Hello All,

As you should be aware the regulations regarding the sale and administration of consumer finance will change from the OFT to the FCA tomorrow on the 1st April 2014. These changes are fundamentally the biggest change to the law surrounding consumer finance, since the Consumer Credit Act was introduced.

In essence the changes follow  the 'principles based' regulation philosophy of the current insurance regulation and has similar principles for business, eleven in total. As current FCA regulations, the Governance Culture and Controls principles are at the heart of the framework as the FCA seek to encourage companies to instill the principles from the top down. Meaning that as with insurance regulation, firms are still responsible for their own culture and actions, and providing best practice.

We have a period of six months to comply to the letter of the regulations, however are expected to comply with the spirit of them from the 1st April. Treating Customers Fairly is at the heart of the new regulations, therefore all sales staff must adopt this attitude.

Over the coming months we shall be introducing new systems, practices and processes to ensure that as a company we meet the required regulatory standards. In the meantime please ensure that the following guidelines are being routinely used for ALL finance customers.

1. Fully complete Platinum's CIF, as this captures the customers budget and buying trends.

2. Complete the 'How Funded' and 'Funding Intention' Section below the Part Exchange on our Appraisals.

3. Those that use 4Square, there is a new section called FCA, please complete this as this will recommend budget and product suitability, detailing each product to the customer.

4. Those that do not use 4Square, you must ensure that the finance payments fall in-line with the customers desired budget requirements and that you have checked the suitability of your recommended product. E.g. do not recommend a PCP for those customers that keep their car for longer periods and vice a versa.

5. Try and gauge the customers attitude towards risk whilst recommending finance products, e.g balloon payments.

6. If the customer wishes their monthly payments to be higher than their initial budget, please detail this and ask the customer to sign to confirm. It is also your responsibility to confirm with the customer that they can afford and meet the payments and to ascertain that there is no impending changes in circumstances which may prevent them from doing so.

7. You must explain all the figures and charges fully to the customer, as you currently do with CCD.

8. Ensure that the Platinum CCD Disclosures are being signed for ALL customers. This will detail our status disclosure, that we use a restricted panel of lenders and that we may receive a commission from the lenders. It will also confirm that the customer has read and fully understands the finance terms and conditions.

9. Use the Platinum Finance Guides, as this will help you fully explain the features and benefits of each product and provides a 'route to funding' chart.

10. Ensure that ALL staff have completed their GMAC CCD training (Carly Emails out logins and password from the Head Office New Starter lists), also all new starters have downloaded and completed the Finance Workbooks, found in the F&I section of Platinum Info Central. STAFF MUST COMPLETE THIS TRAINING BEFORE SPEAKING TO CUSTOMERS REGARDING FINANCE - EVEN 0% OR TAKING A SIMPLE PROPOSAL FORM!

Certain finance companies will be changing their documents as off 1st, so please ensure that any outstanding documents you might have at the dealerships are signed up and sent for payment by close of business today, otherwise they may require resigning - especially Santander and Hyundai Car Finance documents.

As a company, we are in a better place than many of our competitors and bigger national motor groups to implement the required changes. Many of the fundamental issues have already ready been address and you should be doing already within your day to day activities, such as Platinum Financial Solutions, Customer Information Forms and POS etc. You must ensure that all these tools are being fully utilized to be compliant. I believe ITC have loaded an IDD document on EDaN to included our finance details.

The changes will also impact on credit advertising so please be mindfully when advertising credit and even sending customer letters if they discuss finance.

Please ensure that this has been discussed with all of your relevant staff and confirm this by email reply.

If you have any questions please do not hesitate in contacting me.

Kind regards

Jason