NACFB · Helping fund UK business

Patron Due Diligence

Confirmation Form

Stage 1 — NACFB pre-completion. Enter the findings identified through your initial due diligence review, then generate a secure link to send to the customer for confirmation.

NACFB instructions: Fill in the basic submission details and the findings in Section 1. Customer-only fields are disabled and will be enabled when the customer opens their link.

NACFB

1

Organisation details

Enter the information identified through public sources.

Legal entity name
NACFB finding
Confirmed correct?
Comments / corrections
Trading name
NACFB finding
Confirmed correct?
Comments / corrections
Companies House number
NACFB finding
Confirmed correct?
Comments / corrections
FCA Firm Reference Number (if applicable)
NACFB finding
Confirmed correct?
Comments / corrections
ICO registration (if applicable)
NACFB finding
Confirmed correct?
Comments / corrections
Registered office
NACFB finding
Confirmed correct?
Comments / corrections
Trading address
NACFB finding
Confirmed correct?
Comments / corrections
Website
NACFB finding
Confirmed correct?
Comments / corrections
Number of years trading
NACFB finding
Confirmed correct?
Comments / corrections
Ultimate beneficial owner
NACFB finding
Confirmed correct?
Comments / corrections

Name, role, email and telephone.

2

Regulatory status and customer type

Are you registered under Annex 1 of the Money Laundering Regulations, where applicable?
Response
Comments

Do you underwrite business for any of the following customer types?

Sole traders
Response
Comments
Partnerships of two or three individuals
Response
Comments
Unincorporated bodies of persons
Response
Comments
3

Policies and governance

Confirm policy, last review date and availability on request.

Consumer Duty Policy
In place?
Date last reviewed
Available on request?
Comments
Complaints Handling / TCF Policy
In place?
Date last reviewed
Available on request?
Comments
Vulnerable Customer Policy
In place?
Date last reviewed
Available on request?
Comments
Financial Promotions Policy
In place?
Date last reviewed
Available on request?
Comments
Responsible Lending Policy
In place?
Date last reviewed
Available on request?
Comments
Credit Risk Policy
In place?
Date last reviewed
Available on request?
Comments
Arrears, Collections & Recovery Policy
In place?
Date last reviewed
Available on request?
Comments
AML & Financial Crime Policy
In place?
Date last reviewed
Available on request?
Comments
Fraud Policy
In place?
Date last reviewed
Available on request?
Comments
Data Protection Policy
In place?
Date last reviewed
Available on request?
Comments
Operational Resilience / BCP
In place?
Date last reviewed
Available on request?
Comments
Training & Competence Policy
In place?
Date last reviewed
Available on request?
Comments
Conflicts of Interest Policy
In place?
Date last reviewed
Available on request?
Comments
SMCR Policy
In place?
Date last reviewed
Available on request?
Comments
Risk Management Policy
In place?
Date last reviewed
Available on request?
Comments

Name, role, email and telephone.

Do you confirm that the NACFB may request evidence to support any response provided in this form?
Response
Comments
4

Products, funding and customer outcomes

Do you offer any of the following products?

Merchant cash advance
Response
Comments
Revenue-based finance
Response
Comments
Daily or weekly repayment products
Response
Comments
Products with significant fees, charges or early settlement costs
Response
Comments
Short-term lending
Response
Comments
Unsecured lending
Response
Comments
High-cost lending
Response
Comments
Are there any material funding, ownership or group relationships that could create a conflict of interest for brokers or customers?
Response
Comments
5

Broker relationships, commission and conduct

Does the commission paid to brokers affect the cost to the customer?
Response
Comments
Is the commission arrangement disclosed to the customer?
Response
Comments

Do you offer any of the following incentives to brokers?

Volume bonuses
Response
Comments
Profit share
Response
Comments
Enhanced commission
Response
Comments
Retrospective commission
Response
Comments
Marketing allowances
Response
Comments
Introducer incentives
Response
Comments
Non-cash incentives
Response
Comments
Have you suspended, restricted or terminated any broker or introducer relationships in the last three years due to conduct, complaints, fraud, commission concerns or poor customer outcomes?
Response
Comments
6

Complaints, arrears and financial crime

Have you received any material complaints, complaint trends or upheld complaints in the last three years?
Response
Comments
Have you experienced any material arrears, collections or recoveries issues in the last three years?
Response
Comments
Have you experienced any material fraud, AML, financial crime or sanctions issues in the last three years?
Response
Comments
Have you had any reportable data breaches, cyber incidents or material operational incidents in the last three years?
Response
Comments
7

Reputation and disclosure

Are you aware of any matter that could create reputational risk for the NACFB if your organisation became a Patron?
Response
Comments
Have your organisation, directors, senior managers or group companies been subject to any material litigation, insolvency event, regulatory action, public criticism or adverse media in the last five years?
Response
Comments
Are there any matters not already disclosed that could reasonably affect the NACFB's decision to approve your organisation as a Patron or Partner?
Response
Comments
8

Ongoing obligations

Please confirm that you would be willing to meet the following ongoing obligations.

Notify the NACFB of material changes to ownership, funding, permissions, products, commission model, complaints, conduct issues, data breaches, litigation, adverse media or reputation
Response
Comments
Notify NACFB before launching any materially different product
Response
Comments
Provide updated information annually or on request
Response
Comments
Provide copies of selected policies or evidence if requested
Response
Comments
Participate in further due diligence discussions if required
Response
Comments
Comply with NACFB expectations around conduct, transparency, broker relationships and customer outcomes
Response
Comments
9

Declaration

I confirm that the information provided in this form is accurate and complete to the best of my knowledge. I confirm that this form has been reviewed and approved by an appropriate senior individual within the organisation. I understand that the NACFB may rely on this information as part of its Patron / Partner due diligence process and may undertake further checks where appropriate.

Type your full name to e-sign.