Treating Customers Fairly Policy (TCF)

At Crystal Lease we are dedicated to treating customers fairly and putting our customers at the heart of everything we do. We are committed to ensuring that the FCA principle of Treating Customers Fairly

(TCF) is applied to all areas of our day to day activities. As a result, TCF an integral part of our culture and is embedded in all aspects of business and values.

What does Treating Customer Fairly (TCF) Mean?

The TCF initiate aims to deliver six outcomes.

Outcome One

Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

Outcome Two

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 Three

Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

Outcome Four

Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Outcome Five

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 Six

Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

TCF is not just about offering the same rates, products and services to all customers or treating every customer the same. It is about you as an individual having choice. You should be offered clear and transparent information, have confidence in the providers you are buying from and be offered suitable products that are appropriate for your needs, based on your individual circumstances. You should have no barriers and know the products and services will work exactly how you were led to believe.

Ways we meet these requirements in the day to day running of our business

  • We continually aim to understand the needs of our clients
  • We ensure that the marketing of our products is appropriately targeted, clear, not misleading and highlights the risks/conditions as well as the key features/benefits of a product
  • We make certain our clients understand the risks associated with our services at the outset of an instruction
  • We keep our clients fully informed in a clear and fair manner that is unambiguous and not misleading
  • We ensure our services are delivered with clarity and transparency and do not contain hidden conditions or rely on complex technical definitions
  • Any advice provided will be appropriate and take into account the customer’s individual needs and circumstances
  • We take our clients’ privacy seriously and ensure that our staff are aware of and follow rules in relation to data protection to ensure that clients’ details are kept secure and confidential
  • We take any complaint seriously and will deal with any complaints promptly and make improvements to our operations where required

What is expected of you?

In order to deliver the best possible service, we rely on you (the Customer) to also play your part. An efficient service relies as much on capable and confident consumers as it does on the firms who are committed to treating customers fairly. When dealing with us, we expect you to;

  • Engage with us properly and provide accurate information
  • Raise questions if you are uncertain about any aspect of the product or service
  • Read advertisements and other material carefully
  • Read any suitability letter and ensure that it properly reflects the discussion
  • Use cooling off periods to consider whether to go ahead

  • Review your financial needs on a regular basis and consider taking further advice when circumstances change
  • Acknowledge that some financial products or services being provided may involve market risk for the buyer, such as stock movements and interest rate rises
  • Complain to us if you perceive unfair treatment and give us the opportunity to resolve your complaint in a timely manner

Consumer Duty and Defining a “Good Customer Outcome”

Introduced by the Financial Conduct Authority in 2023, the Consumer Duty sets a higher expectation for the standard of care that firms give customers. Firms are required to comply with the Duty’s cross-cutting rules by acting in good faith towards customers, avoiding causing foreseeable harm to customers and enabling and supporting customers to pursue their financial objectives.

Crystal Lease’s target market is categorised as Retail Customers with the following common traits:

As an introducing broker we are responsible for arranging and introducing the customer to the product i.e. the finance agreement. We also source vehicles from one of our approved supplying dealers. Our target market is typically financially stable, credit worthy middle to high income earners who are either in their own or rented accommodation. As such we believe are (unlikely to present a specific vulnerability.

We accept all customers are susceptible to event driven vulnerabilities”)

The financial objective of the client is to find a suitable finance product that enables them to lease a vehicle. Our Sales process is such that we can guide and support a consumer towards their objects of leasing a vehicle in a way that is suitable to their needs.

In our sales process we will seek to identify any likely consumer vulnerabilities such as the inability to understand, read, communicate, or any financial or affordability issues. We seek to identify vulnerability/affordability concerns though our customer qualification process.

A good customer outcome is one where a client/consumer proceeds with full understanding regarding the nature of the product (financial product i.e., a Personal Contract Hire Agreement) and the specifics of leasing a vehicle. In addition to this, this customer receives a vehicle that is suitable for their needs.

We endeavour to validate positive customer outcomes through our customer follow up calls

In order to achieve good customer outcomes, we adhere to the following:

Cross Cutting Rules

Crystal Lease recognises that delivering good customer outcomes will be achieved through adhering to the three cross-cutting rules of Consumer Duty which are to:

  • Act in good faith towards retail customers.
  • Avoid foreseeable harm to retail customers; and
  • Enable and support retail customers to pursue their financial objectives.

Consumer Outcomes

Crystal Lease will ensure that it adheres to the four Consumer Duty Outcomes, which are:

1. Products and Services:

We will ensure that the products and services we distribute meet the needs, characteristics and objectives of our customers and perform as they are expected to.

As a distributor of products and services we will:

  • Understand the features, benefits and limitations of the products and services we distribute, along with who the target market is and what the distribution channels are, to enable us to sell them in an appropriate and correct manner. Therefore, we must make sure that we have obtained all the information we need to fully understand and appropriately sell them to consumers.
  • Have appropriate distribution arrangements in place for each product and service that we distribute, which will be in line with guidelines set out by the manufacturer.
  • Monitor and review how products and services are being sold to make sure that they are being sold to the identified target market and are distributed in the correct way.
  • Share relevant information with manufacturers to support their review of products and services.

2. Pricing and Value:

We will ensure that the products and services that we distribute offer fair value for clients.

We will ensure that:

  • Fees are fair and proportionate to the cost of providing or delivering the product or service and that we can justify the value of the fees we charge. We ensure that we explain clearly in our initial disclosure document our upfront fees and remuneration. This is also clearly advised in the customer order forms.
  • We review whether there are other charges levied throughout the distribution chain which might mean that the overall cost of the product or service does not provide fair value to the customer.
  • All fees and charges applicable to our products and services are clearly and fully communicated to customers at point of enquire, on our website www.crystallease.co.uk, the IDD, the quotation including key facts, the order from and through discussion/ qualification with our Sales Executives.
  • We share relevant information with manufacturers in relation to pricing, including feedback from customers. We have regular review meetings with our funders and share information on an ad hoc basis.
  • Review any actions take in relation to pricing and value to make sure that these changes achieve the required outcomes.

3. Consumer Understanding:

We will ensure that we support our customers by helping them to make in informed decisions about products and services. Customers will be given the information they need, at the right time and presented in a way that they can understand.

We will:

  • Support our customer’s understanding by making sure that our communications are likely to be understood by our “average” customer and are provided at the right time, so that they can make properly informed and timely decisions.
  • Tailor communications, considering the characteristics of the customers who we intend to receive these communications, including customers with characteristics of vulnerability, the complexity of the product or service and the manner in which the information will be communicated.
  • Monitor, test and adapt communications on a regular basis and make sure that where information is unclear, misleading or incorrect, that action is taken to amend them.
  • Review any actions take in relation to customer communications to make sure that these changes achieve the required outcomes.
  • Make sure that all fees and charges, including any ongoing charges or exit charges, are clear and prominent in communications with customers.
  • Make sure that the protections applicable to products and services or customers, such as the Financial Services Compensation Scheme protection and right of referral to the Financial Ombudsman Service are clearly highlighted.
  • Be clear about whether a product is regulated or unregulated.

4. Consumer Support

We recognise that customers can only pursue their financial objectives when we provide them with the level of support, they need to use the product or service they have bought.

We will provide customers with support channels which allows them to use products and services as expected and enjoy their benefits.

This includes:

  • Making how and when customers can access support clear to them.
  • Providing post-sale support that is as good as pre-sale support.
  • Meeting customer’s needs, including accommodating customers who are dealing with complex issues, or those who are vulnerable.
  • Including appropriate “friction” points in the sales process which can mitigate the risk of harm to a customer and result in good outcomes.
  • If a product or service is no longer suitable for customers, make it easy for them to switch to another product or exit.
  • Being clear about how they can make a complaint when things go wrong.
  • Carrying out reviews of customer support levels on a regular basis and addressing any issues identified in a timely manner.
  • Reviewing any actions take in relation to customer support to make sure that these changes achieve the required outcomes.

WHAT TO DO IF YOU HAVE A COMPLAINT

If you wish to register a complaint, please contact us:

Write to: Alastair Walker
Crystal Lease
The Old Barn,
Cupola Court
Spetchley
Worcestershire 
WR5 1RS

Telephone: 01905 731772

Email: alastair@crystallease.co.uk

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service or the BVRLA.

A copy of our complaints procedure is available upon request or on our website, www.crystallease.co.uk