Loans for people with low income

Responsible Broking Policy

Last updated: June 2026

As a credit broker, 1st‑Loan is committed to acting responsibly, transparently and in the best interests of customers. This policy explains how we ensure that our broking activities support good customer outcomes and comply with FCA requirements.

1. Purpose of this policy

The purpose of this policy is to set out how we conduct our broking activities responsibly, ensuring that customers receive clear information, fair treatment and access to suitable finance options. It applies to all staff and all customer interactions.

2. Our role as a credit broker

1st‑Loan is a credit broker, not a lender. We introduce customers to lenders and finance providers who may be able to offer commercial finance products. We do not provide financial advice or recommend specific products.

3. Regulatory framework

Our broking activities comply with:

  • FCA Consumer Duty (PRIN 12)
  • FCA CONC – Consumer Credit Sourcebook
  • FCA FG22/5 – Guidance on the Consumer Duty
  • FCA FG21/1 – Vulnerable Customers
  • TCF (Treating Customers Fairly) principles
  • UK GDPR and data protection requirements

4. Acting in the customer’s best interests

We act in good faith, avoid causing foreseeable harm and support customers in making informed decisions. This includes:

  • Providing clear, fair and not misleading information
  • Ensuring customers understand the nature of our service
  • Explaining that finance is subject to status and lender criteria
  • Avoiding any pressure‑selling or unfair influence

5. Understanding customer needs

We gather sufficient information to understand the customer’s requirements and circumstances. This helps us introduce them to lenders whose products may be suitable for their needs.

6. Affordability and suitability

While lenders are responsible for affordability assessments, we support responsible lending by:

  • Providing accurate information to lenders
  • Highlighting any concerns about affordability or customer vulnerability
  • Ensuring customers understand key product features and risks

7. Vulnerable customers

We recognise that some customers may be vulnerable due to personal circumstances. We take extra care to ensure they receive appropriate support, including:

  • Communicating clearly and at an appropriate pace
  • Checking understanding throughout the process
  • Offering alternative communication methods where needed
  • Escalating concerns to senior staff where appropriate

8. Transparency and disclosure

We provide clear information about:

  • Our role as a credit broker
  • How we are paid, including commission disclosure
  • Any limitations in the range of lenders we work with
  • Key risks associated with finance products

9. Conflicts of interest

We identify and manage any potential conflicts of interest to ensure they do not negatively impact customers. Staff must disclose any potential conflicts immediately.

10. Staff competence and training

Staff involved in broking activities receive regular training on FCA rules, Consumer Duty, vulnerable customer support and best practice in customer communications.

11. Monitoring and quality assurance

We monitor customer interactions, lender feedback and customer outcomes to ensure our broking activities remain compliant and effective. Any issues identified are addressed promptly.

12. Complaints and feedback

Complaints are handled in line with our Complaints Policy. We use complaint data to identify areas for improvement and prevent future issues.

13. Continuous improvement

We regularly review this policy and our broking processes to ensure they remain aligned with regulatory expectations and deliver good customer outcomes.