REQUIREMENTS IMPOSED BY THE OFFICE OF FAIR TRADING (OFT)

PURSUANT
TO
SECTION
33A AND
SECTION
33D(4)
OF
THE

CONSUMER CREDIT ACT 1974 ('the Act')

REQUIREMENTS RELATING TO:

Hermes Property Services Limited (consumer credit licence No: 622271 ),

2NN, (Company Number 6548951 ).

THE OFT REQUIRES HERMES TO DO OR NOT TO DO (OR TO CEASE DOING)
AS FOLLOWS:

1.
Assessing affordability

Hermes Property Services Limited ('HPSL') shall comply fully with its requirement to properly
assess affordability in accordance with paragraphs 4.4.1, 4.4.2 and 4.4.4 of the CCT A Code
of Conduct. In particular, it shall ensure that its decision to lend to each borrower is subject to
a proper assessment of the borrower's ability to meet repayments under the agreement in a
sustainable manner, having regard to the customer's current circumstances and any
reasonably foreseeable changes to those circumstances, in particular HPSL will:

a. require potential borrowers to provide documentary evidence of income declared;
b. take account of a potential borrower's regular expenditure having regard to any
documentation provided and where no evidence is available, take steps to ensure the
expenditure declared is reasonable; and

c. take account of a potential borrower's personal circumstances when assessing
affordability.

2.
Adequate explanations

HPSL shall comply fully with its requirement to provide 'adequate explanations' in accordance
with section 55A of the Consumer Credit Act 1974 and section 4.3.2 of the CCTA Code of
Conduct.
In particular, staff will inform borrowers, before meeting with the borrower to
complete the agreement, of the provisional weekly and/or monthly repayment and total
amount payable under the credit agreement and, where the agreement is to be secured by a
bill of sale, the particular features of a bill of sale agreement which differ from the more
common forms of finance, including:

a. HPSL's right to recover the vehicle without first obtaining a court order; and
b.
that HPSL may enter private premises to do so.

3.
Training and monitoring

HPSL will implement and maintain procedures to ensure that all employees are fully trained
on company procedures and that their compliance with those procedures is regularly
monitored, particularly:

a. All field, call centre and compliance staff will receive adequate training on assessing
affordability in accordance with the requirement 'Assessing affordability' above;
b. All field and call centre staff will receive adequate training on explaining the product
and its associated risks in accordance with 'Adequate explanations' above;
c.
The training detailed in (a) and (b) above will be completed within 6 weeks of a new
staff member being employed and in any event prior to new staff members having
unsupervised contact with any consumers;

d. All existing call centre and compliance staff will receive re-training in accordance with
(a) and (b) above within 6 weeks of the date of these requirements;
e. All staff's performance and compliance with company procedures, particularly in
respect of the requirements given herein, will be monitored and reviewed regularly;
and
f.
All staff will be subject to further re-training, disciplinary action and ultimately
dismissal if they do not adhere to the said company procedures.

ANY FAILURE TO COMPLY WITH THE ABOVE REQUIREMENTS WILL RENDER

HERMES LIABLE TO FURTHER FORMAL ACTION BY THE OFT. THIS COULD

INCLUDE THE IMPOSITION OF FINANCIAL PENAL TIES PURSUANT TO SECTION
39A OF THE ACT AND/OR THE REVOCATION OF HERMES' CONSUMER

CREDIT LICENCE PURSUANT TO SECTION 32 OF THE ACT.

Authorised signatory on behalf of the OFT

Simon Brindley, Credit Legal Director