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QUARTER 3 RATE REVIEW CURRENTLY IN PROGRESS - all quotes to be validated
21st Century Motors Limited referred to herein as ‘We’ ‘Company’ ‘AVC’ ‘Us’ ‘Our’ and ‘21st Century Motors’. Customers and potential Customers may also be referred to herein as ’You’ and ‘Clients’.
Clients may not be experienced and knowledgeable with our services and financial products and if they have a clear understanding of the contracts and affordability
How we deal with this...
We have set implemented processes that detail full and detailed information regarding the services we provide
On every quote and order process email, we include a link to details about the product they have chosen along with the initial disclosure document.
The customer may read promotions and understand the price on screen to be the total amount payable.
How we deal with this...
21st Century Motors advertise clear pricing with the structure broken down to show the plan on offer. For more information on how we promote our offers we have a Financial Promotion Policy.
21st Century Motors aim to prevent detriment to clients who find themselves in vulnerable circumstances.
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.”
It is unlikely that our customers will be in vulnerable circumstances due to the way we conduct business, or their circumstance will limit or remove the availability to the services that we provide.
We always remain aware that non vulnerable customers may become vulnerable in the future so we always ask for confirmation that if there are any future changes to circumstances due to happen
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
We will not discriminate against Clients in vulnerable circumstances. Refusal or adjustment to fees purely on the grounds of the Client’s circumstance will not happen (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).
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 21st Century Motors, their recommendation or the consequences of that recommendation.
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.
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 .
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.
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.
Solution: Client must provide “Power of Attorney” to a competent individual to act on their behalf.