CarLoans 365 — Complaints Training

Section 1

How Complaints Enter the System

Every complaint, cancellation, and service issue enters through one form. The Customer Issue Form sits on the Account Paid and Vehicle Collected stages. The customer service agent fills it in during the call. Based on their answers, the system routes the record to the correct workflow automatically. No manual moves. No Microsoft Forms. No Power Automate.

Core Rule

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

Account Paid + Vehicle Collected stages · Click to see how routing works

1. What is the customer's PRIMARY issue regarding?*

Vehicle issues always take priority if multiple concerns exist.

The Vehicle

The Dealership's Service

CarLoans365's Service

↳ Vehicle selected

3. Has the customer collected the vehicle?*

Yes

No

↳ Vehicle Complaint — Triage Fields

Initial SQ Complaint Summary *

Collection Date

Date of Complaint *

Faulty System

Vehicle Status *

→ SQ Complaint Flow > SRC - Early Resolution > Triage Complaint

↳ Not Collected — Cancellation

Cancellation Reason *

Customer Re-deal?

→ Unwind Flow > Investigation & Retention > Triage Unwind

↳ Dealership Service Issue

Forwarding Category *

Complaint Source *

Customer Issue Summary *

→ Service Complaints > Dealer Forwarding > Forwarded to Dealer

↳ CarLoans365 Service — Regulated Complaint

Complaint Category *

Complaint Source *

Complaint Summary *

→ Service Complaints > Regulated Complaint > Acknowledged

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.

Secondary Concerns

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.

Section 2

SQ Complaint Flow

Vehicle quality complaints. Every complaint starts in SRC — no exceptions. The dealer gets first chance to resolve. If they can't or won't, it escalates to formal investigation. Every form submission drives the next step automatically.

SRC - Early Resolution

Triage Complaint

Form Email

Awaiting Dealer Response

Email

Investigation

Awaiting Evidence

Email

Under Assessment

Form

Upheld - Pending Resolution

Awaiting Dealer Response

Form

Resolution Arranged

Form

Dealership Dispute

Form

Independent Report

Form

Complaint Closed

SRC Resolved Repair

Terminal

SRC Resolved Rejection

Terminal

Resolved Repair

Terminal

Resolved Rejection

Terminal → Unwind

Unresolved Rejection

Terminal → Unwind + Legal

Not Upheld

Terminal

No Evidence

Terminal

Pipeline 1 — SRC Early Resolution

Triage Complaint

Triage FormAck Letter

▶

Form Fields

Initial SQ Complaint Summary text, mandatory

Collection Date · Date of Complaint text

Mileage at Complaint Inception number

Complaint Source Connex Inbound / Customer Email / Lender Email

Faulty System · Faulty Part text

Vehicle Status Immobile / Safely Mobile / Unsafely Mobile

Vehicle Location Customer / Dealer / Third Party Garage

Customer Desired Outcome · Third Party Garage text

On Submission

Email: Complaint Acknowledgement Letter → customer

Assign: Complaint handler

Moves To

Always → Awaiting Dealer Initial Response

Awaiting Dealer Initial Response

SRC Dealer Notification

▶

On Entry

Email: SRC Initial Dealer Notification → dealer (includes complaint details, DOW clause references, 5-day response window)

Handler Decides

Dealer resolves, customer happy

Handler completes SRC Resolution Arrangement Form → Closed > SRC Resolved Repair or SRC Resolved Rejection

Dealer doesn't respond, disputes, or no resolution

→ Investigation > Awaiting Evidence

Pipeline 2 — Investigation

Awaiting Evidence

Evidence Email + WhatsApp

▶

On Entry

Email: Evidence Request Email → customer

WhatsApp: Short evidence request referencing the email

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. The post-6-month customer help guide is attached. See Section 5 for full details.

Handler Decides

Evidence received

→ Under Assessment

Customer silent after chasing (see No Contact process)

→ Closed > No Evidence

Under Assessment

Assessment Form

▶

Form Fields

Customer Evidence Received · Customer Evidence Summary text

Assessment Outcome Upheld / Not-Upheld

Upheld - Customer Rights 30-Day Reject / Final Reject / Repair (conditional)

Outcome Reasoning text

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.

On Submission

Not Upheld

→ Closed > Not Upheld · Final Response Letter fires

Upheld

→ Upheld > Awaiting Dealer Response · Post-SRC Dealer Notification fires

Pipeline 3 — Upheld - Pending Resolution

Awaiting Dealer Response

Resolution Form

▶

Handler completes Resolution Arrangement Form

Dealership Response Accepts Liability / Disputes Liability

Resolution Type Dealer Repair / Rejection / Third Party Repair (conditional)

Customer consent checkbox mandatory

Routing

Accepts Liability → Resolution Arranged

Disputes Liability → Dealership Dispute

Resolution Arranged

Outcome Form

▶

Resolved by Dealer Resolved / Unresolved

Date Outcome Resolved · Costs to CL365 text / number

Routing

Resolved + Repair

→ Closed > Resolved Repair · Final Response Letter fires

Resolved + Rejection

→ Closed > Resolved Rejection · Final Response fires
⤷ Auto-creates Unwind record → Awaiting Funds > ROA Processing (skips retention)

Unresolved

→ Closed > Unresolved Rejection
⤷ Auto-creates Unwind + Legal records

Dealership Dispute

Dispute Form

▶

Dealership Evidence Received · Dispute Evidence Summary text

Dispute Outcome Not-Upheld / Remains Upheld / Evidence Deadlock

Routing

Not-Upheld (dealer evidence accepted) → Closed > Not Upheld

Remains Upheld → Resolution Arranged · Indemnity reminder fires to dealer

Evidence Deadlock → Independent Report

Independent Report

IR Outcome Form

▶

Independent Report Outcome Customer Liable / Dealer Liable / Inconclusive

Complaint Outcome Upheld / Not Upheld

Routing

Upheld → Resolution Arranged · Dealer notification fires ("independent report found you liable")

Not Upheld → Closed > Not Upheld

Why Custom Forms Matter

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. Records move automatically. Without the forms, none of this works — the system has no data to act on. 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.

Section 3

Service Complaints Flow

Two types of complaint in one workflow. Dealer forwarding complaints are about the dealer's conduct — not vehicle quality. Regulated complaints are about CarLoans365's own service — mis-selling, fees, communication failures. These are FCA-regulated under DISP.

Dealer Forwarding

Forwarded to Dealer

Form Email

Awaiting Dealer Response

Waiting

Regulated Complaint

Acknowledged

Form DISP

Under Investigation

Form

Final Response

Form DISP

FOS Referral

Form

Closed

Dealer Resolved

Terminal

Dealer Unresolved

Terminal

Upheld

Terminal

Partially Upheld

Terminal

Not Upheld

Terminal

FOS Upheld

Terminal

FOS Not Upheld

Terminal

Pipeline 1 — Dealer Forwarding

Forwarded to Dealer

FormDealer Email

▶

Form Fields

Forwarding Category Vehicle not as described / Poor dealer service / Missing items or docs / Dealer communication / Other

Customer Issue Summary text, mandatory

Customer Desired Outcome text

On Submission

Email: Dealer Forwarding Notification → dealer

Moves To

→ Awaiting Dealer Response

Awaiting Dealer Response

Waiting

▶

Handler Decides

Dealer resolves → Closed > Dealer Resolved

Customer wants to escalate → Regulated Complaint > Acknowledged

Dealer doesn't engage, customer accepts → Closed > Dealer Unresolved

Pipeline 2 — Regulated Complaint

Acknowledged

Log FormDISP Ack

▶

Form Fields

Complaint Category Mis-selling / Affordability / Commission Disclosure / Fees / Delays / Communication / Data Protection / Vulnerability Handling / Other

Complaint Summary text, mandatory

Customer Desired Outcome text

Date of Complaint date — 8-week clock starts here

Escalated from Dealer Forwarding? Yes / No

On Submission

Email: Regulated Complaint Acknowledgement Letter → customer (DISP-required: confirms receipt, 8-week timeframe, FOS rights)

Assign: Complaint handler

Moves To

→ Under Investigation

Under Investigation

Detriment Form

▶

The Two Questions

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.

Form Fields

Evidence Reviewed text — call recordings, emails, CRM notes

Process Compliance Process Followed / Not Followed / Partial

Genuine Detriment? Yes / No

Detriment Type Financial Loss / Distress & Inconvenience / Both (conditional)

Detriment Description text (conditional)

CL365 Responsible? Yes / No / Partially

Liability Reasoning text

Moves To

→ Final Response

Final Response

FRL FormDISP FRL

▶

Outcome Upheld / Partially Upheld / Not Upheld

Outcome Reasoning text — populates the FRL

Redress Type Fee Refund / Financial Compensation / Goodwill / Apology Only (conditional)

Redress Amount · D&I Payment · Total Redress numeric (conditional)

Manager Approval Approved / Not Approved (conditional on redress > £250)

On Submission

Email: Final Response Letter → customer (DISP-required: includes findings, redress, FOS rights, 6-month window)

Routing

Upheld → Closed > Upheld

Partially Upheld → Closed > Partially Upheld

Not Upheld → Closed > Not Upheld

FOS Referral

FOS Form

▶

FOS Case Reference text

FOS Decision Upheld / Not Upheld / Partially Upheld

FOS Award Amount numeric

FOS sides with CL365 → Closed > FOS Not Upheld

FOS sides with customer → Closed > FOS Upheld

Section 4

CRA Rights by Vehicle Age

The Consumer Rights Act 2015 gives customers different rights depending on how long they've owned the vehicle. This matrix shapes what evidence to request, what outcomes are reasonable, and how to frame customer expectations. Use it alongside the complaint handling — don't confuse the CRA age bands with the complaint diary timeline.

Within 30 Days

HIGH RISK — REJECTION / UNWIND REVIEW

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

REPAIR / REPLACE

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

REPAIR / REPLACE — WEAR & TEAR FACTOR

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

CUSTOMER EVIDENCE REQUIRED

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. If evidence is not provided, manage via the no contact / no cooperation process.

Two checks at intake: capture Delivery/Sale Date and Fault First Reported Date so EL can calculate vehicle age. Then open the correct complaint diary. These are separate clocks — the CRA age band tells you what rights apply, the DISP diary tells you how long you've got to resolve the complaint.

Section 5

Post-6-Month Evidence Path

When a vehicle complaint is raised more than 6 months after sale or delivery, the evidence request changes. The customer help guide is sent automatically. The handler sets a clear evidence deadline and manages the case through structured follow-ups.

What Changes After 6 Months

The standard evidence request email is replaced with a post-6-month version that explains why more information is needed and what types of evidence are most helpful. The customer help guide is attached — it walks them through getting an independent diagnostic report, what the garage should include, and what happens next. The tone is supportive, not adversarial.

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
Timeline of events	When the problem started and how it progressed

If evidence never arrives: Follow the no contact / no cooperation process. Send reminders, warn that a decision will be made on available information, and keep the complaint within DISP timing. The case can be reopened if evidence is provided later.

Section 6

No Contact / No Cooperation

When a customer stops responding or doesn't provide requested evidence, the complaint still needs to progress. DISP doesn't pause because the customer went quiet. Follow this sequence — it's documented, defensible, and keeps the diary under control.

Step	Action	Template
1	Issue clear evidence request with a reasonable return date	Evidence Request Email (standard or post-6-month)
2	Send reminder after deadline passes. Log all chase attempts.	No Contact / Evidence Reminder
3	Warn the customer that the case may be assessed on available information if nothing is received	No Contact / Evidence Reminder (2nd)
4	If still no response, assess the complaint on what you have and issue the appropriate response	No Contact / Evidence Not Provided Outcome
5	If evidence later arrives, reopen and review	Reopen Confirmation

The key principle: never let the diary drift. Even if the customer has gone silent, the DISP clock is still ticking. Log every chase attempt, every email, every call. If FOS asks why the complaint took 10 weeks, "the customer didn't respond" only works if you can show you chased consistently and warned them before closing.

Section 7

Communications Reference

Every automated and manual communication across both workflows. Automated emails fire on form submission — the handler doesn't draft or send them. Manual templates are available in EL for the handler to use when needed.

SQ Complaint Flow — Automated

Template	Fires When	To	Auto?
Complaint Acknowledgement Letter	Triage Form submitted	Customer	✓
SRC Initial Dealer Notification	Entry to Awaiting Dealer Response	Dealer	✓
SRC Summary Resolution Communication	SRC closure	Customer	✓
Evidence Request Email	Entry to Awaiting Evidence	Customer	✓
Evidence Request WhatsApp	Entry to Awaiting Evidence	Customer	✓
Post-SRC Dealer Notification	Assessment = Upheld	Dealer	✓
Resolution Arrangement Confirmation	Resolution arranged	Customer + Dealer	✓
Dealer Dispute Rejected / Indemnity	Dispute = Remains Upheld	Dealer	✓
Final Response (Not Upheld)	Closure as Not Upheld	Customer	✓
Final Response (Resolved Upheld)	Closure as Resolved	Customer	✓

SQ Complaint Flow — Manual (handler sends from template library)

Template	Used When	To
Customer Progress Update	Keeping customer informed during triage/investigation	Customer
Repair Booked Confirmation	Dealer has scheduled repair/inspection	Customer
Dealer Chase	Following up with dealer for overdue update	Dealer
Post-6-Month Evidence Request	Vehicle > 6 months — different evidence request	Customer
Post-6-Month Customer Help Guide	Attached with evidence request for older vehicles	Customer
No Contact Reminder	Customer not responding to evidence request	Customer
No Contact Final Warning	Last chance before assessing on available info	Customer
No Contact Closure	Closing due to no engagement	Customer
Resolution Offer	Presenting proposed outcome	Customer
Dealer Recharge / Recovery	Recovering costs from dealer post-resolution	Dealer

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 (Upheld)	FRL Form, Upheld/Partial	Customer	Yes
Final Response Letter (Not Upheld)	FRL Form, Not Upheld	Customer	Yes
Holding Letter	Manual — approaching 8 weeks	Customer	Yes

Unwind + Legal — Automated

Template	Fires When	To
Dealer ROA (Complaint / Non-Collection)	ROA Form submitted	Dealer
Lender Unwind Request (Complaint / Non-Collection)	ROA Form submitted	Lender
Letter Before Action	LBA Form submitted at Informal Recovery	Dealer

Section 8

Call Scripts

Key scripts for customer service agents and complaint handlers. Use these as frameworks — adapt to the conversation, don't read them verbatim.

Customer Intake

Taking the initial call from a customer reporting a vehicle issue

"Could you tell me what the issue is with the vehicle and when it first arose? Is the vehicle currently safe to drive?"

"Have you spoken to the supplying dealer about this yet, and what is your desired outcome?"

"Thank you. I'm logging this now. We will contact the dealer today to give them the opportunity to resolve this directly, and we'll keep you updated."

Multiple Concerns

Customer complaining about both the vehicle and the service

"I can hear you've got concerns about both the vehicle and the service you've received. Let me get the vehicle issue sorted first as that's the most pressing. Once that's resolved, if you still have concerns about the service, we'll absolutely address those separately — nothing gets lost."

Dealer First Contact

Calling the dealer to initiate the triage process

"Hello, I'm calling from CarLoans 365 regarding a mutual customer's vehicle. Can you confirm who is handling this case? Could you let me know whether the vehicle can be inspected, what your proposed action is, and the expected timescale?"

Dealer Chase

Dealer is overdue on their response

"Hello, I'm following up on the vehicle issue we previously discussed. We need a specific next step and a firm timescale so we can update the customer today."

Escalation to Formal Complaint

Triage has failed, moving to formal complaint

"As we have attempted a dealer-led resolution and the matter remains unresolved, we are now escalating this to a formal complaint. The complaints team will take full ownership of the investigation."

Post-6-Month Evidence

Explaining why evidence is needed for older vehicles

"Because it has been more than 6 months since your purchase, we require supporting evidence to determine if the fault was developing at the point of sale. Diagnostics, service history, and photos are very helpful. If you don't have them right now, we may close the complaint temporarily, but we can reopen it as soon as the evidence is received."

No Contact / Evidence Reminder

Customer hasn't sent requested evidence

"I'm calling because we still need the information requested to progress your complaint. If you are able to send it by [date], we can continue our review. If we do not receive anything further, we may need to make a decision based on the information currently available."

Resolution Offer

Presenting the outcome

"We've now completed our review and would like to propose the following resolution: [summary]. I'll explain what this means, the next steps, and what we need from you to proceed."

Dealer Forwarding Explanation

Explaining why a complaint is being forwarded to the dealer

"Because your concern is an operational matter that belongs to the dealership, it has been forwarded to the dealer for direct investigation. CarLoans 365 will monitor the progress where appropriate, but the dealer will be responsible for resolving this with you."

Section 9

Cross-Workflow Connections

Complaints don't exist in isolation. When a vehicle complaint ends in rejection, it triggers an unwind. When the dealer doesn't pay, it triggers legal escalation. These handoffs are automatic — the receiving handler gets a pre-populated record with full context.

SQ Complaint → Unwind Flow

When a complaint closes as Resolved Rejection or Unresolved Rejection, a record is automatically created in the Unwind Flow. Because the complaint has already been fully investigated and the customer has been through SRC and retention discussions, the unwind record skips Investigation & Retention entirely and lands directly in Awaiting Funds > ROA Processing.

Unwind → Legal Escalation

When an unwind closes as Unresolved (shortfall, dealer didn't pay), a record is automatically created in the Legal Escalation Flow. The handler starts at Debt Triage with all data carried 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 from Dealer Forwarding > Awaiting Dealer Response into Regulated Complaint > Acknowledged. The Regulated Complaint Log Form captures the complaint details and the DISP clock starts.

The Full Chain

Complaint → customer raises issue → SRC attempt → investigation → upheld or not → resolution or rejection

Unwind → rejection triggers unwind (skips retention) → ROA to dealer → chase funds → reimburse lender

Legal → dealer doesn't pay → informal chase → LBA → courtesy call → MCOL → enforcement

Every handoff is automatic. Every form pre-populates from upstream. The handler never starts from scratch.

Section 10

Operating Principles

Dealer-First Resolution

Always try to achieve a fast dealer-led fix before formalising a complaint. The 3-day triage 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 SQ complaint ownership. Don't escalate prematurely — it adds time, cost, and complexity that could have been avoided.

Forms Drive Everything

Every stage transition should be driven by a form submission. Forms populate custom fields. Custom fields fire automations. Automations send emails and 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.

Commercial Approach

Work toward repair, contribution, or other sensible resolution steps. Where rejection/unwind is accepted, hand off promptly to Retentions. Protect re-deal opportunities. Recover costs from dealers immediately after resolution.

Rights Clarity

Use the CRA rights matrix as a practical guide at the investigation stage. Don't overstate legal rights in customer communications. Escalate complex matters for compliance review.

Migrated Records

Legacy complaints from AutoConvert have "MIGRATED" in the Initial SQ Complaint Summary field. Automated emails won't fire for these records. Handle communications manually until they close out. New complaints from the Customer Issue Form work fully automatically.