FCA Complaint Handling Procedure

Britannia Financial UK Ltd is the principal firm and Equity Release Scotland is an Appointed Representative of Britannia Financial UK Ltd. We strictly adhere to and follow the Complaints Procedures laid down by the regulator, The Financial Conduct Authority. These companies can be found in the FCA register under the following references: Britannia Financial UK Ltd Ref No. 776344 and Equity Release Scotland Ref No. 923455.

1. Complaint received

A complaint is any expression of dissatisfaction, whether oral or written, about the firm’s provision of a financial service or failure to provide one. Firms should recognise complaints regardless of how they are received.

2. Acknowledge the complaint

• Complaints should be acknowledged promptly.
• The customer should be informed who is dealing with the complaint.
• Firms should explain the complaints process and likely timescales.

3. Investigate fairly

The FCA expects firms to:

• investigate competently, diligently and impartially;
• consider all relevant evidence;
• identify whether the complaint is upheld;
• keep the complainant informed throughout the investigation.

4. Three-business-day resolution

If the complaint is resolved to the customer’s satisfaction by the close of the third business day after receipt, the firm may issue a Summary Resolution Communication rather than a formal final response. This communication must still explain the customer’s right to refer the matter to the Financial Ombudsman Service (FOS) if they remain dissatisfied.

5. Eight-week rule

Where the complaint cannot be resolved within three business days:

• the firm has up to eight weeks to issue a Final Response; or
• If unable to do so, it must send a holding response explaining the delay and informing the complainant of their right to refer the matter to the Financial Ombudsman Service immediately.

6. Final Response

The Final Response should:

• clearly state the firm’s decision;
• explain the reasons for that decision;
• detail any offer of redress or remedial action;
• advise the customer of their right to refer the complaint to the Financial Ombudsman Service if dissatisfied; and
• explain that a referral to the Ombudsman generally must be made within six months of the Final Response.

7. Financial Ombudsman Service (FOS)

If the customer remains dissatisfied, they may refer the complaint to the Financial Ombudsman Service, which will independently investigate the matter and determine what is fair and reasonable in the circumstances.

FCA Expectations of Firms

The FCA expects firms to:

• Maintain effective written complaints procedures.
• Allocate responsibility to appropriately trained staff.
• Treat complainants fairly and consistently.
• Identify and support vulnerable customers.
• Keep comprehensive records of complaints and outcomes.
• Carry out root cause analysis where appropriate to identify systemic issues.
• Report complaints data to the FCA in accordance with DISP reporting requirements.

Consumer Duty Considerations

Since the introduction of the Consumer Duty, firms are also expected to use complaints as an important indicator of customer outcomes. The FCA expects firms not only to resolve individual complaints fairly, but also to identify recurring issues and make improvements to products, services and processes where necessary.
For an FCA-regulated equity release adviser or lender, a well-run complaints process should therefore be:

• Prompt.
• Fair and impartial.
• Well documented.
• Transparent.
• Focused on achieving good customer outcomes.
• Used to drive continuous improvement across the business.