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All Vehicle Contracts Ltd

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Compliance Your Rights - Customer Risk Assessment

All Vehicle Contracts Compliance Your Rights - Customer Risk Assessment
  • Customer Risk Assessment

    Terms:

    All Vehicle Contracts Limited may also be referred to herein as ‘We’ ‘Company’ ‘AVC’ ‘Us’ ‘Our’ and ‘All Vehicle Contracts’.

    Customers and potential Customers may also be referred to herein as ’You’ and ‘Clients’.

    Customer Risk Assessment

    Customer Risk Assessment

    Problem:

    Risk Client Product  Knowledge

    Not understanding how experienced and knowledgeable Clients are in terms of financial products and services We offer, and if they have adequate assessment of affordability and clarity in their understanding of the contract.

     AVC solution - how we will deal with this:

    Having identified areas where We consider that problems may arise by each of the potential situations, we have set out and implemented controls to monitor our sales process, and gather feedback from our Clients and from ourselves, which will be considered at regular intervals  our controls consist in providing adequate information, so clients can make an informed decision as follows.

    With Initial contact quotation we provide a full and detailed  (IDD) Initial-DisclosureDocument that provides links to Key information that relate to problem areas. We also insure that clients are provided with all the relevant key information on the products relevant to the clients quotation such as Personal Contract Hire and PCP Finance.  

    Misleading leasing promotions

    The risks misleading leasing promotions could pose to consumers in our opinion are that the general low pricing in some instances are not in consumers best interests. The risk in our opinion is that the consumer can presume that the advertised price as the total price they pay without giving full consideration to the total affordability and there contractual obligations.

    AVC solution - how we will deal with this:

    AVC promote a clear and transparent method of offering vehicle promotions that are 'clear, fair and not misleading' and not miss lead consumers by price offering alone. For further information please view our Financial-Promotion Policy

    Vulnerable Persons Policy

    The aim of this Policy is to outline the practice and procedures for staff who work for the Company to contribute to the prevention of detriment to Clients who find themselves in vulnerable circumstances. The Policy covers all staff areas of work when dealing directly with the Customer.

    Definition of Vulnerable

    We consider a vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, with the most significant detriment occurring when “through the use of consumer credit [they may] get into unmanageable or problem debt.”

    The nature of AVC’s business makes it unlikely that new Customers will be in vulnerable circumstances or that the nature of their circumstance may limit or remove the availability of facilities to the extent that the Company might be unable to accommodate their requirements.

    However, we remain mindful of the potential for enquiry by such Clients and the potential for any change of circumstance in respect of existing Customers.

    Identification of clients in Vulnerable Circumstances

    • Mental capacity deficiencies – The FCA provides clear guidance on the identification of mental capacity issues in their Handbook under   CONC 2.10.8.
    • Underbanked, Financially Unsophisticated –can be identified through interview and credit profile
    • Low income – can be identified through interview and credit profile
    • In financial distress - can be identified through interview and credit profile

    Assessment and Management Risks

    AVC Limited will not discriminate against Clients in vulnerable circumstances by way of adjustment to fees or any refusal to assist purely on the grounds of the Client’s circumstance (unless that circumstance creates a situation which is likely to lead to detriment or a risk that removes the availability of any finance or funding facility).

    Capacity Issue Risk Mitigation

    This section illustrates mitigation actions for Clients with mental capacity deficiencies (for the avoidance of confusion, “competent person” means an individual without the limitation presented by the Client):

    • Problem: Language - Client cannot fully understand important features of their agreement with AVC Limited, their recommendation or the consequences of that recommendation.

    o   Solution: Client to instruct a competent person to act as interpreter.

    • Problem: Other communication problem created by the disability as detailed above from a Client to instruct a competent person to act as interpreter.

    o   Solution: Client to nominate a reasonable communication medium suitable for their disability.

    • Problem: Mental incapacity (temporary) such as intoxication, mental illness, and/or both of the aforementioned, plus the potential for reckless disregard for consequence .

    o   Solution: Client to instruct a competent person to communicate on their behalf. Legal agreement must be reached outside of any period of incapacity. The Client should be encouraged to seek independent professional advice.

    • Problem: If legal agreement cannot be reached outside of any incapacity.

    o   Solution: Client must provide “Power of Attorney” for a competent individual to act on their behalf.

    • Problem: Mental incapacity (Permanent) as detailed in temporary mental incapacity section plus the possibility that any agreement might be unenforceable as a result of known.

    o   Solution: Client must provide “Power of Attorney” to a competent individual to act on their behalf.

    Responsibilities of All Vehicle Contracts Limited

    a. To ensure staff are aware of this policy and are adequately trained

    b. To support individuals in relation to identified risk and vulnerability

    c. To provide means of reporting any instance where they believe that a client might be in vulnerable circumstance.

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