Complaints Policy (Regulated Activities)

1. Objective 

• To ensure that all complaints related to the regulated activities of credit broking are handled promptly, fairly, and effectively, in compliance with the FCA’s Dispute Resolution (DISP) rules and guidance, Consumer Duty requirements, and Treating Customers Fairly (TCF) principles.

2. Key Components of the Policy

• The key principles and component which underpins this policy are: 
• Accessibility: Make the complaints process easy to access and understand.
• Fairness: Treat all complaints fairly and impartially.
• Timeliness: Resolve complaints promptly and within regulatory timeframes.
• Transparency: Keep customers informed throughout the complaint process.
• Learning: Use complaints as a learning tool to improve services and prevent recurrence.

3. Definition of a Complaint

• A complaint is any expression of dissatisfaction, whether oral or written about the provision of, or failure to provide, a financial service, which alleges that the complainant has suffered (or may suffer) financial loss, material distress, or material inconvenience.

 

4. How to Make a Complaint

• Customers can make a complaint through any of the following channels:

In Person / By Post:        Car-Holics Ltd,

Regus
6-9 The Square
Stockley Park
Uxbridge
Hillingdon
UB11 1FW.

By Phone:   07990280083

By Email:     [email protected]

 

5. Handling Complaints

• Step 1: Acknowledgment

• If we are able to resolve a complaint within 3 business days, we will issue the complainant with a summary resolution letter detailing our resolution and advising the customer of their right to refer the complaint to the Financial Ombudsman Service (FOS).

• For every complaint received that cannot be resolved within 3 business days, we will issue the complainant with an acknowledgement letter within 5 business days, along with a copy of our complaints procedure.

• Step 2: Investigation

• If the Firm identifies that customers might have suffered harm but have not yet complained, we will proactively contact the affected customers immediately to inform them of the potential issue. We will provide clear information about the nature of the harm and offer appropriate remedies, such as compensation or corrective actions, even if a formal complaint has not been made. This approach ensures that we address issues promptly and maintain trust with our customers.

• If we believe another Firm may be solely or jointly responsible for a complaint, we will promptly forward the complaint details to the relevant Firm. This will include providing the customer with the complaint contact details of the other Firm (taken from the FCA’s Register) and advising them of the referral. If our Firm jointly responsible for a complaint, we will coordinate with the other Firm and their complaints contact to address the complaint, ensuring that the customer receives a comprehensive and fair resolution. Both Firms will work together to investigate and resolve the issue, keeping the customer informed throughout the process.

• Gather all relevant information and evidence from the customer and internal records. Analyse the cause of the complaint

• Conduct a thorough and impartial investigation of the complaint. However, if after 4 weeks we are not in a position to resolve a complaint, we will issue the complainant with a 4 week holding letter advising why we are not in a position to resolve the complaint.

 

• Step 3: Resolution

 

• Make a fair and reasonable decision based on the evidence gathered with an aim to resolve complaints in a timely manner within 8 weeks as a maximum.

• Inform the customer of the outcome in writing, providing clear reasons for the decision. However, if we cannot resolve a complaint within 8 weeks then we will remind complainants of their right to refer their complaint to the FOS where applicable.

• If the complaint is upheld, offer appropriate remedies such as an apology, corrective action, or compensation.

• Complaints received outside the time limits for referral to the Financial Ombudsman Service will still be thoroughly investigated by the Firm. We will inform the customer that their complaint is outside the FOS time limits but will still seek to resolve the issue fairly and transparently. We will document all actions taken and maintain a record of the complaint and its resolution in our complaints log.

• Step 4: Final Response

• Final Response Letter: Issue a final response letter within eight weeks of receiving the complaint. This letter will:

• Summarise the complaint.

• Outline the investigation process.

• State the Firm’s decision and any offer of redress.

• Provide information on the customer’s right to refer the complaint to the Financial Ombudsman Service (FOS) if dissatisfied.

• All complaints received and resolved will be recorded so we are able to identify trends through Root Cause Analysis and make the necessary business changes to improve the services to our customers and prevent repeat occurrences.

 

6. Timeframes

 

• We aim to resolve complaints as quickly as possible, and in any event, ensure all complaints are resolved within eight weeks of receipt.

 

7. Summary Resolution Communication (SRC) Template

• Car-Holics Ltd will develop and maintain a formal template for the Summary Resolution Communication (SRC) that will be issued to complainants in appropriate cases. This template will explicitly include:’

• Confirmation that a complaint has been received and logged.

• The Firm’s view that the complaint issue has been resolved or the outcome of the investigation.

• Clear information on the complainant’s right to escalate the matter to the FOS, including the six-month time limit for referral and the FOS contact details.

• Waiver of the Six-Month FOS Referral Time Limit

 

In exceptional circumstances, such as serious illness, bereavement, or other significant personal difficulties, Car-Holics Ltd will consider waiving the six-month time limit for referring complaints to the Financial Ombudsman Service. This commitment will be:

 

• Explicitly incorporated into the Complaints Policy.

• Reflected in the SRC and other complaints correspondence templates to inform complainants of this possibility.

• Applied on a case-by-case basis, with flexibility exercised fairly and transparently.

 

8. Support for Vulnerable Complainants

• Car-Holics Ltd is committed to identifying and supporting vulnerable complainants during the complaints process by:

• Training staff to identify signs of vulnerability early in the complaints interaction.

• Offering accessible formats, clear and simple language, and additional time to understand and respond to communications.

• Allowing complainants to appoint trusted third parties such as family members, carers, or debt advisors to act on their behalf. Such representatives will be fully engaged in the process with the complainant’s consent, provided access to all relevant information, and treated with respect throughout the complaints procedure.
  • Identification of vulnerable complainants

• In addition to general staff awareness, the Firm will identify vulnerable complainants by:

• checking any existing vulnerability flags held on the customer record/CRM (where applicable);
• using complaint-intake prompts at the start of the interaction to identify support needs (e.g., language needs, preferred communication channel, accessibility needs, any health or significant life event impacting communication);

• recognising vulnerability cues during the interaction (e.g., distress, confusion, difficulty articulating the issue, repeated contact or escalation, inconsistent understanding of key facts).

• Additional steps / adaptations (support measures)

 

• Where vulnerability is identified or suspected, the Firm will take proportionate steps to support the complainant, including:

• allowing extra time and offering call-backs at suitable times;
• using the complainant’s preferred channel (phone/email/post/in-person) and providing simplified written summaries in plain English;
• offering accessible formats and, where needed, slower pacing and confirmation questions to check understanding;
• allowing the complainant to appoint a trusted third party (e.g., family member, carer, debt adviser) to support them, subject to the complainant’s consent and appropriate verification;
• clear signposting to the appropriate escalation route (including FOS referral rights and time limits), with additional explanation where needed.

• Recording (complaints log)

 

• The complaints log will include a vulnerability flag (where identified), the vulnerability driver type (where disclosed), the support/adaptations provided, and a record of tailored communications so the Firm can evidence fair treatment and consistent outcomes for vulnerable complainants.

9. Customer Rights and Further Recourse

• FOS Referral: Inform customers of their right to refer the complaint to the FOS if they are not satisfied with the Firm’s final response or if the complaint is not resolved within eight weeks. Provide the FOS contact details:

 

Financial Ombudsman Service

Exchange Tower,

London,

E14 9SR

0800 023 4567

www.financial-ombudsman.org.uk

10. Record Keeping

 

• Maintain detailed records of all complaints, including:

• Complaint details and customer information.
• Correspondence and communications.
• Investigation notes and evidence gathered.
• Final response and outcome.

• Retain complaint records for a minimum of three years from the date of resolution.

 

11. Management Information (MI) and Reporting on Complaints

• Car-Holics Ltd will collect and report comprehensive complaints-related MI to senior management, including:

• Number of complaints received within reporting periods.
• Categorisation of complaints by type and root cause.
• Details of complaint resolutions, including upheld or rejected status and remedies provided.
• Average and maximum time taken to resolve complaints.
• Identification of recurring issues and emerging risks.

• Consumer Duty complaints MI (monthly) and governance

 

• In addition to the above, the Firm will produce Consumer Duty-focused complaints MI monthly, including:

 

• acknowledgement timeliness (e.g., % acknowledged within 5 business days where not resolved within 3 business days);
• final response timeliness (e.g., % issued within 8 weeks) and any cases exceeding 8 weeks (with reasons);
• uphold and part-uphold rate;
• root cause categories and repeat issue themes;
• number of complaints involving vulnerable customers and the vulnerability support measures applied;
• redress / remediation issued (type and value where applicable);
• referrals / escalations (including referrals to the Financial Ombudsman Service where applicable).

Review cadence and escalation

• The SMF29 will review complaints MI monthly and record any actions taken (e.g., root cause analysis, process changes, document/script updates, staff coaching). A quarterly summary will be provided to Directors for oversight. MI will trigger process change where themes recur, response times deteriorate, or where complaints indicate customer misunderstanding (including misunderstandings relating to commission disclosure and/or total cost of credit).

• This MI will be reviewed regularly (e.g., monthly or quarterly) and used to:

• Inform risk management and compliance oversight.
• Drive operational improvements to prevent recurrence of issues.
• Support ongoing staff training and quality assurance initiatives.

• Regular Reviews: Conduct regular reviews of complaints to identify trends, root causes, and areas for improvement.

• Management Reporting: Report complaints data to senior management regularly, including the number of complaints, resolution times, outcomes, and any systemic issues identified.

• The Firm understands that it is required to report eligible complaints data to the FCA as per the FCA’s regulatory requirements via the CCR007 and CCR009 regulatory returns as per SUP 16.12.29CR. We will ensure that all complaints are recorded and reported accurately in accordance with FCA guidelines, adhering to the specified reporting timelines. As we are not a full permission consumer credit Firm, we will be following DISP 1.10.1R (4).

• Additionally, as per DISP 1.10A.1(4), if the Firm receives 1000 complaints or more, then we understand that we must publish the total number of complaints received via the Complaints Publication Report set out in DISP 1 Annex 1B R. The Complaints Publication Report will be published on our website within the time limit as per DISP 1.10A.3R(4) – which will be after our ARD.

• As per DISP 1.10A.4R we also understand that confirmation of the Complaints Publication Report must be notified to the FCA via email to [email protected] immediately upon publication of our complaints data confirming that it has been published on our website.

 

12. Continuous Improvement

 

• Use complaints as a feedback mechanism to improve services, products, and customer interactions.

• Regularly review and update this Complaints Policy to ensure it remains compliant with FCA rules and reflects best practices.

 

13. Training

• Provide regular training to all staff on the complaints handling process, Consumer Duty requirements, and TCF principles.

• Regularly assess staff competence in handling complaints to ensure high standards are maintained.

 

 

STATEMENT OF COMMITMENT

 

Car-Holics Ltd is fully committed to handling all complaints related to its regulated credit broking activities promptly, fairly, and effectively. We recognise that a transparent, accessible, and customer-focused complaints process is essential to maintaining trust and ensuring compliance with the FCA’s Dispute Resolution (DISP) rules, Consumer Duty, and Treating Customers Fairly principles.

Our Firm pledges to provide clear information and support to all complainants, including vulnerable customers, and to resolve complaints within regulatory timeframes wherever possible. We will maintain comprehensive records, perform thorough investigations, and communicate outcomes clearly and respectfully.

Car-Holics Ltd is dedicated to using complaints as a vital feedback mechanism to drive continuous improvement in our services, products, and customer experience. We will ensure that all staff receive appropriate training and that complaints management remains an integral part of our culture of compliance and customer care.