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Customer Risk Assesment

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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’.

RISK: Client product knowledge

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.

RISK: Misleading promotions

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.

RISK: Vulnerable Person

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

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

Management and Assesment to Risks

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).

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 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. 

Responsibilities of 21st Century Motors Limited

  •  To ensure staff are aware of this policy and are adequately trained 
  • To support individuals in relation to identified risk and vulnerability 
  • To provide means of reporting any instance where they believe that a client might be in vulnerable circumstance. 
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21st Century Motors - Vehicle Leasing Specialists

Email :

Telephone : 03333 70 2121

Company Address :
21st Century Motors Limited
16a Cann Bridge Street
Higher Walton

Member number 2223

21st Century Motors Limited are a credit broker and not a lender, we are authorised and regulated by the Financial Conduct Authority. Registered No : 682528

Registered in England & Wales with company number : 08901938 | Data Protection No : ZA105350 | VAT No : 214205361

Registered Office : 16a Cann Bridge Street, Preston, PR5 4DJ

Disclaimer: All vehicle images and descriptions are for illustration and reference purposes only, all vehicle leases are subject to credit approval and subject to change at any time. E&OE.

Copyright © 2020 21st Century Motors Limited, All rights reserved.