How Complaints Enter the System
One primary complaint at a time. If the customer has multiple concerns, the most pressing one drives routing. Vehicle complaints always take priority. Secondary concerns are captured as a flag and followed up when the primary complaint resolves.
Customer Issue Form
Vehicle + Collected → SQ Complaint
Full triage fields populate. Acknowledgement letter fires. Handler assigned. Record lands in SRC > Triage Complaint with everything filled in.
Vehicle + Not Collected → Unwind
Pre-collection cancellation. Unwind Category auto-sets to Non-Collection. Retentions picks it up for a retention attempt before processing the unwind.
Dealership's Service → Dealer Forwarding
Not a regulated complaint against CL365. Forwarded to the dealer with a notification email. If unresolved, customer can escalate to a regulated complaint.
CL365's Service → Regulated Complaint
FCA-regulated under DISP. 8-week clock starts. Acknowledgement letter fires immediately. Full investigation with detriment and liability assessment.
When the primary complaint closes, an automated task fires if secondary concerns were flagged: "Primary complaint resolved. Customer also raised concerns about [X]. Confirm whether a separate complaint is needed." The handler calls the customer. If yes, a new case is logged. If no, the task is closed.
SQ Complaint Flow
Pipeline 1 - SRC Early Resolution
Pipeline 2 - Investigation
Post-6-month complaints: If the vehicle was purchased more than 6 months ago, a different evidence request fires. It explains that supporting diagnostics are needed because the burden of proof shifts to the customer. See Section 5 for full details.
The assessment uses the CRA Rights Matrix to determine the customer's rights based on vehicle age from sale. This shapes whether a repair, reject, or evidence-led path applies.
Pipeline 3 - Upheld - Pending Resolution
DOW Enforcement: The dealer email now includes: vehicle must not be returned to dealer until repair/rejection is agreed. If dealer disputes and requests an IER, dealer is liable for the IER cost. Recovery cost liability sits with the dealer per the DOW.
The complaint handler has exhausted their ability to negotiate with the dealer. This stage hands the file off to Peri, who takes over the dealer negotiation. A task is created specifically in Peri Bromley's activity feed. The file doesn't leave the pipeline - it just moves to a stage owned by Peri.
DOW Enforcement: If the dealer requested the IER as part of their dispute, the dealer is liable for the IER cost. Vehicle must remain at its current location - recovery cost liability sits with the dealer per the DOW.
⤷ Auto-creates Unwind record → Awaiting Funds > ROA Processing (skips retention)
⤷ Auto-creates Unwind + Legal records
Pipeline 4 - Complaint Closed
Each closure stage applies its own tag on entry automatically. Withdrawn (new) - customer withdrew the complaint, no form, manual move. Duplicate (new) - duplicate complaint identified, no form, manual move. Both are tagged for reporting.
Every stage transition is driven by a form submission. When a handler completes a form, the system knows what happened and what to do next. Fields populate automatically. Emails fire automatically. Tags apply automatically. Tasks create automatically. If a handler skips a form and manually drags a record to a different stage, the automations won't fire and the data won't be captured.
Service Complaints Flow
Pipeline 1 - Dealer Forwarding
Pipeline 2 - Regulated Complaint (DISP)
1. Has the customer experienced genuine detriment? Financial loss, distress and inconvenience, or both. No detriment = cannot uphold, even if we made a mistake.
2. Is CarLoans365 responsible? Did we cause it through our actions or inaction? Customer may have a real problem, but if the cause sits with the dealer, the lender, or the customer - it's not our liability.
Both must be "yes" for a complaint to be upheld. This is what FOS will scrutinise.
CRA Rights by Vehicle Age
Within 30 Days
Did the fault exist at sale? Short-term rejection may apply. Highly sensitive to delays. If rejection/unwind is accepted, hand off promptly to Retentions for implementation.
Agent focus: Immediate action. Diagnosis and dealer's willingness to accept return or repair. Fast-track to manager if dealer disputes.
31 - 90 Days
Still within first 6 months. Dealer has one opportunity to repair or replace. Burden of proof is on the dealer to show the fault wasn't present at sale.
Agent focus: Book the repair. Manage expectations that the dealer leads the fix. Escalate if repair fails or takes an unreasonable amount of time.
91 Days - 6 Months
Burden of proof generally still rests with the dealer. Wear and tear becomes a factor. Independent Engineer Report often required if dealer disputes liability.
Agent focus: Gather diagnostic evidence and wear & tear assessment. IER if the dealer cites driving style or wear.
Over 6 Months
Burden of proof shifts to the customer. They must evidence that the fault existed at the point of sale. Move to a structured evidence-led path. Send the post-6-month customer help guide immediately.
Agent focus: Set clear, supportive expectations. Explain what evidence is needed. Do not authorise IER spend unless directed by Complaints Manager.
Post-6-Month / IER Process
Handler selects "Post 6 Month" on the SRC Complete form. The system: sends the branded 6 Months+ IER Required email to the customer (explains CRA position, lists recommended inspection companies - ACE, Scotia, IVIS, DEKRA - tells them to send the report to complaints@carloans365.com). Applies the 6 Months+ IER Required tag. Closes the case into No Evidence pending the customer providing their independent inspection report. When the customer provides the IER, the handler reopens and moves to Investigation.
The evidence that matters most:
| Evidence Type | Why It Helps |
|---|---|
| Independent diagnostic report | Shows exactly what the fault is, likely cause, and whether it was present at sale |
| Fault codes / mechanic's notes | Technical details of the problem |
| Photos or videos | Visual confirmation of the issue |
| Service and MOT history | Shows the car has been maintained - rules out neglect |
| Repair quotes or bills | What's needed to fix it and at what cost |
| Breakdown / recovery reports | Confirms what happened if the car failed on the road |
Unwind Flow
SQ Complaint → Unwind: When a complaint closes as Resolved Rejection or Unresolved Rejection, the file moves to Unwind > ROA Processing. It skips Investigation & Retention entirely because the complaint has already been fully investigated.
Legal Escalation Flow
The pattern is email → call → email → call, alternating every day for 14 days. Emails are automated, calls are manual. The combination of both is the pressure.
Unwind → Legal: When dealer funds aren't received after the 5-day chase period, or there's an outstanding shortfall, the handler moves the file to Legal Escalation > Debt Triage. Temp ban fires automatically. All data carries across.
Communications Reference
SQ Complaint Flow - Automated
| Template | Fires When | To |
|---|---|---|
| Complaint Acknowledgement Letter | Triage Form submitted | Customer |
| SRC Initial Dealer Notification | Entry to Awaiting Dealer Response | Dealer |
| 6 Months+ IER Required | SRC Complete with "Post 6 Month" | Customer |
| Evidence Request Email | Entry to Awaiting Evidence | Customer |
| Dealer Upheld Notification | Assessment = Upheld (includes DOW wording) | Dealer |
| Dealer Dispute Rejected / Indemnity | Dispute = Remains Upheld | Dealer |
| Final Response (Not Upheld) | Closure as Not Upheld | Customer |
| Final Response (Resolved) | Closure as Resolved | Customer |
Service Complaints - Automated
| Template | Fires When | To | DISP? |
|---|---|---|---|
| Dealer Forwarding Notification | Forwarding Form submitted | Dealer | No |
| Regulated Complaint Acknowledgement | Regulated Log Form submitted | Customer | Yes |
| Final Response Letter | FRL Form submitted | Customer | Yes |
Unwind + Legal - Automated
| Template | Fires When | To |
|---|---|---|
| Dealer ROA | ROA Form submitted | Dealer |
| Lender Unwind Request | ROA Form submitted | Lender |
| Temporary Ban Notification | Entry to Debt Triage | Payouts Team |
| Letter Before Action | Entry to LBA Issued (Day 1) | Dealer |
| Total Ban Notification | Entry to MCOL Filed | Payouts Team |
Timed Chasers (automated by EL based on time in stage)
| Template | Stage | Timing | To |
|---|---|---|---|
| ROA Dealer Chase | Awaiting Funds from Dealer | Daily for 5 days | Dealer |
| Informal Recovery Chase | Informal Recovery | Daily for 6 days | Dealer |
| LBA Warning (Internal) | Informal Recovery | Day 7 | Complaints Mgr + Head Of |
| LBA Chaser | LBA Issued | Days 3, 5, 7, 9, 11, 13 | Dealer |
Tags & Reporting
Without tags, we can only see where a file is right now. With tags, we can look at one file and see its entire journey - every stage it passed through, whether the customer was vulnerable, whether it came from Trustpilot, whether it went through Peri's escalation. Tags are applied automatically on stage entry and never removed.
Vulnerable Customer
Apply manually at any stage when vulnerability is identified. Works across all workflows. Used for FCA reporting and ensuring appropriate treatment.
FOS Complaint
Apply when the Financial Ombudsman Service becomes involved. Interim tag until a dedicated FOS flow is built.
Warranty / Trustpilot
Auto-applied based on Complaint Source selection on the triage form. For reporting on complaint channels and warranty-related volumes.
2nd Complaint
Auto-applied when an app is duplicated via custom action. For logging multiple complaints against the same application. Maya can exclude from primary reporting.
6 Months+ IER Required
Auto-applied when handler selects "Post 6 Month" on SRC Complete. Tracks how many complaints are in the 6-month+ evidence path.
Temp Ban / Total Ban
Applied when a dealer enters Pre-Action (temp) or MCOL Filed (total). Signals to Payouts to suspend or permanently stop payouts.
Cross-Workflow Connections
SQ Complaint → Unwind Flow
When a complaint closes as Resolved Rejection or Unresolved Rejection, a record is created in the Unwind Flow. Because the complaint has already been fully investigated, the unwind skips Investigation & Retention entirely and lands directly in Awaiting Funds > ROA Processing.
Unwind → Legal Escalation
When dealer funds aren't received after the 5-day chase period, or there's an outstanding shortfall, the handler moves the file to Legal Escalation > Debt Triage. Temp ban fires automatically. All data carries across - dealer, amount owed, unwind reference, complaint reference.
Dealer Forwarding → Regulated Complaint
When a dealer forwarding complaint isn't resolved and the customer wants to escalate, the handler moves the record into Regulated Complaint > Acknowledged. The DISP clock starts on the date of the Regulated Complaint Log Form.
Complaint → customer raises issue → SRC attempt → investigation → upheld or not → resolution or rejection
Unwind → rejection triggers unwind (skips retention) → ROA to dealer → 5-day daily chase → reimburse lender
Legal → dealer doesn't pay → temp ban → 7-day informal chase → 14-day LBA cadence → courtesy call → MCOL → total ban → enforcement
Every handoff carries context. Every stage applies a tag. Every entry creates a task. The system chases so handlers don't have to diary it.
Operating Principles
Dealer-First Resolution
Always try to achieve a fast dealer-led fix before formalising a complaint. The SRC window exists for a reason - most vehicle issues can be resolved without a formal complaint if the dealer acts quickly.
Speed & Visibility
Chase daily during triage. Keep the customer copied into dealer communications. Customers tolerate problems - they don't tolerate silence. A progress update email takes 30 seconds and prevents an escalation.
Escalate Only When Needed
Delay, refusal, dispute, or no progress from the dealer are the only triggers for formal complaint ownership. Don't escalate prematurely - it adds time, cost, and complexity.
Forms Drive Everything
Every stage transition should be driven by a form submission. Forms populate custom fields. Custom fields fire automations. Automations send emails, apply tags, create tasks. Skip the form and the whole chain breaks.
Diary Discipline
Where customers don't respond, keep the case moving. Document every decision within DISP timing. "The customer didn't reply" is only a defence if you can show you chased consistently and warned them before closing.
DOW Enforcement
Vehicle must not return to dealer until repair/rejection is agreed. Dealer is liable for IER cost if they dispute. Recovery costs sit with the dealer. This wording is in the dealer emails - use it.
Tags for Reporting
Every stage entry applies a tag. Don't remove tags. If a customer is vulnerable, apply the tag. If it's a warranty complaint, the tag auto-applies. Maya and Kim need these for reporting - don't skip them.
Timed Chasers Do the Work
ROA chase (5 days), informal recovery (7 days), LBA cadence (14 days) - the system sends the emails automatically. Handlers make the manual calls on alternating days during LBA. Don't duplicate what the system is already doing.
carloans365 - Aftersales Training - June 2026