Calling all companies that offer hot key from UK Call centres

[Blue fin]

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Please contact me direct regarding a unique partner opportunity with Blue Financial

[Blue fin]

Interesting website, Blue Financial. Non FSA member collecting full mortgage and remortgage applications online, and where the applicant is not told who will be contacting them once the application is submitted.

In fact, interesting is the wrong word. What I should have said was ILLEGAL.

Interesting logos in the top right hand corner too...

Dear Michael,

You know sometimes I read your comments and chuckle away and other times I feel you can come across in a completely unprofessional manner and this is no exception! Nice try

You glibly pass comment on my business and cast aspersions on our conduct in the market without knowing anything about who we are or what we do.

I find the fact you call us illegal somewhat comical when we are clearly promoted as an independent marketing site operated for and on behalf of one the UK’s largest broker networks who, and for your information, are directly authorised.

Equally trying to play up your position to play down the competition is not credible and highly unprofessional in this type of forum, especially when I hear your own house is not in order.

An just for your information perhaps you've filled one of applications now i know where my budget is going! You would have received our responder assigning a broker local to you that clearly stats their contact info!

[angiet]

That is a cheap shot Mick.

Coming from someone who only recently thought it appropriate to consider the legal requirements of the services that you offer.

If you are so good at what you do then why are you so late to come to the compliance table ?

How long has AMS been fully compliant with the appropriate rules for the services you supposedly offer ?

Angiet.
TeakTalk.

[tonyhessey]

Agree,

Michael Anthony spends all day slagging off the competition, is this to mask the failings of AMS? Or to make other suppliers look so bad that he can then look good?

Signs of a bad salesman/product when you have to slag off others to make yours look good.

Michael you should stop talking and let your products/customers do the talking for you, if you are as good as you say then you don't need to be slagging off everyone you don't like the look of or understand,

And if you are so big/popular/the best how the hell do you find the time to post so many replies? Or is this why I see so many people saying they haven't heard back from AMS? Because your too busy on here giving your unwanted opinion!

[Andrew Copeland]

Hi all,

Just to clear the air a little I decided to call the FSA a couple of minutes ago to get a ruling on the matter...as I'm pretty sure its a bit more complicated than everyone first thinks.

As we all thought, the Blue Financial website and business model is perfectly legal!! According to the FSA, registration with them is only required if the company concerned plans to evaluate the leads and select a broker/lender based on the data provided by the customer. This is deemed to be providing financial advice...obviously needing regulation.

As Blue Financial simply pass the lead to their brokerage network...NOTE: no evaluation is done...they are not giving financial advice and therefore only have to ensure that they are sending the lead on to professionals who are regulated...which Blue Financial are very strict about doing.

And because there is no regulation needed, Blue Financial does not need to inform the end user about which brokers/lenders their enquiry will be referred to.

So crisis over I think....Blue Financial are above board and, judging by this months figures, look to be a fantastic program to promote both in the run up to Christmas and in the January finance rush.

[anshul123]

I guess what matters more to Affiliates is their market reputation in regard with timely payments and affiliate support..

[steve333]

Hi Bluefin,

Listen mate, do not let Mr A annoy you and I agree with the other comments. If he was so busy, why all the posting times.

I think he is a bit of a Dr Jekyll and Mr Hyde, so from now on when he is nice we should call him Dr Michael and when he is not so nice we should call him Mr Tony !

Happy to deal with your company anytime in the future.

Best regards,

Steve333
L2U.

[Michael_Anthony]

How long has AMS been fully compliant with the appropriate rules for the services you supposedly offer ?

Since day one

We too are in regular communication with the FSA, as we too have a duty to ensure compliance across our network.

As my colleagues at Leadbay will no doubt confirm, the FSA themselves cannot and will not tell you whether or not your site is compliant, and instead suggest that you contact a specialist company whose function it is to advise and recommend compliant solutions. To their credit, Leadbay are the only network who have taken this commendable and no doubt expensive step, as their main business is in first charges (mortgage and remortgage) where these regulations are highly relevant.

If I buy data from a decline or PrimeQ survey type operation, then call these customers myself to flesh out the required details and then sell this data to someone like Blue Financial, am I operating in a legally compliant manner? What if I just trawl the phone book? Or send out mailshots?

I don't actually know the answer to this question, and would be genuinely interested in an informed response from someone with the necessary expertise and credibility.

Please understand that I'm not after an argument here, nor is it my intention to bash any competitors, just a real understanding of how all this hot key business works.

If my comments above have upset anyone at Webgains and/or Blue Financial, please accept my sincere personal aplogies - perhaps it's ME that doesn't understand the rules?

[Blue fin]

If I buy data from a decline or PrimeQ survey type operation, then call these customers myself to flesh out the required details and then sell this data to someone like Blue Financial,

Just to correct your pointless response:

Blue Financial would not use your services.
We have no affiliation, relationship or dealings with your company what so ever!

[Andrew Copeland]

Don't worry about the earlier post, thats all in the past . Lets get back to the matter of the FSA stuff.

If I buy data from a decline or PrimeQ survey type operation, then call these customers myself to flesh out the required details and then sell this data to someone like Blue Financial, am I operating in a legally compliant manner? What if I just trawl the phone book? Or send out mailshots?

Depends on whether you have evaluated the data and selected company X based on the info you received from the customer. If you did...then you're acting illegally as you have effectively offered the user financial advice by evaluating their case and you're not FSA regulated.

Basically, the rule of thumb is this (if I understand correctly), if you're not FSA regulated then you can't make any judgements on where to send a specific lead and have to pass it on to someone who is regulated (you don't have to tell the customer who you've sent the info to). If you are regulated, you can evaluate a lead based on the circumstances of the applicant and then refer where you think is best...however you have to tell the user who you will be passing their data onto.

Thats how it got explained to me by the woman at the FSA earlier but if anyone has any other info...please let us know

[russell cpanuk]

I understand what you say under the FSA rules; you only have to be registered with them if you give advice. FSA cover Mortgage and re-mortgage products, but that is only one governing body, and the finance industry has many.

I am no expert on this matter, but I think the Advertising Standards and the OFT would have something to say if an applicant is not told which company they have applied too.
I think what I am trying to say is that the FSA rules only apply to a small percentage of products within the industry. The OFT and AS cover all products, and their rules have to be adhered to also.(on-line and off-line)

So, from what I can understand from reading this thread is, an applicant can make an application, not know which company he will end up at, and thats OK with the OFT and AS because the FSA say so.

[Andrew Copeland]

So, from what I can understand from reading this thread is, an applicant can make an application, not know which company he will end up at, and thats OK with the OFT and AS because the FSA say so.

Nope, I was only talking FSA regulations as those are the one's called into question. There are loads of other regulators...not to mention legislation like the DPA which would have some sort of bearing here. (is it possible to overdose on red tape? )

My discussion with the FSA was simply about their regulations.

From what I gather, each regulator will evaluate a situation only as it applies to their rules. But his thread could get very long and very complicated if we looked at every influencing agency, ruling etc

[russell cpanuk]

So what we can understand here, is that not informing the applicant who their application will be sent to, is not breaking the FSA rules, however could fall foul, under other regulations. Correct?

[Andrew Copeland]

something like that...if you're not regulated you don't have to tell the user where their data goes simply because the FSA has no say in what you do as it is unregulated activity.

However, its quite possible that this could be breaking the rules of some more general regulator or legislation.

[Blue fin]

As mentioned above and to play it safe within what can only be described as a grey area i.e. "financial lead gen' sites" the FSA requires:

Financial sites that interface with the public for the purpose of searching for or obtaining financial based products must be fair and not misleading, carry the correct wealth and risk warnings and associated APR as an over all cost for comparision.

The later is particularly difficult if you supply multiple brokers in the sub and prime market as their over all APR's will seem like worlds apart. The answer is simple if your site like ours is geared purley towards adverse you'll need to ask your main account for their overal cost for comparison.

Finally the site must be registered under the DPA and ensure that the applicant is aware the the information recorded will be passed to a third party that is regulated either directly or indirectly by the FSA (such as an AR)

The FSA will then require you as the lead gen company to notify the applicant of exactly who will be contacting them and how they will be contacted.

I hope this helps answer a few questions that have been raised but do bear in mind this is not gospel or full an final on what the FSA deem wright or wrong! It is based purely on the research from own compliance team.