The Financial Conduct Authority

Avram Financial Services Ltd trading as Mortgage Circle is authorised and regulated by the Financial Conduct Authority (FCA). The FCA regulates financial services in the UK, and you can check our authorisation and permitted activities on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register. Our Financial Services Register number is 797652

Our Services

For Mortgages, we are independent mortgage advisers, and we will recommend a mortgage product that is suitable for you following an assessment of your personal needs and circumstances. This will include a detailed assessment of affordability.

We will consider all products and lenders that we have access to. This means we will not consider those lenders that are only available by you going direct to them.

Where you are increasing your borrowing, we will consider the merits of both a new first-charge mortgage and securing this with an additional mortgage on a second-charge basis. You may have the option of a further advance from your existing lender; however, we will only consider this where we can deal directly with the lender on your behalf.

It may be in your best interests to explore this option and look at the further alternative of an unsecured loan, as these may be more appropriate for you.

Protection

For protection, we are independent protection advisers, and we will recommend a protection product that is suitable for you following an assessment of your personal needs and circumstances. This will include a detailed assessment of affordability.

Please note that we only use Vitality for Private medical insurance.

We will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and personal analysis of your circumstances for life insurance, income protection, critical illness, and private medical insurance.

Please note we do not charge a fee for protection or general insurance products as we will receive a commission from the provider/insurer after the policy has been placed on risk.

Building and general insurance

Please note for building and general insurance we are whole of market. We will assess your needs and provide you with a policy that meets your needs.

Unregulated Mortgages

It is important to point out that not all mortgage loans and services are regulated by the Financial Conduct Authority. Some of the advice and services we provide may relate to loans which are either unregulated or have limited consumer protection.

We will confirm with you if any product we are recommending is not regulated by the FCA.

You should note that if we are arranging a “Buy-to-Let” mortgage for you, it is very important to understand that very few Buy-to-Let mortgages are regulated by the Financial Conduct Authority (FCA).

We will confirm with you if any product we are recommending is a Business Loan; a Business Buy-toLet; or a Consumer Buy-to-let loan.

Service level

We are committed to providing prompt and efficient service and always aim to respond as quickly as possible. All correspondence, including phone calls, emails, and text messages, will be responded to within 1 working day.

Fully packaged cases submitted with all required documents will be thoroughly reviewed within 5 working days.

Please note that we will only submit cases to lenders once all required documents have been received in line with regulatory requirements and have been reviewed to our satisfaction.

The Costs of Our Service

Mortgages

We charge a fixed fee of £495 for all cases, excluding product transfers, at the Agreement In Principle (AIP) / Decision in Principle (DIP)stage.

This fee is non-refundable, even if you decide not to proceed with a property purchase.

This fee reflects the premium service we provide at the early stages of your mortgage journey, which includes:

• A full affordability and eligibility assessment

• Review of all supporting documents

• Credit file review and risk flagging

• Obtaining a lender-approved AIP/DIP tailored to your circumstances

• Unlimited AIP renewals or lender switches for up to 12 months from the date of payment

Once the AIP is in place, you are free to search for a property over the next 12 months.

If we submit a mortgage application and the case does not proceed due to a property downvaluation or £0 valuation, the original case will be closed. Should you wish to proceed with a new property, a new AIP/application cycle will be required, and full fees will apply again for the new case. Please see the fee table below for more details.

Standard Complex Case

A Standard Complex Case refers to a standard residential or buy-to-let application that, while not classed as specialist lending, involves significantly more time, documentation or complexity than typical cases.

This may include, but is not limited to:

• Applicants with multiple or irregular income sources (e.g. self-employed, foreign income,

rental income, commissions)

• Changes in any circumstances after the AIP has been submitted

• Any additional document checks that fall outside our standard document requirements

• Additional documentation required due to visa, residency or status checks

• Cases requiring repeated document reviews, clarification, or lender-specific formatting

We are committed to treating all customers fairly and complying with FCA Consumer Duty by ensuring that any fees reflect the genuine time and expertise required to progress your case responsibly.

Please note due to consumer duty requirements set by the FCA all the fees are fixed and nonnegotiable.

We will receive and retain any commission paid by the lender when your mortgage is completed. This amount will be confirmed by the lender in their disclosure document.

Should you wish, you can request to view the commission rates from each of the lenders we have considered at the time that we make our recommendation to you.

Referral Fees

Please note that we may receive a referral fee from solicitor firms or valuers if we refer you to their services. The amount of this fee varies on a case-by-case basis and will be fully disclosed to you at the time of the referral.

Packagers fees

Please note that some lenders only accept cases from a packager and not from us directly. If we do use a packager the packager will have their fees. Please note that the fees will be on the illustration that is provided to you.

Refund of fees

Please note our fee will still be charged should the lender reject your mortgage application due to you not disclosing any material information about your personal situation or if the property is not suitable for lending.

It should also be noted we do not provide a refund should you decide not to proceed with the mortgage loan after we have made an application to the lender on your behalf following your request.

Please note that we do not provide a refund for the AIP/DIP if you are unable to find a property, as mentioned above we will continue to renew the AIP/DIP for 12 months from the date of payment.

In the event that your mortgage application is declined due to an error or oversight by the adviser, or if it becomes clear that the case was not suitable for the lender’s published criteria or risk appetite at the time of submission, we will issue a full refund of our advisory fee in accordance with our commitment to treating customers fairly.

Non-Investment Protection and General Insurance Contracts

We do not charge a fee as we will receive a commission from the provider/insurer after the policy has been placed on risk.

Your Duty of Disclosure

Any financial advice we provide will be based on your personal financial circumstances and objectives. The information you give us must be both accurate and a true reflection of your current circumstances.

It is your responsibility to provide complete and accurate information to a provider (a provider being, for example, an organisation that provides insurance, mortgage, or investment-related plans).

All statements made on any proposal form, or on any additional documentation must be full and accurate.

Please be aware that if you fail to disclose any relevant information or any change of circumstances to a provider, then the terms of your desired plan may be invalidated (e.g. an insurance claim may not be paid). We strongly recommend that the information you provide is checked thoroughly prior to submission.

Client Money Peace Of Mind

We do not handle Client Money. We never handle cash and will only accept BACs/Card payments in settlement of Advice and Service Charges. Our preferred method of payment is via bank transfer.

Paying For Advised Services

Full details of the final Advice will be provided in the Suitability Advice Report. Details of any fees payable and future service agreements will be provided in the ‘Authority to Proceed’ document prepared for you by your Adviser. You will be asked to sign and return a copy of this document to confirm your understanding and acceptance of the arrangements.

Our Ethical Policy

We are committed to providing the highest standard of advice and service possible. The interest of our customers is paramount to us and to achieve this we have designed our systems and procedures to place you at the heart of our business. In doing so, we will:

• be open, honest and transparent in the way we deal with you.

• not place our interests above yours.

• communicate clearly, promptly and without jargon.

• seek your views and perception of our dealings with you to ensure it meets your

expectations or to identify any improvements required.

Cancellation rights

Certain protection and insurance contracts allow you the right to cancel after a contract has been put in force. Prior to you entering into a contract of protection or insurance we will provide you with specific details should this apply to include: its duration; conditions, practical instructions and any costs for exercising it, together with the consequences of not exercising it.

Instructions

We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing.

Complaints

If you wish to register a complaint, please write to Avram Financial Services trading as Mortgage Circle, 157A Stratford Road, Shirley, Solihull, B90 3AX or telephone 0121 572 0675 or email us at Info@mortgagecircle.co.uk

A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them on 0800 023 4567.

Compensation Scheme

If you make a complaint and we are unable to meet our liabilities, you may be entitled to compensation from the Financial Services Compensation Scheme.

Further information about the limits applicable to the different product types is available from the FSCS at http://www.fscs.org.uk/what-we-cover/products

Client Verification

We may be required to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up to date. For this purpose, we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.

Law

This agreement is governed and shall be construed in accordance with the Law of England and the parties shall submit to the exclusive jurisdiction of the English Courts.

Force Majeure

Avram Financial Services Ltd trading as Mortgage Circle shall not be in breach of this Agreement and shall not incur any liability to you if there is any failure to perform its duties due to any circumstances reasonably beyond its control.

Termination

The authority to act on your behalf may be terminated at any time without penalty by either party giving 7 days’ notice in writing to that effect to the other, but without prejudice to the completion of transactions already initiated. Any transactions effected before termination and a due proportion of any period charges for services shall be settled to that date.

Customer Privacy Notice

Why should you read this document?

During dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances.

Your Personal Data may identify you directly, for example, your name, address, date of birth, and national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing, you with assistance in relation to your mortgage or insurance requirements Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses

and documents that are necessary to verify your identity.

• Employment and remuneration information, (including salary/bonus schemes/overtime/sick

pay/other benefits), employment history.

• Bank account details, tax information, loans and credit commitments, personal credit history,

sources of income and expenditure, family circumstances and details of dependents

• Health status and history, details of treatment and prognosis, medical reports (further details

are provided below specifically regarding the processing we may undertake in relation to this

type of information)

• Any pre-existing mortgage or insurance products and the terms and conditions relating to

these.

The basis upon which our firm will deal with Your Personal Data

When we speak with you about your mortgage or insurance requirements, we do so on the basis that both parties are entering a contract for the supply of services.

To perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either during initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to contact you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

When you ask us to assist you with for example your insurance / ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you for information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data to make enquiries of insurance/investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data. The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together with “Criminal Disclosures”). This is relevant to insurance-related activities such as underwriting, claims and fraud management. We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to mortgage or insurance. You will provide information to us verbally and in writing, including by email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voter’s roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?

While handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer

systems (websites, email, hard drives, and cloud facilities). This information can only be

accessed by employees and consultants within our firm and only when it is necessary to

provide our service to you and to perform any administration tasks associated with or incidental

to that service.

• Submit Your Personal Data to Product Providers/Mortgage Lenders/Commercial Lenders

and/or Insurance Product providers both in paper form and online via a secure portal. The

provision of this information to a third party is essential in allowing us to progress any enquiry or

application made on your behalf and to deal with any additional questions or administrative

issues that lenders and providers may raise.

• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage or insurance you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

• Mortgage or Insurance Third parties who we believe will be able to assist us with your enquiry

or application, or who are able to support your needs as identified. These third parties will

include but may not be limited to, our compliance advisers, product specialists, estate

agents, providers of legal services such as estate planners, conveyancing, surveyors, and

valuers (in each case where we believe this to be required due to your particular

circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e., to progress your mortgage or insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and Retention of Your Personal Data

Your privacy is important to us, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password-protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have the legal right to such information we will retain records indefinitely.

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control.

• ask us to further explain how we use Your Personal Data

• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to

the extent to which we can do this will be provided at the time of any such request)

• ask us to send an electronic copy of Your Personal Data to another organisation should you

wish

• change the basis of any consent you may have provided to enable us to market to you in the

future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document or wish to make contact in order to exercise any of your rights set out within it please contact: Muhim Tanjib, Mortgage Circle, 157A Stratford Road, Shirley, Solihull, B90 3AX or email info@mortgagecircle.co.uk

If we feel we have a legal right not to deal with your request, or to action, it in a different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Please sign below to confirm you have read and understood the Customer Privacy Notice.

Authority to Proceed

This document confirms the fees and terms and conditions that apply to our work with you. It does this by confirming:

• which documents you have been issued with, upon which we can both rely

• any specific fees agreed with you for providing advice, implementation or ongoing

services

• the method of payment of those fees and cash equivalent examples where required

• how we keep in touch with you and manage your personal data

YOUR CONFIRMATION

I have given consent for you to hold my/our personal data and to share it with Providers for the purpose of advising, arranging, administering and servicing of financial products and services.

For your own benefit and protection, you should read these terms carefully before signing. If you do not understand any point, please ask for further information.

INITIAL / ADVICE FEE CONFIRMATION

ONGOING SERVICE CONFIRMATION

To provide you with a high-quality service we may want to contact you regarding items we consider are of interest to you, or to make you aware of new opportunities. If this happens, we would like to contact you.

Please confirm:

I want to receive this type of contact, by the following method(s):

by phone by post by e-mail by text

We will make reasonable endeavours to contact you to arrange a review of your mortgage and protection needs. This ensures that you are not paying more than you need to, as well as reassuring you that your current arrangements are still the most appropriate for your needs.