Fair Dealing Policy
Under the Financial Markets Conduct Act 2013 (Act) and the Regulations under the Act, Harmoney is required to have in place a fair dealing policy. This document is Harmoney's fair dealing policy.
This document is in effect from July 2014.
Summary of Fair Dealing Policy
Harmoney has in place specific processes and procedures for the purpose of verifying the identity of the Borrower, and for assessing the credit-worthiness of the Borrower (which, through the application of Harmoney's proprietary credit scoring process to that information, will result in Harmoney generating a credit score for that Borrower).
In order for a person to register as a Borrower, that person must:
- provide to Harmoney all information which Harmoney requires, as set out in the application process on the Harmoney website at http://www.harmoney.com;
- be otherwise acceptable to Harmoney at Harmoney’s absolute discretion.
Harmoney reserves the right at any time to:
- not register any person as a Borrower;
- revoke the registration of any person as a Borrower; or
- restrict the activities of any Borrower,
- where Harmoney believes or has cause to believe that the relevant person or Borrower has, in relation to the Harmoney service or application process or otherwise:
- engaged in conduct that is misleading or deceptive or likely to mislead or deceive;
- made a false or misleading representation in contravention of section 22 of the Act;
- made an unsubstantiated representation in contravention of section 23 of the Act; or
- has otherwise been in breach of any of the terms under which Harmoney provides any service or access to its website at http://www.harmoney.com
Application of the Fair Dealing Policy
Harmoney implements its fair dealing policy with a combination of automated and manual checks. During the automated credit approval process credit rules will pick up anomalies and inconsistencies in information provided, and either decline the Borrower or refer it for manual review by Harmoney staff.
If the lending purpose disclosed by the Borrower is debt consolidation, and the Borrower successfully funds a loan through the Harmoney platform, then the Harmoney process automates the payment of existing debt providers with the loan funds from the Harmoney platform to ensure the loan is used for its intended purpose. If the Borrower's affordability analysis undertaken by Harmoney discloses that the Borrower can service existing debt as well as the Harmoney sourced loan then the loan proceeds will be paid directly to the Borrower.
Harmoney's customer service and collections staff are trained to identify deceptive and misleading conduct and report it to Harmoney management for investigation. For example, a 20 year old who discloses a significant annual income would be flagged for further investigation by Harmoney to ensure appropriate verification is completed and (where appropriate) the conduct will be reported to the relevant authorities.