vTiger Database System

vTiger is Paleso's CRM/Database and Compliance Tool

Vtigers Purpose

Why was vTiger implemented

NCCP 

When the NCCP legislation was implemented, Paleso developed a customer disclosure process that we had checked and verified by external auditors relating to how we could have customers receive the Credit Guide, Credit Quote and Credit Disclosure prior to our offering credit assistance, without any disruption to our processing process. The key to our process is these 3 points: 

1 - The Broker reads the "Broker Declaration" on the front page of the Paleso Application Form to the customer at the time the application is taken and initials to say they have read it and the customer accepted it.

2 - At the time of submission, the customer is emailed or posted a copy of the Credit Guide, Credit Proposal and Credit Quote outlining the lender the application was submitted to and the Brokerage Fee being charged for that submission. A new Credit Guide, Credit Proposal and Credit Quote are to be provided with each subsequent submission with a different lender and that lender's details on it. It is a requirement that we can prove we provided these documents and the exact time they were provided. Prior to sign up, there is no requirement for a customer to sign any of these forms, only that we have to prove they were provided.

3 - If Approved, the Customer at sign up of loan contracts also signs the Credit Quote that was emailed to them at submission acknowledging that they received it prior to Approval and they were advised they would be receiving it. 

How vTiger makes this compliance work

As soon as you take an application you need to put in vTiger the details about the application and ensure you input at least the customers First Name, Last Name, email address and mobile number. 

As you progress through the application you input notes about the checks you have completed on the application and why you have chosen a particular lender over another (capacity, age of vehicle, etc).

As soon as you have submitted the loan application to a lender, you change the application status to 'Submitted to Lender' ensuring the brokerage amount is correct and select the Lender that you submitted to. 

Once changed to 'Submitted to Lender' the vTiger system then automatically emails the customer an advice advising that a submission has been made with the Credit Guide, Credit Quote and Credit Proposal attached noting the Lender and the Brokerage Fee being charged. 

The key to this process meeting our NCCP legal requirements are:

1. vTiger stores a copy of the email and the attachment which is adequate proof that we completed our requirement of disclosure prior to Credit Assistance being provided.

2. Because it is automatically sent, it prevents Brokers getting busy and forgetting to send the documents leaving Paleso and the Broker exposed to a compliance issue.

3. The Credit Guide, Credit Quote and Credit Proposal are all time and date stamped and the email stored is time stamped so it is adequate proof that the documents were provided before Credit Assistance was provided.

The system sends a copy of the email sent to the customer to the owning Broker, the owning Broker should keep this email for easy access to the attachment so it can be signed if the application is approved.

If a customer doesn't have an email address then these documents need to be printed out and mailed to the customer with a note on the file stating when it was mailed.

When should a customer receive a copy of the Credit Guide, Credit Quote and Credit Proposal?

  • Staight after the loan is submitted by Paleso to a lender, and prior to the customer receiving any Credit Assistance
  • At the loan sign up
  • Never, we can just tell them we submitted a loan on their behalf and we don't have to mention that we are charging a Brokerage Fee

Do you need to send the customer another set of disclosure documents if you send the application to a different lender?

  • Yes
  • No