1. Introduction

My Credit Score Ltd is committed to delivering good outcomes for retail customers in accordance with the Financial Conduct Authority (FCA) Consumer Duty. This policy sets out our approach to ensuring that customers receive fair value, clear communication, and appropriate support while using our services.
This policy also applies to all trading styles of My Credit Score Ltd, including but not limited to CarFinance4U, and reflects our commitment to delivering good outcomes across all brands under our control.

2. Scope

This policy applies to all employees, directors, contractors, and third-party service providers of My Credit Score Ltd and its trading styles, including CarFinance4U. It covers all aspects of our business operations that impact retail customers, regardless of the brand or trading style through which those customers interact with us. For the purposes of this policy, "My Credit Score Ltd" refers to the company and all its trading styles, including but not limited to CarFinance4U.

3. FCA Consumer Duty Principles

The FCA Consumer Duty, as outlined in PRIN 2A, establishes higher standards of consumer protection across financial services. My Credit Score Ltd adheres to the following principles:

• Acting in Good Faith: Ensuring all interactions with customers are fair, honest, and transparent.
• Avoiding Foreseeable Harm: Identifying and mitigating risks that could cause harm to customers.
• Enabling and Supporting Customers: Providing the necessary information and assistance to help customers make informed financial decisions.
• Delivering Good Outcomes: Ensuring that customers receive products and services that meet their needs and offer fair value.

4. Governance and Oversight

• The Board of Directors is responsible for overseeing compliance with the Consumer Duty.
• Senior Management ensures that business practices align with regulatory expectations.
• Regular Consumer Duty reviews are conducted to assess the effectiveness of our approach.

Effective product governance is crucial to ensure that products and services meet the needs of identified target markets and function as expected. According to the FCA's Product Intervention and Product Governance Sourcebook (PROD), firms should have robust systems and controls in place throughout the product lifecycle.

To align with FCA expectations, My Credit Score Ltd will:

• Target Market Identification: Clearly define and document the target market for each product or service, ensuring offerings are designed to meet the specific needs, characteristics, and objectives of that market segment.
• Product Testing: Conduct rigorous testing to ensure products perform as intended and deliver expected outcomes. This includes assessing product features, terms, and charges to confirm they align with customer needs and provide fair value.
• Ongoing Monitoring: Regularly monitor products and services to verify they continue to meet customer needs and function as intended. This involves collecting and analysing data on customer outcomes and taking corrective action if issues are identified.
• Distributor Oversight: Ensure that distributors understand the target market and product features, providing them with adequate information to promote products appropriately.

5. Product and Service Design

• Products and services are designed with customer needs in mind.
• Testing and monitoring ensure that products provide fair value.
• Vulnerable customers are considered in product development and service delivery.

Note: Product offerings may differ across trading styles to reflect the specific needs and characteristics of the respective target markets. These differences are documented internally through our product governance framework to ensure alignment with the Consumer Duty outcomes.

6. Price and Value

The FCA's Consumer Duty emphasizes that firms must ensure the price a customer pays for a product or service is reasonable relative to the benefits received. This is outlined in PRIN 2A.4 and further explained in the FCA's guidance on fair value assessments.

To adhere to this principle, My Credit Score Ltd will:

• Fair Value Assessments: Conduct comprehensive assessments to evaluate whether the total price paid by customers is proportionate to the benefits derived from the product or service. This includes analysing all associated costs and charges.
• Benchmarking: Compare products and services against similar offerings in the market to ensure pricing is competitive and offers fair value.
• Transparent Communication: Clearly communicate pricing structures, fees, and charges to customers, ensuring they understand the cost-benefit balance of the product or service.
• Regular Reviews: Periodically review pricing and value propositions to ensure ongoing fairness and alignment with customer outcomes, adjusting as necessary.

7. Communications and Transparency

• Clear, fair, and non-misleading information is provided to customers.
• Communications are tailored to customer needs and understanding levels.
• Key terms, risks, and costs are disclosed in an accessible manner.

We will communicate with our customers in a way that enables them to make informed decisions about the product/service on offer. Information will be provided at the correct moments in the journey and be presented in a way that considers the needs of our target market. All communications and prompts will comply with the principle of ‘clear, fair and not misleading’.

8. Customer Support and Vulnerable Customers

The support provided by our firm will meet the needs of the customer throughout the relationship. We will not set unreasonable barriers for the customer to access products or services which our firm offers. 

Where our firm declines to provide a customer with a particular product or service, we will use our knowledge of the reasons for why individual customers get declined to consider whether there is information or support that we can provide to help the customer pursue their financial objectives.

As a business, we understand the need for us to monitor trends and understand how vulnerable characteristics may change over time within our target market and customer base.  We will capture management information to monitor for trends, learn from experiences, and improve our support to customers.

We aim to ensure:

• Adequate support is provided to assist customers in decision-making.
• Additional provisions are in place for vulnerable customers to ensure their needs are met.
• Complaint handling processes align with FCA requirements to resolve issues efficiently and fairly. Please refer to our Complaints Policy.

9. Monitoring and Reporting

• Customer outcomes are regularly reviewed through data analysis and feedback.
• Internal reporting mechanisms ensure issues are escalated and addressed.
• Compliance with the Consumer Duty is assessed through periodic audits.

10. Training and Awareness

All staff receive Consumer Duty training to understand their responsibilities. Ongoing training updates ensure compliance with evolving FCA expectations.

11. Policy Review

This policy will be reviewed annually or as required to reflect regulatory updates and business developments.

For further information, please contact the Compliance Team.