Treating Customers Fairly (TCF) Policy
Car Leasing takes Treating Customers Fairly (TCF) seriously. All firms regulated by the Financial Conduct Authority (FCA) must pay due regard to the interests of its customers and as a consequence, TCF is an integral part of our business and is embedded in all areas from systems, controls, training, remuneration and staff activity.
Treating Customers Fairly is a key principle set by the Financial Conduct Authority to ensure that customers are treated fairly.
Essentially, it is crucial to how we carry out every aspect of our business. The FCA have set out six 'Treating Customers Fairly' principles which outline how we communicate and engage with our customers, the quality of service we provide and the fairness of our procedures. As an authorised broker we follow and obey these key principles of treating customers fairly.
What does treating customers fairly (TCF) mean?
The FCA has outlined six outcomes as part of TCF. These include:
Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Outcome 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.
Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Outcome 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 as they have been led to expect.
Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
What you can expect from us?
Treating customers fairly is an integral part of Car Leasing’ business culture and we are continuously working to ensure customers are treated fairly. As a result, you can expect the following services when dealing with us:
Clear, fair and transparent pricing
Continual monitoring of our pricing
Quality advice from our sales team based on customer needs, priorities and circumstances
Clear and transparent information regarding pricing as detailed in our Initial Disclosure Document
Continual advice and support
Clear and jargon free information on the product with adequate opportunity for customers to ask questions
After-sales information and services including contract reminders, product updates and help and advice regarding additional services
Full complaints handling procedure
Consumer Duty and Defining a Good Customer Outcome
Introduction
The Consumer Duty, introduced by the Financial Conduct Authority (FCA) in 2023, establishes a higher standard of care for retail customers. Firms are required to comply with the Consumer Duty's cross-cutting rules by:
Acting in good faith towards customers.
Avoiding foreseeable harm to customers.
Enabling and supporting customers to pursue their financial objectives.
Our Target Market
Car Leasing's target market consists primarily of retail customers seeking vehicle leasing solutions through regulated finance agreements.
As an introducing broker, we are responsible for arranging and introducing customers to suitable finance products, including Personal Contract Hire (PCH) agreements, and sourcing vehicles through our approved dealer network.
Our typical customers are financially stable, creditworthy individuals with middle-to-high incomes who either own or rent their homes. While we do not generally expect our customer base to present specific vulnerabilities, we recognise that all customers may experience circumstances that create temporary or ongoing vulnerabilities.
The primary financial objective of our customers is to secure a suitable vehicle leasing solution that meets their needs and circumstances. Our sales process is designed to provide appropriate guidance and support, enabling customers to make informed decisions and achieve their vehicle leasing objectives.
As part of our customer qualification process, we seek to identify any indicators of vulnerability, including difficulties with understanding information, communication barriers, financial hardship, or affordability concerns. Where vulnerabilities are identified, we take appropriate steps to provide additional support.
Defining a Good Customer Outcome
A good customer outcome is achieved when a customer:
Fully understands the nature and features of the finance product they are entering into.
Understands the rights, responsibilities, costs, and commitments associated with vehicle leasing.
Selects a product that is appropriate for their needs, objectives, and financial circumstances.
Receives a vehicle that is suitable for their requirements.
Feels supported throughout the customer journey and after the sale.
We monitor customer outcomes through customer feedback, ongoing reviews, and management oversight to ensure our processes continue to deliver positive results.
Delivering Good Customer Outcomes
To achieve and maintain good customer outcomes, Car Leasing adheres to the FCA Consumer Duty framework.
Cross-Cutting Rules
We are committed to:
Acting in good faith towards retail customers.
Avoiding foreseeable harm to retail customers.
Enabling and supporting retail customers to pursue their financial objectives.
Consumer Duty Outcomes
1. Products and Services
We ensure that the products and services we distribute are designed to meet the needs, characteristics, and objectives of the target market and perform as customers would reasonably expect.
To achieve this, we will:
Maintain a thorough understanding of the products and services we distribute, including their features, benefits, limitations, target markets, and distribution arrangements.
Follow manufacturer distribution requirements and maintain appropriate distribution processes.
Monitor and review sales activity to ensure products are distributed to the intended target market.
Share relevant information and customer feedback with product manufacturers to support ongoing product reviews.
2. Price and Value
We are committed to ensuring that customers receive fair value from the products and services we distribute.
We will:
Ensure fees and charges are fair, reasonable, and proportionate to the service provided.
Clearly disclose all fees, commissions, and remuneration arrangements through our Initial Disclosure Document, quotations, order forms, and customer communications.
Consider the overall cost of products and services throughout the distribution chain when assessing value.
Assess whether fee structures could result in harm to vulnerable customers and take appropriate action where necessary.
Communicate all applicable fees and charges clearly and prominently at each stage of the customer journey.
Share relevant pricing and customer feedback information with lenders and product manufacturers.
Regularly review pricing structures and implement improvements where required to maintain fair value.
3. Consumer Understanding
We support customers in making informed decisions by providing information that is clear, timely, and easy to understand.
We will:
Ensure communications are appropriate for the needs and characteristics of our target market.
Tailor communications where necessary to support customers with vulnerabilities or additional needs.
Present information at the right time and in a format that enables informed decision-making.
Regularly review and test customer communications to ensure they remain clear, accurate, and effective.
Promptly correct any communications that may be unclear, misleading, or inaccurate.
Clearly explain all fees, charges, ongoing costs, and any applicable exit charges.
Highlight relevant customer protections, including access to the Financial Ombudsman Service and any applicable compensation arrangements.
Clearly identify whether a product or service is regulated or unregulated.
4. Consumer Support
We recognise that customers can only achieve their financial objectives when they receive appropriate support before, during, and after the sale.
We will:
Provide accessible support channels and clearly explain how and when customers can obtain assistance.
Ensure post-sale support is at least equivalent to the support provided during the sales process.
Meet the needs of all customers, including those with vulnerabilities or complex circumstances.
Introduce appropriate controls and checkpoints within the sales process to help prevent foreseeable harm.
Make it straightforward for customers to switch products or exit arrangements where appropriate.
Clearly explain how customers can raise concerns or make complaints.
Regularly review customer support arrangements and address identified issues promptly.
Monitor the effectiveness of improvements made to customer support to ensure they deliver the intended customer outcomes.
Ongoing Review and Governance
Car Leasing regularly reviews its Consumer Duty framework, customer outcomes, products, communications, pricing structures, and support arrangements to ensure continued compliance with FCA requirements and to maintain consistently positive outcomes for customers.
What do you do if you feel you've been treated unfairly?
A critical element of TCF is how we handle customer complaints. If in the sad event you believe there is cause to complain, and then please refer to the complaints process found on our web site or click here to see full details.