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Treating Customers Fairly

Purpose

This policy deals with Automotive Online Ltd T/A Quick Car Finance (AOL/QCF) responsibilities to comply with the FCA’s Treating Customers Fairly (“TCF”) initiative. It applies to all members of our team, and they are expected to abide by the processes set out within this document.

Regulation

The aim of FCA’s Treating Customers Fairly (TCF) initiative is to ensure that firms meet the requirements of Principle 6 to “pay due regard to the interests of its customers and treat them fairly”. What constitutes fairness is evidenced differently for each firm, depending on their type of business, product and service range, target customers and the channels used to sell and support their products and services

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

  1. Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
  2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
  3. Consumers are provided with clear information and are kept appropriately informed before, during, and after the point of sale.
  4. Where consumers receive advice, the advice is suitable and takes account of their
    circumstances.
  5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and also as they have been led to expect.
  6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Processes

Income and Expenditure evaluation

  • We will validate income information to ensure our lenders have the information to calculate a sensible max lend the customer can afford.
  • All proofs will be checked by our team to validate the income proof is a valid form.
  • We will question the customer on our pre/validation calls to ensure the customer feels they can comfortably afford the monthly repayment.

Communication

  • All communication templates and scripts will be reviewed for compliance purposes
  • Compliance will be involved in subsequent disclosures involving our products and services.
  • We continually invite feedback from our clients to ensure that our services meet their needs and expectations

Training

  • At least annually, all employees will be required to undertake TCF training. All new hires need to complete TCF training within 90 days of their hire date.
  • We will establish training materials for staff explaining new products and services.
  • Products
  • We will review all new proposals for products and services, prior to implementation, for TCF compliance.
  • We will ensure that our lender criteria is updated on our system to ensure that customers are not being sent to lenders where their circumstance wont fit criteria, therefore avoiding unnecessary searches.

Leadership

  • On at least a monthly basis we review and discuss compliance with TCF outcomes.
  • We regularly, at least annually, remind staff in writing of TCF expectations.
  • We will monitor compliance on a weekly basis, a compliance monitoring report will be submitted to the board each month

Complaints

  • Monthly we will review the customer complaints log. If there are any complaints impacting TCF, a complete review will be completed to determine the root cause issue and identify any necessary procedural changes and/or staff training needs required to address

Marketing

  • All marketing will be clear, fair and not misleading
  • All representatives will be kept accurate and up to date to ensure consumers expectations are managed

Remuneration

  • Should any member of staff found to not act according to process, commission may be deducted
  • Staff must not choose specific lenders based on commission received, but at all times must act in the customers best interests and provide them with the best rate possible

Monitoring and Compliance

All staff are expected to comply with our policy, and any member found not to may be subject to disciplinary action. Staff will be monitored and audits carried out to ensure that this policy is being complied with.

Monitoring and Compliance

This policy will be reviewed on at least an annual basis. Any updates will be reissued to our team, along with any training to ensure they fully understand the changes that have been made.