Risk Warning: Don't invest unless you're prepared to lose money. This is a high-risk investment. You may not be able to access your money easily and are unlikely to be protected if something goes wrong. Take 2 minutes to learn more.
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Lending to property companies and property developers can be very rewarding, but it involves a number of risks which mean that investors may not get back what they put in.
Protecting investors’ money is our number one priority. It is our responsibility to address each of the risks involved to mitigate their effect in the best ways possible. As a precaution, we recommend that our investors do not lend more money than they can afford to lose without altering their standard of living. For added security, we also recommend that our investors diversify their investments by lending to a range of different projects.
Underpinning our whole approach to risk mitigation is the CrowdProperty Shield, an industry-leading three-tiered system, which protects investors’ funds and benefits borrowers too. The three tiers are:
Ensures we only launch the most lucrative, secure and profitable projects on our platform.
This ultimate level of legal security gives us the safest fall-back position on all projects
Our hands-on experts oversee and ensure the success of all projects
These three tiers of security work to reduce each of the risks of lending to property developments as shown below:
As part of our operational and regulatory requirements as well as our dedication to openness and transparency, as evidenced by our third party data verification by Brismo and membership of the P2PFA, we have elected to publish our Wind Down Plan detailing what would happen in the unlikely event of the failure of CrowdProperty as a business.
This Wind Down Plan is a living document and will be updated periodically as part of CrowdProperty’s dedication to acting in the best interest of lenders and borrowers. This document, and associated financial planning has been reviewed by our Backup Service Provider, Smith and Williamson.
Property prices can go up and down as a result of a wide range of economic factors on a national, regional and local level. Different property types may be more or less susceptible to reduced or negative growth.
It is the mainstay of our business, however, that we understand the factors affecting property value fluctuations, so that we can identify properties that are the most secure investments.
For every investment opportunity, our in-house property experts assess the property’s full details. We assess the desirability of the local area in terms of inward investment, business growth and employment; good transport links and local facilities and amenities. All these changing factors affect a property’s initial and final value.
We also commission an independent ‘red book valuation’ of each specific property by a member of the Royal Institution of Chartered Surveyors (RICS) – the world’s leading professional body for standards in property and construction - to confirm the specific project values for loan security purposes. Every property is different.
Based on the existing and projected final value of a property project our experts calculate what Loan To Value (LTV) finance ratio we will agree. This calculation is a fundamental part of how we protect investors’ funds, whilst also supporting borrowers by understanding the full potential of their projects.
The LTV figure is a measure of how much of a buffer the developer has to mitigate any adverse events, such as a property price decrease. Our loans will not exceed 70% LTV {including rolled up interest}, this provides a buffer for the developer to weather any adverse events.
For some larger loans we may phase the loan, if this is the case it is clearly marked on the project that it will be a multi-phase loan. We use LTV as it is the most relevant metric of the type of loan we provide. The LTV will be calculated for each phase of a project.
We also use Profit on Cost and Loan to Cost in analysing all deals.
There are several factors that may result in a borrower defaulting on their loan repayments and so jeopardising investors’ returns. To mitigate this risk we undertake rigorous due diligence. This is to ensure that the loan agreement is affordable for the borrower, as a default is not in the interests of our investors or the platform.
Rigorous Due Diligence
We work closely with each developer that approaches us for a property-project loan to confirm their identity through a process of Know Your Client (KYC) checks and we establish their integrity through Anti Money Laundering (AML) searches.
We scrutinise the viability of their proposition from every perspective: We evaluate whether each borrower’s loan-repayment schedule is realistic and their exit strategy (sale of the developed property or refinance), to ensure the most profitable and secure route of action is followed. We employ lawyers for every loan that we provide, who work with the borrower’s legal adviser.
Loan calculation
We use several metrics to determine how much a borrower can receive through our platform. Firstly we run through the borrowers financial plan, examining the projected costs of a project, the purchase price and gain a RICS survey and valuation. From this we understand the estimated profit the developer will make. See here how we calculate Loan to Value or Loan to Cost on projects.
To qualify for a maximum of 70% LTV, based on the purchase price, a project must at least, have planning consent in place and meet our 25% profit on cost model.
For the initial phase of a project (often the purchase price and initial work) we calculate Loan To Value (LTV) in the following way:
We include the total interest on a loan in the LTV calculation to give our lenders the most accurate picture of the project financial plan. The total interest is calculated on the maximum loan term as set out for each loan agreement, with a minimum loan term of 6 months. The Purchase Price always comes from the RICS valuation as part of our due diligence process. For projects that require subsequent tranches of payment, we monitor progress of the project through an Independent monitoring surveyor and at the right stages the developer can draw down further payments.
Otherwise, in cases where projected profit is less than 25%, the maximum to be lent is calculated via Loan to Cost (LTC):
In some instances we will provide 100% of the development finance, provided that we hit 25% profit on costs, including finance costs. Otherwise we reduce our development funding on a LTC/LTV calculation, but it must not be more than 70% LTV, including rolled up interest.
For some projects we will quote two figures for LTV in the details section. The highest LTV will generally be at the start of a project and we structure payments to reduce the risk profile over a project. The LTV will generally be lowest once the project is completed, due to value being added throughout a project and a stable market will reduce the overall LTV risk.
First Legal Charge
We take out first legal charge on all the properties we list for investment so that, in the unlikely event that the borrower defaults on their repayments, we can take charge of the project and recover investors’ money. Unlike many other marketplace property lending companies, we have in-house, hands-on property expertise to enable us to do this. We would look at each case on its own merits; how advanced the project is, how much money is left in the project account; market conditions, etc. We are able to dictate the way forward to ensure any losses and delays are mitigated, This means that we do not have to sell immediately, but we hold the option to manage all aspects of the project ourselves until completion, with the aim of returning all capital and interest.
Any surplus to the initial loan amount recovered from the sale of property at the completion of a project would be used to service the forecast interest payments for the lenders. In such events, CrowdProperty will write to the lenders through the platform and via email as appropriate.
Extensions
If a borrower needs an extension of further advances on the loan, we carefully assess the issues before agreeing to an extension. This is sometimes necessary due to factors beyond their control – for instance delays with planning permission or hold-ups with the final sale of the finished property. Generally, in the event that a project overruns, the borrower will pay a higher interest rate from the original due date up until the loan is settled. The additional interest will be paid along with the original capital and pre-agreed interest at the completion of the extended loan.
We monitor the progress of the project constantly, until its successful completion and the loan is repaid.
Although our robust due diligence does not completely remove the risk inherent in property investment, our track record indicates that it has a major impact on securing investors’ funds.
Marketplace platforms are not covered by the FSCS. In principle, if a platform were to fail, or become insolvent, their investors could lose all of the money they have pledged.
However, lending companies which are regulated by the Financial Conduct Authority, like CrowdProperty, are required to protect investors’ money in several ways if the platform were to fail:
Investors funds that have not been lent to borrowers are held in a Modulr FS E-Money Account, which is a segregated Santander Safeguarded client account. These funds are ring-fenced and are held on trust for investors in accordance with the FCA’s Client Money Rules. These funds are completely separate from CrowdProperty’s own money and we cannot use client money for our own business purposes. These funds do not form part of our assets, which means that they would not be available to creditors in the event of our insolvency.
As an FCA regulated lender we have a back-up servicing arrangement in place. This means that in the unlikely event that CrowdProperty ceases to trade, the back-up service provider would take our place in operationally managing and administering existing loan contracts between investors and borrowers. It would continue to receive loan repayments from borrowers, and to process and distribute these payments to investors. In practice, this means that if our platform does fail, all of investors’ existing loans would be unaffected.
The first legal charge that we take out on all property projects on your behalf, would still stand, if CrowdProperty became insolvent. This would continue to safeguard investors’ money, so that if the project developer was to default on repayments, the back-up service provider would operate on investors’ behalf and take over the project to extract and pay back investors’ funds in the best way possible.
Our current back-up service provider is also authorised by HMRC as an ISA Manager, and would be able to take over the administration of CrowdProperty IFISA accounts. This means loans held within a CrowdProperty IFISA would keep their tax-free benefits.
All FCA regulated marketplace lending platforms are required to hold capital reserves (extra cash) to help mitigate any business and financial risks. This is something we have always done.
Any investment you make through the platform will be highly illiquid – you will not be able to withdraw your money before the end of the investment term. This is because there is no active secondary market for loans to investee property development companies. The only way you can release your money is if the investee company is sold or, at the end of the investment term when the property is sold or refinanced, with a different loan being concluded.
You will be responsible for the payment of your own tax, which, as a borrower selling a property project, may include capital gains tax, and, as an investor the interest you receive may be liable to income tax. Individual circumstances will be different and we do not provide tax advice and you should seek independent tax advice before investing if you are unsure of your position. It is still your responsibility to ensure that your tax return is correct and is filed by the deadline and any tax owned is paid on time. If you are unsure how this investment will affect your tax status you must seek professional advice before you invest.
Past performance is no indicator of future performance and we make all our judgements on a project-by-project basis. The internal calculations and opinions of CrowdProperty are subject to change at any time.
We have comprehensive insurance policies in place that are tailored to our business, these cover fraud and crime, terrorism, and contingent buildings insurance for our loans. Should a loss be suffered on a loan as a result of fraud or crime we will, where possible, seek to claim on the insurance policies in an effort to return any shortfall to investors.
CrowdProperty do not offer any advice to lenders or borrowers. We recommend that if you are not sure about anything you should seek independent third-party advice. We recommend that you do your own due diligence on any project before you decide if you want to invest.
Central to our business model at CrowdProperty is our technology platform, which is designed and supported in-house by our technical experts. This provides us with the flexibility and nimbleness to continually improve the services for both Lenders and Borrowers. We have integration into Goji and Modulr to give our Customers the best experience possible. We are also confirmed as an IFISA provider by HMRC.
1.1. In this Privacy Policy, the following terms shall have the meanings set out below:
1. 1. 1. "Applicable Law" means any laws or regulations, regulatory policies, guidelines or industry codes (whether national or international) which apply to Company (or any of its Sub-Processors) and/or the provision of or the subject matter of the Services in each case as in force from time to time;
1. 1. 2. "Company" means CrowdProperty Ltd
1. 1. 3. "Customer Group Member" means a Customer or any entity that owns or controls, is owned or controlled by or is or under common control or ownership with Customer where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise;
1. 1. 4. "Customer Personal Data"means any Personal Data Processed by Company on behalf of a Customer Group Member pursuant to or in connection with the Principal Agreement;
1. 1. 5. "Data Protection Laws" means EU Data Protection Laws and, to the extent applicable, the data protection or privacy laws of any other country;
1. 1. 6. "EEA" means the European Economic Area;
1. 1. 7. "EU Data Protection Laws" means EU Directive 95/46/EC, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR;
1. 1. 8. "GDPR" means EU General Data Protection Regulation 2016/679;
1. 1. 9. “Personal Data” means any data that relates to an identified or identifiable natural person and where such data is protected under applicable Data Protection Laws;
1. 1. 10. “Principal Agreement” means the agreement or agreements between Company and the Customer Group Member for the Services Company is providing them.
1. 1. 11. "Service/s" means the services and other activities to be supplied to or carried out by or on behalf of Company for Customer Group Members pursuant to the Principal Agreement;
1. 1. 12. "Sub-processor/s" means any person (including any third party and any Company Affiliate) appointed by or on behalf of Company or any Company Affiliate and that Processes Customer Personal Data on behalf of any Customer Group Member; and
1. 1. 13. Company Affiliate/s" means an entity that owns or controls, is owned or controlled by or is or under common control or ownership with Company, where control is defined as the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise.
1.2. The terms, "Commission", "Controller", "Processor", "Data Subject/s", "Member State", "Personal Data Breach", "Processing" and ,"Supervisory Authority" shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.
Company warrants and represents that, before any Company Affiliate Processes any Customer Personal Data on behalf of any Customer Group Member, Company entry into this Privacy Policy as agent for and on behalf of that Company Affiliate will have been duly and effectively authorized (or subsequently ratified) by that Company Affiliate. References to ‘Company’ shall be deemed to include a reference to each Company Affiliate as applicable.
3.1 Scope of this Privacy Policy and Role of Parties. This Privacy Policy applies to the Processing of Personal Data by Company in the course of providing the Services. For the Purposes of the Services and this Privacy Policy, Customer and each Customer Group Member are the Controller(s) and Company is the Processor and shall be Processing Personal Data on the Customer’s behalf, the Customer receiving the Services as principal and as agent of each Customer Group Member.
3.2 Instructions for Processing Personal Data. Company shall Process Personal Data as reasonably necessary for the provision of the Services arising from the Principal Agreement (inclusive of this Privacy Policy) and in accordance with Customer’s documented instructions which, unless expressly agreed otherwise, shall at all times be consistent and in accordance with the nature of the Principal Agreement. Company may terminate the Principal Agreement if Customer provides instructions to Process Personal Data which are inconsistent with the Principal Agreement, or which Company could not comply with without (i) incurring material additional costs or (ii) undertaking material variations to the manner in which the Services are provided which variations Company does not propose to introduce in respect of the majority of its other customers. Company may Process Personal Data otherwise than in accordance with Customer's instructions if required to so by Applicable Law. In such case Company shall inform Customer of that legal requirement, unless prohibited from doing so by Applicable Law.
3.3 Compliance with Laws. Company, in Processing the Customer Personal Data in accordance with Clause 3.2 above, shall comply with all applicable Data Protection Laws. Company shall not be responsible for complying with Data Protection Laws applicable to Customer Group Member or its industry that are not otherwise consistent with the provision of the Services or if, and to the extent that, the relevant provision of Data Protection Law would not also apply to Company provision of services equivalent to the Services to other customers. Customer shall comply with all Data Protection Laws applicable to Customer as Controller.
4.1. Personnel Reliability. Company shall take reasonable steps to (i) require background screening and to ensure the reliability of any personnel who may have access to the Customer Personal Data or the Customer environments in which the Personal Data is processed, ensuring in each case that access is strictly limited to those individuals who need to know / access the relevant Customer Personal Data, as strictly necessary for the purposes of the Principal Agreement; and (ii) ensuring that any personnel are informed of the confidential nature of Personal Data, have received training, and are subject to confidentiality obligations or professional or statutory obligations of confidentiality.
4.2. Data Protection Officer. Company have appointed a data protection officer. The appointed person may be reached at dpo@crowdproperty.com.
5.1. Appointment of Sub-processors. Subject always to section 3.2 above, each Customer authorizes Company to appoint Sub-processors in accordance with this section 5 to Process Customer Personal Data. Company shall be responsible for ensuring that each Sub-process or has entered into a written agreement requiring the Sub-process or to comply with terms no less protective than those provided in this Privacy Policy (a summary of such terms will be made available to Customer on request). Company shall be liable for the acts and omissions of any Sub-process or to the same extent as if the acts and omissions were performed by Company. Sub-processors may process such data within the EU or outside the EU.
5.2. Notification of New Sub-processors. Company may continue to use those Sub-processors already engaged by Company or any Company Affiliate as at the date of this Privacy Policy. Company shall make available to Customer through Company customer website a list of Sub-processors authorized to Process Customer Personal Data (“Sub-processor List”) and provide Customer with a mechanism to obtain notice of any updates to the Sub-processor List (“Sub-processor Notice”). At least thirty (30) days prior to authorising any new Sub-processor to Process Personal Data, Company shall provide notice by updating the Sub-processor List.
5.3. Sub-processor Objection Right. This section 5.3 shall apply only where and to the extent that Customer is established within the EEA or where otherwise required by Data Protection Laws applicable to the Customer. In such an event, If Customer notifies Company in writing of any objections (on reasonable grounds) to a Sub-processor added to the Sub-processor List within fourteen (14) days after the date of the applicable Sub-processor Notice:
5. 3. 1. Company shall work with Customer in good faith to make available a commercially reasonable change in the provision of the Services which avoids the use of that Proposed Sub-processor; and
5. 3. 2. where such a change cannot be made and Company choose to retain the Sub-processor, Company shall notify Customer at least fourteen (14) days prior to the authorisation of the Sub-processor to Process Personal Data and the Customer may discontinue using the relevant services and terminate the relevant portion of the Services which require the use of the Proposed Sub-processor immediately upon written notice to Company, such notice to be given by Customer within thirty(30) days of having been so notified by Company.
6.1. Requests from Data Subjects. Customer acknowledges, as part of the Services, it is responsible for responding to any Data Subjects’ request under any Data Protection Law to exercise the Data Subject’s right of access, right of rectification, restriction of Processing, right to be forgotten, data portability, object to processing, or its right not to be subjected to an automated decision-making process (“Data Subject Request”). Company shall:
6. 1. 1. to the extent permitted by Applicable Law, promptly notify Customer if it receives a Data Subject Request from a Data Subject; and
6. 1. 2. to the extent permitted by Applicable Law, promptly notify Customer if it receives a Data Subject Request from a Data Subject; and
6.2 Government and Law Enforcement Authority Requests. Unless prohibited by Applicable Law or a legally-binding request of law enforcement, Company shall promptly notify Customer of any request by government agency or law enforcement authority for access to or seizure of Personal Data.
7.1. Breach notice. Company shall notify Customer within 24 hours upon Company becoming aware of a confirmed Personal Data Breach affecting Customer Personal Data. To the extent able within the scope of the Services, Company will provide Customer with sufficient information to allow it to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
7.2. Investigatory Cooperation. Company shall co-operate with Customer and take such reasonable commercial steps as are directed by Customer to assist in the investigation, mitigation and remediation of each such Personal Data Breach.
8.1. Technical and organisational measures. Company shall implement and maintain appropriate technical and organisational measures designed to protect the security, confidentiality and integrity of Customer Personal Data, including to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, such Personal Data as set forth in Schedule A. Company regularly monitors compliance with these measures. Company reserves the right to update its technical and organisational measures and will not materially decrease the overall security of the Services pursuant to the Principal Agreement.
8.2. Audit. Customer agrees that Company then-current attestation of compliance (“AOC”) as applicable to the Services, will be used to satisfy any audit or inspection requests by or on behalf of the Customer, including any Customer Group Member arising from this Privacy Policy, and at the Customer’s written request, a copy of such AOC shall be provided to the Customer by Company. In the event that Customer, any Customer Group Member, a regulator, or Supervisory Authority requires additional information, including information necessary to demonstrate compliance with this Privacy Policy, Company will provide commercially reasonable cooperation to make such information available.
8.3. Customer Applications. Customer acknowledges that if at any time it installs, uses or enables products or applications that operate using the Services, but are not part of the Service itself, then by such action Customer is instructing Company to cause the Service to allow such products or applications to operate and potentially access Personal Data. Accordingly, this Privacy Policy does not apply to the processing of Personal Data by such products or applications.
8.4. Return and Deletion of Personal Data. Upon termination of the Services, Company shall at Customer's option, return and/or delete any Personal Data retained on the Services in accordance with the terms of the Principal Agreement and not retain any copies unless Company is required to do so by Applicable Law.
Personal Data may be stored at various data centre premises as part of the Services (the “Designated Data Centre Location”).
10.1. Without prejudice to any Mediation and Jurisdiction and Governing Law of any other agreement between the parties, or the applicability of any Data Protection Laws:
10. 1. 1. the parties to this Privacy Policy hereby submit to the choice of jurisdiction stipulated in the Principal Agreement with respect to any disputes or claims howsoever arising under this Privacy Policy, including disputes regarding its existence, validity or termination or the consequences of its nullity; and
10. 1. 2. the obligations of Company and Company Affiliates arising hereunder are subject to and governed by the laws of the country or territory expressly set forth in the Principal Agreement.
10.2. With regard to the subject matter of this Privacy Policy, in the event of inconsistencies between the provisions of this Privacy Policy and any other agreements between the parties, including the Principal Agreement and including (except where explicitly agreed otherwise in writing, signed on behalf of the parties) agreements entered into or purported to be entered into after the date of this Privacy Policy, the provisions of this Privacy Policy shall prevail.
10.3. Customer is responsible for coordinating all communication with Company on behalf of its Customer Group Members with regard to this Privacy Policy. Customer represents that, in relation to this Privacy Policy, it, as agent for its Customer Group Members (where applicable),is authorized to issue instructions; make and receive any communications or notifications; and enter into any agreement expressly contemplated herein for and on behalf of any of its Customer Group Members.
10.4. Customer and/or its Customer Group Members may only disclose the terms of this Privacy Policy to a Supervisory Authority to the extent required by law or such Supervisory Authority. Customer shall reasonably ensure that the Supervisory Authority does not disclose the terms of this Privacy Policy to the public or any third party, including :(i) marking copies of this Privacy Policy as "Confidential and Commercially Sensitive”;(ii) requesting return of copies of this Privacy Policy once the governmental regulatory notification has been completed or approval granted; and (iii) requesting prior notice and consultation before any disclosure of this Privacy Policy by the Supervisory Authority.
10.5. The Company and/or Company Affiliates’ aggregate liability to the Customer and/or any Customer Group Member arising from a breach of this Privacy Policy (including the Standard Contractual Clauses) shall be subject to the terms of the Principal Agreement.
In addition to the terms set out in Part A above, the terms set out in this Part B shall apply to the Processing of Personal Data by Company on behalf of a Customer established in the European Union or otherwise subject to the requirements of the GDPR.
11.1 General Data Protection Regulation. With effect from 25 May 2018, Company will Process any Personal Data in accordance with the requirements of GDPR as directly applicable to Company provision of the Services.
11.2 Subject Matter, Nature, Purpose and Duration of Data Processing. Company will Process Customer Personal Data to provide the Services. The duration of the Processing of Personal Data shall be for the term of the Principal Agreement.
11.3 Types of Personal Data and Categories of Data Subjects. The types of Personal Data and categories of Personal Data shall be those determined by the Customer being the Customer Personal Data which, along with the categories of Data Subjects, may be more particularly described in the Principal Agreement.
11.4 Data Protection Impact Assessment and Prior Consultation. The Customer for itself and on behalf of each Customer Group Member (where applicable) agrees that Company then-current standard policies & documented information about the Services, will be used to carry out Customer’s data protection impact assessments and prior consultations, and Company shall make such information available to the Customer where requested. Company and each Company Affiliate shall provide reasonable assistance to each Customer Group Member with any data protection impact assessments, and prior consultations with Supervisory Authorities or other competent data privacy authorities, which Customer reasonably considers to be required of any Customer Group Member by article 35 or 36 of the GDPR or equivalent provisions of any other Data Protection Law, in each case solely in relation to Processing of the Customer Personal Data by, and taking into account the nature of the Processing and information available to, Company. The Customer shall ensure, to the extent that such data protection impact assessments and, where necessary, prior consultations with Supervisory Authorities, are required by Data Protection Laws, that Customer and relevant Customer Group Members take such steps as are required to implement such assessments and consultations. If, following the implementation of a data protection impact assessment or a consultation, the Customer reasonably determines that it would be a breach of Data Protection Laws to continue with the Services, Customer shall notify Company and the parties shall attempt to reach a solution. If the parties fail to agree a solution within thirty (30) days of commencing discussions, the Customer shall be entitled to terminate the Services, subject to the payment of an early termination fee determined in accordance with the Principal Agreement.
11.5 Access to Personal Data. Unless otherwise agreed and notwithstanding Section 9 above, in order to provide the Services Company and its Sub-processors will only access Personal Data from (i) countries in the EEA, (ii) countries or territories formally recognized by the European Commission as providing an adequate level of data protection (“Adequate Countries”) and (iii) the United States provided, in this case, that Company makes available to the Customer a Valid Transfer Mechanism in accordance with Section 11.6 below. When Company or its Sub-processors access Personal Data from outside the Designated Data Centre Location for the purposes of providing the Services, the Customer agrees that such Personal Data may be transferred accordingly.
11.6 Transfers Required by Applicable Law. Notwithstanding the foregoing, Company shall be entitled to access Personal Data from, or transfer Personal Data to, territories outside the EEA other than in the circumstances specified in clause11.6 if required to do so by Applicable Law. Unless prohibited by Applicable Law, Company shall not transfer any Personal Data outside of the European Economic Area unless the prior written consent of the Customer has been obtained and the following conditions are fulfilled:
What is Treating Customers Fairly (TCF):
All regulated firms must “pay due regard to the interests of its customers and must treat them fairly”.
At CrowdProperty this is at the heart of what we do, not just because it is a regulatory requirement but because it is the right thing to do. The FCA expects the interests of our clients to be at the heart of how we do business and, in particular, that our clients receive a service and products that meet their needs.
CrowdProperty is fully committed to TCF and the demonstration of this during the course of our day to day activities.
Our TCF Principles:
Implementing TCF
CrowdProperty firmly believes that its principles, business procedures and ethics fulfil the requirements of TCF. We provide clients with clear information about the products and services we offer, including fees and charges, allowing them to make an informed decision as to the services that best suit their individual needs.
We encourage clients to ask if there’s something they don’t understand and give them access to a formal complaints procedure should they become unhappy with our service.
Compliance
CrowdProperty have a compliance team who are independent from operational functions and continually monitor and assess TCF and all other areas of regulatory compliance. Our compliance team is continually evolving further demonstrating CrowdProperty’s commitment to TCF.
Management Information
Management information is provided monthly to the Board covering trends and themes. Current and historic data is also provided monthly to the Board for review.
Ownership and Governance
The Board of Directors has ownership and governance of this policy and reviews it annually.
