does not currently hold Appointed Representative status with a Principal Firm. This pack is a working draft prepared ahead of that appointment, so our compliance framework can be reviewed alongside the commercial relationship rather than after it. It is not a substitute for our Principal Firm's own oversight documentation or template, and nothing here constitutes a finalised or legally binding compliance position.
1. Business overview
Paylo Finance Ltd is a credit broker, not a lender. We introduce customers to a limited panel of lenders for unsecured consumer credit, from £1,000 to £50,000 over 6 to 60 months, used specifically to fund home improvement work.
Our distribution model runs through contractors and installers who carry out the work — not through direct advertising or in-house sales. Critically, those contractors are not authorised and are not Appointed Representatives of Paylo or our Principal Firm. They are unregulated introducers, and the entire customer journey below exists to enforce — and evidence — that boundary.
2. The four Consumer Duty outcomes
Assessed and reviewed against PRIN 2A, the same way a data protection impact assessment evidences data harm has been considered — here it's financial harm.
Products & services
Our target market is homeowners financing improvement work from £1,000–£50,000, over 6–60 months, introduced through contractors and installers rather than sold direct. Products are reviewed against that market before distribution, not after.
Price & value
Each product on our panel carries a Fair Value Assessment before it's offered: does the total cost of credit represent fair value against the benefit received, compared to like-for-like products in the market.
Consumer understanding
Financial promotions and customer-facing copy are tested for plain-language comprehension before publishing, with particular attention to customers who may be in vulnerable circumstances.
Consumer support
Support doesn't stop at completion. Queries, cancellations, arrears and complaints are handled through a dedicated support channel — see 'Complaints handling & MI' below.
3. Customer journey & friction checkpoints
This is the control that matters most: since we can't know what's said in a room we're not in, the journey is built so the installer is structurally unable to be the one who sells the finance — and every checkpoint below produces evidence, not just a policy statement.
Installer handoff
- The installer's only role is a passive handoff: a card or QR code, at quote stage if asked, or on completion.
- One fixed line only if pressed on cost: “We don't handle finance ourselves — this'll show you your options in a couple of minutes.” No numbers, no elaboration, ever.
- The installer's involvement ends there. Nothing else about finance should come from them.
Enforced time / session gap
- The QR/link leads to information only — how it works, an indicative range, nothing installer-specific — not a live application.
- To start a real application, the customer must independently return later: an emailed link, a separate session, account creation. Never completed in the installer's presence on the day.
- Timestamp of QR scan / first visit and timestamp of application start are both captured and logged. The gap itself is part of the evidence.
Paylo intake call (the core control)
- Run by Paylo before any application proceeds to underwriting. Recorded (audio) or logged (chat, timestamped) — contemporaneous and independently retrievable, not something the customer simply ticks.
- Sequence, open to specific: how the customer first heard about Paylo; what the installer actually said about paying by finance; whether any figures, rates or borrowing amounts were mentioned; whether a specific lender was recommended; the time gap since the installer left; a closing confirmation that the installer's only involvement was the handoff.
- Any answer indicating figures, rates or advice were given stops the process there: routed to compliance review, not underwriting, and the installer is flagged.
Signed declaration
- A standalone declaration, distinct from the credit agreement, confirming no representative of the installer discussed loan terms, rates, payments or eligibility, and that the customer is applying independently.
- Digitally signed with timestamp, IP address and device recorded against the case ID, so it can be pulled in isolation if a complaint arises.
Escalation & installer record
- Any flagged case from Stage 2 triggers immediate compliance review and the application is paused.
- A confirmed instance of an installer discussing terms results in removal from the network — no warnings, no second chances.
- Installer-level referral volume and any flags are logged and available to our Principal Firm on request.
Retention
- Per case: QR scan timestamp, application-start timestamp, Stage 2 recording/transcript, Stage 3 declaration with metadata, and any escalation outcome.
4. Fair value assessment
Before any lender is added to our panel, we assess whether the total cost of credit — APR, fees and any add-ons — represents fair value against the benefit the customer receives, benchmarked against comparable products in the market. This is reviewed periodically, not just at onboarding, and is revisited immediately if a lender changes pricing or terms.
5. Communications & financial promotions sign-off
Customer-facing copy — the website, application flow, and anything an installer is given to hand over — goes through a comprehension and accuracy review before publishing. The one fixed line installers are permitted to use if asked about cost (see Stage 0) is treated as a financial promotion in its own right and is reviewed on the same basis, precisely because it's the one thing said outside our own oversight.
6. Complaints handling & management information
Our complaints process follows FCA DISP timelines and is published in full at /complaints. Every customer support request is logged against a case reference and categorised — payments, account, documents, complaints, or general — so patterns are visible, not just individual cases.
Management information reviewed on an ongoing basis includes: complaint volume and category, cancellation and early-settlement rates, vulnerability flags raised during Stage 2 calls, and installer-level referral volume against flags raised (see Stage 4).
7. Training, competence & introducer oversight
Installers onboarded to the network are briefed on the single line they're permitted to say about cost (Stage 0) and nothing further — they hold no authorisation and are given no product training, deliberately, since product knowledge is exactly what they're not meant to need. Any confirmed breach results in removal from the network with no warning cycle (Stage 4). Staff handling Stage 2 intake calls are trained specifically to ask open questions before closed ones, so a rehearsed "no" doesn't pass as evidence of a clean handoff.
8. Governance & record retention
This pack, and the management information behind it, is reviewed and signed off by senior management at least annually, with root cause analysis carried out whenever a Stage 2 call is flagged or a complaint is upheld.
Per-case records — timestamps, Stage 2 recordings or transcripts, and the Stage 3 declaration with its metadata — are retained for a minimum of 6 years, consistent with the retention period Principal Firms are required to hold for their own AR oversight assessments under SUP 12.
For Principal Firm compliance teams
We hold this pack in the format above so it can be reviewed on its own merits before adapting it into your own template. If your firm has a standard Consumer Duty / AR oversight format you'd rather we complete instead, we'd rather do that than have you re-map this one — get in touch via /contact and we'll send the underlying MI this pack draws on.