Complaints Handling Procedure

1. Purpose

• This document represents our policy towards complaints, how a consumer can
  make them and how as a company we handle them.
• This policy and procedure have been created to meet general standards and
  requirements and complies with standard complaint handling procedures,
  including the Financial Ombudsman Service (FOS) and FCA regulations such as
  CONC and DISP.
• We take our responsibilities seriously, in addition to the legal and regulatory
  requirements we have as a financial firm
• We are committed to ensuring the fair treatment of our consumers and ensuring
  they face no post sale barriers with our service, and we have eective and
  transparent procedures in place.
• As a business we ensure that complaints can be made using any reasonable
  means and recognise complaints require a resolution.

2. Definition

As per FCA material, they define a complaint as the following –

‘Any oral or written expression of dissatisfaction, whether justified or not, from, or
on behalf of, a person about the provision of, or failure to provide, a financial
service, claims management service or a redress determination, which alleges that
the complainant has suered (or may suer) financial loss, material distress or
material inconvenience’

3. Customer Complaints Procedure

‘Our aim is always to provide an exceptionally high level of service to all of our
customers. Where customers are unsatisfied, it’s important to us that this is dealt
with objectively, fairly and as quickly as we are able to.

The following procedure explains how we deal with complaints, our commitments
to you and what action to take if you think your complaint has not been resolved
to your satisfaction.

If you have a complaint about any aspect of our service, then we would like to
hear from you. Please use the below details to let us know –

E: info@capitalcarfinance.co.uk

T: 01270 306000

P: Unit 10 Alvaston Business Park, Nantwich, Cheshire, CW5 6PF

We kindly ask, so we can look into your complaint as quickly as possible. You
include as much detail as you can, however if we are missing anything we will be in
touch. We will aim to come back to you within 48 working hours of receiving your
complaint.

If we are able to investigate and resolve your complaint within 3 days, you will
receive a summary resolution response from ourselves, which will detail our
outcome and findings.
In the event our investigations take longer than 3 days, we will issue you a Final
Response within the 8-week timescale.

Whilst we try to close any complaint before this 8-week time frame, we do need to
make you aware we do have this time. Our final response will include detailed
information of your complaint, our investigation and the resolution we have come
to. If you are not satisfied with our Final Response or the handling of your
complaint within the 8-week time frame, you can contact the Financial
Ombudsman service using the details below. You must do this within six months of
our final response.

W: www.financial-ombudsman.org.uk

T: 0800 023 4567

P: Exchange Tower, Harbour Exchange, London, E14 9SR

Please note, should your complaint be regarding a car finance agreement and/or
discretionary commission arrangement (‘DCA’) before 28
th January 2021, we need
to make you aware that the current 8 week deadline to respond to your complaint
is currently paused. This is due to the investigation and review the FCA are
carrying out within the Motor Finance Industry regarding the handling of such
complaints. Please note we will still work hard to resolve your complaint in the
background and keep you updated throughout the process; however we need to
make you aware that we will not have to respond to your complaint with a Final
Response until after 4th December 2025 at the earliest.

Please note should your complaint be regarding a Non-DCA Commission
Disclosure and was made on or after 26th October 2024, the same extension is in
place and we have until after 4th December 2025 to provide you with a Final
Response.

We also need to make you aware that if you are unhappy with your response, the
FCA has extended the deadline in which you can refer your complaint to the
Financial Ombudsman Service (for these types of complaints only)

If you’re sent a final response between 12 July 2023 and 29 April 2025, you’ll now
have until 29 July 2026 to take your complaint to the Financial Ombudsman.

If you’re sent a final response between 30 April 2025 and 29 January 2026 you’ll
have 15 months from the date the final response is sent to refer your complaint to
the Financial Ombudsman.

You can find further information on the work the FCA is carrying out via this link

https://www.fca.org.uk/carfinance.

4. Processes and Responsibilities

1. Record Keeping

• As per DISP 1.9 and to ensure that we handle our complaints eciently and
  eectively, any correspondence or notes from phone communication will be
  documented on our CRM and internal systems
• This will allow the complaints handler to review the whole complaint and
  refer back to any point in the investigation if they are required to do so.
• Any documentation received regarding the complaint will also be uploaded
  to the application.
• All records of complaints will be kept as per our retention periods, only
  employees that require access to customer complaint notes will be granted
  this information.
• We aim to resolve all complaints as soon as possible to minimise the
  number of open complaints (DISP1.4.3).

2. Training

• Sta will receive complaints training within their initial induction and at least
  once a year
• Training will ensure our team understands the processes that we have in
  place and the regulatory importance of following these processes.
• At any time, sta have the opportunity to request further training on any
  aspect of our business.

3. Treating Customers Fairly (TCF)

• As a company, we ensure that we follow all regulatory guidelines, including
  treating customers fairly.
• When it comes to complaints, we guarantee that our customers will not face
  any post sale barriers.
• Our sta are aware that they need to assist customers as much as possible
  when they wish to make a complaint, and they should not receive a
  dierent service to any other customer
• As per DISP 1.3.2 customers are made aware they can make a complaint
  verbally or in writing and these contact details are provided in our
  complaint’s procedure for ease for the customer.
• We will ensure that our complaints procedure is in a clear location so our
  consumers can access it with ease. To ensure we are in compliance with
  DISP 1.2, our complaints procedure is clearly listed on our website and a
  copy will be sent via email.
• Specifically, to meet DISP 1.2, our complaints procedure will also detail
  contact details for the FOS.
• Customers will have their expectations managed, and sta will explain the
  complaints process so a customer can understand the next steps.
• As per DISP 1.4.1, we will thoroughly investigate any complaint competently,
  diligently and impartially, ensuring that any evidence obtained is saved to
  the customer’s application for record.
• i In line with 1.4.2 all factors of the customer journey and outcome will be
  considered in our investigations.
• We wil keep in constant communication with all parties, including our
  finance partners, ensuring we keep in touch at least once a week whilst
  investigations are taking place.
• We will assess fairly, consistently, and promptly
  • the subject matter of the complaint.
  • whether the complaint should be upheld.
  • what remedial action or redress (or both) may be appropriate
  • if appropriate, whether it has reasonable grounds to be satisfied that
    another respondent may be solely or jointly responsible for the
    matter alleged in the complaint
• All communication received will be acknowledged within 48 hours, as per
  DISP 1.6.1.
• If a customer makes a complaint about a specific member of the team, that
  employee will not have any involvement in handling the customer’s
  complaint
• Customers will never be charged for making a complaint, no matter what
  method of communication they use (DISP 1.3.1).
• Where a customer has referred a complaint to the FOS, we will fully comply
  with any further investigations and comply promptly with any settlements
  or rewards in line with DISP1.4.4.
• At any point in our trading future, we are required to publish our complaints
  data due to the number of complaints received, we will ensure this is easily
  available to our customers and contains all the required information and in the time limits required. We will inform the FCA in writing as and when this
  has been actioned.
• As per DISP 1.8, should we receive a complaint which is outside of the time
  limit (as detailed in DISP 2.8) for referral to the FOS and we reject the
  complaint, we will provide a full explanation of this to the complainant.
• For reference these time limits are as follows –
  • more than six months after the date on which we sent our final response,
    redress determination or summary resolution communication
  • More than six years after the event complained of
  • three years from the date on which the complainant became aware (or
    ought reasonably to have become aware) that they had cause for
    complaint

Summary Resolution

• In line with DISP 1.5 we have put in the following process should we resolve
  the complaint within 3 working business days.
• Once resolved, we will send the customer a Summary Resolution using our
  templates.
• This will include details of how the customer can refer their complaint to
  FOS should they wish to if they are not satisfied with our response, the time
  limits able to do this and that we consider the complaint closed.
• Depending on the customer’s circumstance, and if it is deemed easier or
  preferred for the customer, we may communicate this resolution via other
  methods such as telephone.

5. Redress and Compensation

• Compensation or redress will be decided on an individual basis and detailed
  to the customer in our final communication
• Management will take into account all aspects of the complaint and any
  suering caused to the customer and oer compensation based on these
  aspects and per regulation.
• Where Compensation and redress is considered or decided, we will ensure
  all factors have been taken into account including all evidence obtained
  and regulation set out by the FCA and FOS.
• Compensation or redress may also involve agreements with lenders or
  suppliers, to determine an overall decision, and where application all
  communication and decision will be documented.
• As with all complaint records, redress and compensation will be recorded so
  we are able to report amounts to the regulator.

6. Point of Contact

• As per DISP 1.3.7, the firm has appointed Mark to currently handle all
  complaints and SQ issues
• We will ensure this information remains clear and up to date on our FCA
  register.
• As the firm grows and moves forward, we will consistently review Mark’s
  ability to carry out this responsibility and regularly review their knowledge
  and training to ensure they are competent in their responsibilities.
• We will request an email or detailed description over the phone to handle
  the complaint further
• They will then liaise with the customer and any third parties as required
  (and in line with DISP 1.7.1) and issue a final response letter or summary
  resolution.
• If in the event or circumstance we are required to forward the complaint, we
  will do so promptly and inform the customer that we have done so.
• We are committed to ensuring that we are in control of all complaints and
  complete them as soon as possible.
• Mark will ensure all complaints are updated on the complaints log, system
  and compliance monitoring plan.
• Templates will be used when liaising with customers for acknowledgement
  (including initial and holding letters), Summary Resolution and Final
  Response Letters to ensure that the customer receives information required
  in DISP such as (but not limited to) 1.6.1 and 1.6.2.
• This will include:
  • Acceptance or rejection of the complaint
  • Information on any redress oered and agreed on
  • Information on how the customer can contact FOS and the time limits
    applicable
  • FOS explanatory leaflet
• If we cannot provide the customer with a final response in 8 weeks, we will
  ensure a holding letter is provided that will include:
  • Why we are unable to provide this
  • A timeframe of when we believe we will be able to
  • Informing they are able to contact FOS and the contact details to do
    so
  • d. FOS explanatory leaflet
• If we cannot provide the customer with a final response in 8 weeks, we will
  ensure a holding letter is provided that will include:
  • Why we are unable to provide this
  • A timeframe of when we believe we will be able to
  • Informing they are able to contact FOS and the contact details to do
    so
  • d. FOS explanatory leaflet
• If we are able to resolve the complaint before the 8-week period, the final
  response will be sent as soon as possible.
• All correspondence with customers will be clear, fair and not misleading.
  Where information such as FOS details is required to be prominent, this will
  be done so.

7. SQ vs. Complaint

• It is important that we can dierentiate between a complaint and an SQ
  issue.
• Whilst they are dierent, we do adopt the same principles, and try to assist
  our consumers rectify any issues they have with their vehicle.
• We provide this service as an extension to our oerings in the hope we can
  make the consumer’s journey as easy as possible.
• We will assist liaising with the dealer/lender, if necessary, to try to come to
  an arrangement to provide our consumer with the vehicle they desire.
• All SQ’s will be documented on our complaints log for management
  information purposes, which assists in providing additional information on
  dealerships and their service/business activities.
• Root analysis may be conducted on specific issues, which will be reviewed
  by Directors and used when completing Dealer Due Diligence.
• To ensure we meet DISP 1.3.2A, we are committed to learning from all
  complaints and SQ issues received, ensuring we are analysing any patterns
  produced or guidance received
• As per DISP 1.3.3 we will ensure appropriate management controls are in
  place to identify and remedy any recurring or systematic problems, both
  with regulated and SQ complaints.
• The following processes and training have been implemented to include:
  • How to identify a root cause
  • How to prioritise
  • to consider whether any information could impact other aspects of
    our process and policies, and if action is required
  • if action needs to be taken to amend a certain process and
    implement a timeframe and actions as to when and how this will be
    done
  • keeping records of all changes and ensure version control rules are
    met
• Should issues or problems be identified and other customers who may not
  have come forward be (or suspected to be impacted) we will take
  appropriate action to contact those customers and if applicable, take steps
  to remedy the problem, obtain a solution or calculate redress (as per DISP
  1.3.6)

8. The FCA’s Motor Finance DCA and Non-DCA Commission Disclosure Complaints Review

• On the 11
  th January 2024 the Financial Conduct Authority (FCA) announced
  their intention to review historical motor finance discretionary commission
  arrangements (DCA’s) across the motor finance industry.
• As per DISP App 5.1.1 (3), all rules and guidance and DISP continue to apply
  to a relevant motor finance DCA complaint unless otherwise stated,
  therefore all other aspects of this policy still apply.
• The FCA, as per DISP app 5.1.2 have determined that a relevant motor
  finance DCA Complaints is a complaint where
  • the subject matter of the complaint relates, in whole or part, to a
    regulated credit agreement entered into before 28 January 2021;
  • the regulated credit agreement, in whole or part, financed the
    purchase of a motor vehicle, or a motor vehicle was bailed or hired
    under the agreement;
  • there were arrangements between the lender and a credit broker
    relating to the entering into of that agreement that included a
    discretionary commission arrangement; and
  • the respondent:
    • (i) received the complaint in the period beginning with 17
      November 2023 and ending with 4 December 2025; or
    • (ii) sent a final response to the complaint in the period
      beginning with 12 July 2023 and ending with 29 January 2026
• Regarding time limits and responding to customers, where a final response
  has been sent in the period beginning 12th July 2023 and ending with 20th
  November 2024, the 6 month period as detailed in DISP 2.8.2R(1) in relation
  to customers referring their complaint to the FOS is extended to 15 months
• This rule applies in respect of a relevant motor finance DCA complaint
  where a final response is sent in the period beginning with 11 January 2024
  and ending with 20 November 2024
• This rule applies in respect of a relevant motor finance DCA complaint
  where a final response is sent in the period beginning with 11 January 2024
  and ending with 20 November 2024
• Where a final response has been sent regarding a non-DCA complaint in the
  period beginning with 21 June 2024 and ending with 29 April 2025, DISP
  2.8.2R(1) is modified so that the Ombudsman cannot consider a complaint if
  it is referred to the Financial Ombudsman Service on or after 30 July 2026.
• If a final response is sent regarding a non-DCA complaint in the period
  beginning with 30 April 2025 and ending with 29 January 2026, DISP
  2.8.2R(1) is modified so that the Ombudsman cannot consider a complaint if
  it is referred to the Financial Ombudsman Service more than fifteen months
  after the date on which the respondent sent the complainant its final
  response
• To ensure customers are fully aware of this change, this has been amended
  within our complaints procedure and complaints communication templates
• Any impacted customers have been informed of this change in writing and
  we have ensured in order to support our customers, we have included the
  link to the FCAs resource page for customers, and made it clear we are
  available to answer any further qu eries.
• The FCA have also stated that they are pausing the 8 week deadline Motor
  Finance firms have to respond to customers in relation to DCA Complaints.
• Time is to be treated as not running for the period beginning with 11
  January 2024 and ending with 4 December 2025 following the update from
  the FCA in September 2024
• As of December 2024, the FCA also advised following the Court of Appeals
  decision in Hopcraft, Johnson and Wrench in October 2024, non-DCA
  Commission disclosure complaints are also included within the December
  2025 Final Response extension.
• As per DISP App 5.1.3A, a motor finance non-DCA complaint is a complaint
  where
  • (1) the subject matter of the complaint relates, in whole or part, to a
    regulated credit agreement or a regulated consumer hire agreement;
  • (2) the regulated credit agreement or the regulated consumer hire
    agreement, in whole or part, financed the purchase of a motor
    vehicle, or a motor vehicle was bailed or hired under the agreement;
  • (3) there were arrangements between the lender or owner and a
    credit broker relating to the entering into of that agreement that
    provided for the payment (directly or indirectly) of any commission,
    fee or other financial consideration or remuneration including a
    benefit of any kind to the credit broker;
  • (4) the complaint is not a relevant motor finance DCA complaint as
    defined in DISP App 5.1.2R; and
  • (5) the respondent:
    • received the complaint in the period beginning with 26
      October 2024 and ending with 4 December 2025; or
    • sent a final response to the complaint in the period
      beginning with 21 June 2024 and ending with 29 January 2026.
• We have ensured information regarding the extensions is clear in our
  customer complaints procedure, and are suitably knowledgeable to answer
  any questions the customer may have regarding the extensions.
• As per DISP 5.2.5 we will promptly ensure that the customer is aware of any
  changes regarding the time limits or extensions in writing and refer them to
  fca.org.uk/car-finance-complaints which details the reason for this pause.
• This includes customers who may have made a complaint regarding
  non-DCA commission during the time period 26th October 2024 and 19th
  December 2024 but did not receive a final response during that time.
• To ensure we are abiding by other regulations such as the Consumer
  Support Outcome of the Consumer Duty, we will keep up to date and in
  touch with the customer throughout this period to keep them informed of
  any investigations and updates, and be on hand to answer any queries
• As per DISP 5.3.1, DISP5.3.1A and DISP5.3.2 and the Record Keeping clause of
  this policy (Section 4.1) we will ensure we retain and preserve all records
  securely.
• In line with the FCA’s update in December 2024 (PS24-18 2.50), complaint
  information is required to be kept for 3 years, which we will be following.
• As the FCA have also stated within the December 2024 update, they may
  revisit this so we will observe caution as revisit if the data can be destroyed
  closer to the date.
• Records include the following information where we have access to such
  information –
  • i) a copy of the regulated credit agreement;
  • ii) records of the commission arrangements relating to the regulated
    credit agreement;
  • iii) records of any commission, fee or other financial consideration paid
    (directly or indirectly) in connection with the regulated credit
    agreement, including details of its structure and calculation;
  • iv) customer files and records, including any agreement setting out the
    nature of the services oered, any customer transactions and
    payments; and
  • v) communications with the customer
• As a firm we are committed to ensuring we will remain up to date with the
  FCA’s investigation into DCA and non-DCA commission Complaints, and will
  ensure we abide by the Conduct Rules and our responsibility as a regulated
  firm in being open and co-operative if any information is requested from
  the FCA or FOS.

5. Monitoring and Compliance

It is extremely important that this policy is complied with to protect our consumers. As a
company we will ensure that we keep up to date with regulatory and legal requirements,
and that our processes and policies are updated accordingly to meet regulation (DISP,
CONC, TCF)

We may conduct root analysis on our complaints to identify any patterns that may
potentially form, therefore limiting risk to our consumers.

All complaint information will be reported within our RegData as per DISP 1.10 rules and
guidance or upon request. We will ensure that all information requested by the FCA
including but not limited to total amount, amount closed, amount open and redress paid,
is accurate, honest and up to date as per the Reg Data system. We do not anticipate
meeting the 500-complaint threshold in the near future but will continue to review
processes and implement necessary reporting requirements when required.

In the event a complaint identifies an area of concern within our procedure, this will be
assessed and rectified where applicable.

6. Review

This policy will be reviewed on at least an annual basis with any updates will be reissued
on this policy. All policy changes are approved by directors.