Huddle Capital Complaints Procedure
We realise that sometimes things go wrong and while we strive to resolve any of your issues as soon as possible, occasionally we may not live up to your expectations and you may want to make a formal complaint.
We have a formal complaints procedure.
Initially, you should contact us via email at firstname.lastname@example.org and we in return will make contact with you directly. Our aim is to respond to any complaint within 48 hours and to resolve any issues within 14 days.
Our Director of Customer Services will handle your complaint personally.
We aim to provide a first-class service to our clients, but in some circumstances, we are going to fall below some client’s expectations. We will attempt to rectify any issue you have with the Platform or our company as soon as possible, but if you feel the issue needs to be escalated to a complaint, these are the procedures we will follow.
These procedures are based on the requirements of the Financial Conduct Authority (FCA) who we are regulated by.
The Huddle Capital rules apply to all staff, all areas of activity and all complainants.
The Financial Conduct Authority defines a complaint as:
“An expression of dissatisfaction whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about a firm’s provision of, or failure to provide, a financial services activity.”
We extend this to also mean where an individual has failed to meet our client’s expectations or where we have done something or omitted to do something, that has caused our service to fall below those expectations.
Anyone who is either:
(a) Any customer, or potential customer who is, or is potential, a borrower or lender.
(b) Those who may have an indirect relationship with Huddle Capital, such as an intermediary or a professional working on behalf of a customer or potential customer.
A complaint may also be made by:
(c) someone authorised and appointed by a customer to complain on their behalf
(d) someone authorised by law to complain on behalf of the customer, this could be a lawyer, an executor of an estate, accountant etc.
We will require relevant copies of authorisation before we could release any information or deal with the complaint lodged by a third party.
We will publish our complaints procedure on this section of the website and may update it from time to time without notice to our clients.
Complaints can be lodged via email and you will receive notifications via your registered email with updates to that complaint.
You may complain by telephone and we will provide an electronic record of that complaint.
You may complain by post and we will (if we have an email address on file) provide you with electronic copies of the complaint.
The initial point of contact for complaints is email@example.com and this applies to direct complaints and email complaints.
E-mail complaints should be directed to the dedicated mailbox at firstname.lastname@example.org
The e-mail will be logged in and the details entered into the complaints register. Each entry will note the person making the entry and the date it is made.
Although we would expect most communications to be by email, there may be some complainants who wish to use Royal Mail.
All written complaints should be directed to the dedicated address as follows:
All written complaints will be date stamped, scanned and emailed to email@example.com at which point we will enter the details into the Complaints Register.
This type of complaint may arise when receiving a telephone call or from a direct email. Telephone complaints will immediately be written up and forwarded to firstname.lastname@example.org with any relevant details.
Our primary Customer Services Telephone Number is:
Emails to email@example.com are delivered to –
• The Head of Compliance
• The Head of Customer Service
• The Complaints Administrator
The Head of Compliance will be the person responsible for ensuring that the Huddle Capital Complaints Procedure is followed and adhered to. The Head of Compliance will oversee and have responsibility for compliance aspects and The Head of Compliance is responsible for complaint handling and administration of complaints.
If in the opinion of the Head of Compliance the complaint is straightforward, then it will be dealt with by the Next Day Process. If for any reason this is not possible, then a formal written procedure will follow.
This allows that if the complaint can be resolved to the satisfaction of the person making the complaint:
• by the end of the next business day following receipt of the complaint.
• with no written correspondence being required.
If this is the case, then no further interaction with the complainant will be deemed necessary with regard to the complaint. This implies that the complaint will need to be discussed by telephone with the complainant.
If the Next Day Process is appropriate to the complaint a summary of the complaint will be passed to the relevant Departmental Head who will contact the complainant to discuss an acceptable outcome. If an acceptable agreement can be concluded a note of the discussion and outcome will be noted into the complaints register. No further action will then be necessary once remedial action has been taken.
If this is not possible (e.g. the person cannot be reached or an agreement cannot be achieved) this information will be fed back to the Head of Customer Services who will reroute the complaint through the formal complaints handling the process.
The Complaints Administrator will add the details of the complaint to Huddle Capitals Complaints Register and advise the Head of Customer Services, the Head of Compliance and the relevant Head of Department.
The Complaints Administrator will email the complainant acknowledging their complaint, which will include setting out our understanding of the complaint, if it has arisen within the business and attaching a copy of our Complaints procedure
Where a complaint is made by a third party on behalf of a complainant, we need to ensure that:
– The complainant has authorised a third party to complain on the complainant’s behalf and
– The complainant gives their consent for us to provide the third party with details and
– The complainant gives their consent for us to record information provided by a third party.
We cannot, therefore, provide any further details to a third party until we have made sure that he or she is authorised to make the complaint.
We do this by sending an acknowledgement email to the complainant requesting that they confirm that they have authorised a third party to complain to us and to receive and provide information. A Letter of Authority should be enclosed. A copy of this acknowledgement will also be sent with a covering email explaining why we have written to the complainant.
We will not enter into any further correspondence with a third-party until we have received a valid letter of authority.
Where the complaint is made by a third party on behalf of an eligible complainant, who has died or has become mentally incapable, we need to ask for proof that the third party is authorised by law to make the complaint on behalf of the complainant, unless we already hold a valid copy of the relevant documentation in our records.
– Where the complainant has died, we need to see evidence that a third party has been appointed as the complainant’s personal representative or executor.
– Where the complainant has become mentally incapable, we will need to see an Enduring Power of Attorney (EPA) or a Lasting Power of Attorney (LPA) giving the third party authority to act on the complainant’s behalf.
The letter to be sent to the third party will request a copy of the relevant documentation and ask them to confirm our understanding of the complaint.
Unless we already have documentary evidence that the complainant is deceased or is mentally incapable, we will also send a letter to the complainant providing details of the complaint being made and asking them to contact us if they have any queries. This will alert the complainant if the complaint is being made without the necessary authority.
If we already have a copy of the complainant’s death certificate, we will not write to the complainant.
We will not enter into any further correspondence with a third party until we hold copies of the relevant documentation authorising them to make the complaint on behalf of the complainant.
As soon as the investigation has been completed and the Final Response agreed, Huddle Capital will advise the complainant in writing.
If the investigation has not been completed within of receipt of the initial complaint, we will send the client a to let them know what progress has been made. We will tell the customer that we will write again within a further if we have not finished our investigation.
If the investigation has not been completed within of receipt of the initial complaint, we will send the client an to let them know what progress has been made.
We will also take the opportunity of updating the complainant before the above deadlines are reached if we have anything material to communicate.
The complaint will be referred by the Head of Customer Service to the relevant Head of Department for investigation. They will delegate this responsibility but will ensure that the person concerned has sufficient expertise to investigate the complaint effectively.
Where there is more than one area of complaint and these fall into different categories, the Head of Customer Service will ensure that a single response is sent responding to all the areas of complaint.
The individual investigating will ensure that they email firstname.lastname@example.org and the advising of all progress as it arises and in all circumstances on the last working day of each week if there has been no progress.
The final response email will include:
• A summary of the complaint
• A summary of the outcome of our investigation
• A statement of whether Huddle Capital acknowledges any fault on its part
• Details of any offer made to settle the complaint
• Details of how long any offer to settle the complaint will remain open
In the event that we are unable to resolve a complaint, Individual Lenders (excluding Corporate Lenders) have rights to refer complaints to the Financial Ombudsman Service. Further details are available from the Financial Ombudsman Service at
The complaints database will be updated by either the Compliance Administrator or Head of Customer Service or delegated where necessary.
Records of complaints will be kept for a minimum of three years. The record will include:
• The name(s) of the complainant(s)
• The substance of the complaint
• Any correspondence between Huddle Capital and the complainant including details of any redress offered by Huddle Capital.
A review of all current complaints will be undertaken on a monthly basis by a Board of Company Directors and Senior Management.