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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.

Submission details

1

Organisation details

Enter the information identified through public sources.

Legal entity name
Trading name
Companies House number
FCA Firm Reference Number (if applicable)
ICO registration (if applicable)
Registered office
Website
Business activity / products or services
Trading history
Ownership / group structure

Name, role, email and telephone.

2

Regulatory status and customer type

Is the regulated, registered or exempt entity the same legal entity applying to become an NACFB Patron or Partner?
Are you registered under Annex 1 of the Money Laundering Regulations, where applicable?

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

Sole traders
Partnerships of two or three individuals
Unincorporated bodies of persons (not entirely bodies corporate, not partnerships)
3

Policies and governance

Confirm policy, last review date and availability on request.

Consumer Duty Policy
Complaints Handling / TCF Policy
Vulnerable Customer Policy
Financial Promotions Policy
Responsible Lending Policy
Credit Risk Policy
Arrears, Collections & Recovery Policy
AML & Financial Crime Policy
Fraud Policy
Data Protection Policy
Operational Resilience / BCP
Training & Competence Policy
Conflicts of Interest Policy
SMCR Policy
Risk Management Policy

Name, role, email and telephone.

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

Products, funding and customer outcomes

Is the NACFB's understanding of your products, services and target customers accurate?

Do you offer any of the following products?

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

Broker relationships, commission and conduct

Can broker commission affect the customer's cost of borrowing?
Is broker commission disclosed to customers, including where it may affect the cost of borrowing or the broker's recommendation?

Do you pay or provide any of the following?

Volume bonuses
Profit share
Enhanced commission
Retrospective commission
Marketing allowances
Introducer incentives
Non-cash incentives
Do you have a policy or standard approach for dealing with future business from broker-introduced customers?
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?
6

Complaints, arrears and financial crime

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

Reputation and disclosure

Are you aware of any matter that could create reputational risk for the NACFB if your organisation became a Patron?
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?
Are there any matters not already disclosed that could reasonably affect the NACFB's decision to approve your organisation as a Patron or Partner?
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
Notify the NACFB before launching any materially different product, repayment model, commission structure or customer segment
Provide updated information annually or on request
Provide copies of selected policies or evidence if requested
Participate in further due diligence discussions if required
Comply with NACFB expectations around conduct, transparency, broker relationships and customer outcomes
Accept approval subject to conditions, improvement actions or enhanced monitoring, where required
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.