Introduction

As a matter of policy in handling complaints and grievances about our services, Liberty Capital Group, Inc.
("Liberty Capital Group, Inc.") maintains a written complaints procedure and ensures that all clients
are made aware of this procedure both at the point of sale and upon making a complaint.

This procedure extends to oral as well as written complaints, including complaints made through third-party
sites where the complaint is first recorded.

Liberty Capital Group, Inc. is a licensed lender broker under the
California Department of Financial Protection and Innovation.
Specific rules and regulations govern how authorized firms must handle and resolve complaints in respect of
activities with their customers.

We intend to effectively apply our policy and rules in treating customers fairly, and complaints must be dealt
with promptly and fairly.

What Is a Complaint?

A complaint is a recordable and reportable event internally. It is:

Complaints refer to any expression of dissatisfaction, whether oral or written, and whether justified or not,
from or on behalf of an eligible complainant about the firm’s provision of, or failure to provide, a service
and alleges that the complainant has suffered (or may suffer) financial loss, material distress, or material
inconvenience.

Who Can Complain?

A complaint can be made by any customer or potential customer of Liberty Capital Group, Inc.

Customers can complain to Liberty Capital Group, Inc. by:

1. E‑mail
2. Online
3. Letter
4. Phone
5. Verbally to an authorized Liberty Capital Group, Inc. employee (for example, during a visit)

How We View Complaints

Complaints are a source of customer feedback and an opportunity to identify how to improve our performance.

The benefits of effective complaint handling include:

• Ensuring that customers can be confident they are dealing with a company that has the customer central to its
  corporate culture.
• Reassuring customers that their opinion matters.
• Identifying any problems, trends of potential customer detriment, or lack of understanding, and then taking
  action to put things right.
• Rectifying potential problems before they become an issue for other customers or colleagues.
• Achieving higher levels of customer satisfaction and recommendations to other potential customers.
• Encouraging or rebuilding customer loyalty.
• Demonstrating our commitment to continuous improvement.

How We Deal With Complaints

We want to make it easy for customers to complain and to be reasonable towards our customers, seeing their side
and treating them as we would like to be treated. Sometimes we do not get things right; when this happens, we
encourage our customers to tell us about their concern so we can put it right.

We investigate complaints fairly, consistently, and promptly, determine whether we have done something wrong,
and ensure appropriate action and redress are made. We set out our conclusions to complainants in a final
response.

Our purpose is to help our customers achieve their financial and business goals. To do this, our customers must
feel we put them at the heart of everything we do. This is core to our “Customer Centricity” in complaint
handling.

We demonstrate this by driving our behaviors to:

• Treat customers consistently, bearing in mind the individual facts of each complaint and the business model the
  customer belongs to.
• Be clear, simple, and transparent in what we do and say.
• Ensure there are no barriers in place for customers to submit a complaint.
• Put ourselves in the customer’s shoes and treat them as we would wish to be treated.
• Put things right for the customer when they complain and learn from our mistakes.

Recording the Life of Every Complaint

We record all complaints at the earliest opportunity to fully and accurately capture these details:

• Receipt – where and when we received the complaint
• Complaint categorization code – what the complaint is about
• Ownership – who dealt with or is dealing with the complaint
• Progress – updates on current position
• Investigation detail and outcome
• Resolution and follow-up action
• Compensation, refund, and reimbursement payments made
• Customer feedback
• Regulatory requirements
• Root cause
• Details of any referrals to an ombudsman and full records of our correspondence on the complaint, including
  the decision and any post final resolution settlement

We retain all complaint records for a minimum of three (3) years; however, there may be instances where we may
elect to retain them longer.

Resolving Complaints

We aim to resolve all complaints within a reasonable time.

We manage and exceed our customers’ expectations by:

• Showing a positive attitude to complaint resolution
• Agreeing and meeting realistic timescales for updates and resolution
• Providing regular updates on progress
• Using the customer’s preferred method of communication
• Striving to resolve the complaint

Empowering Our Colleagues

We empower our colleagues by giving them appropriate authority to own and resolve complaints at the first point
of contact wherever possible. Our colleagues understand our complaint handling procedures and have the skills to
deal with customers who complain.

• The person investigating or managing the complaint has sufficient competence and independence to take a fair
  and unbiased assessment.
• Our colleagues receive clear guidance on when and how to refer complaints through the escalation procedure.
• Our colleagues ensure that customers are made aware of any rights to take their complaint to an independent
  arbitration service, where applicable.
• We have defined hand-off processes and systems agreed and implemented between our departments to provide a
  seamless service to customers.
• We give customers the benefit of the doubt where it would seem fair to do so.
• We reimburse customers who have suffered a financial detriment as a result of our error fairly and quickly.
• We compensate customers who have suffered trouble or inconvenience fairly and quickly.
• We identify frequent problems involving our systems, processes, products, and policies and implement actions to
  resolve them. Where appropriate, we also ensure action is taken on behalf of customers affected who have not
  complained.

How We Communicate With Complainants

Where we have been unable to resolve a customer’s concern as an expression of dissatisfaction, there are certain
time limits we follow.

Complaints Resolved by Business Day 3

If we resolve a complaint by business day three, we issue a summary resolution communication to the customer by
letter, email, or text.

Complaints are acknowledged promptly, and the customer is kept updated on the progress of their complaint. Our
goal is to resolve any grievances as soon as possible.

If we are unable to do so, a written response via letter or email is sent to the customer explaining why we are
unable to resolve the complaint immediately, providing an indication of timeframe, and advising the customer of
their options for further escalation where applicable.

We contact our customers via their preferred method of communication whenever reasonably possible.

Business Day 1

We aim to resolve concerns immediately and at the first point of contact. If complaints are resolved at first
point of contact, a summary communication is issued by email or letter (whichever is the customer’s preferred
method of communication).

Business Day 3

For any complaints which cannot be resolved immediately, we aim to resolve them by working day three after the
date of receipt. These customers are issued with a summary resolution communication by email or letter on
resolution, whichever is their preferred method of communication.

Business Day 7

If we are unable to resolve the complaint at this stage, we aim to issue a written acknowledgement by
email/letter by close of business of working day six at the latest. This will include our complaints procedure.

We contact the customer by phone to agree a contact strategy with them regarding updates and resolution. If we
are unable to contact them by phone, we will email them or, if no email address is available, we will write to
them by post.

After Business Day 21

Updates to the customer will be at a frequency agreed with them and by their preferred method of communication.
We will advise why we have not been able to resolve their complaint and when we hope to be able to do so.

If we are unable to contact the customer by phone, we will update them at least every 10 working days.

Third-Party Companies

If a complaint occurs at any third-party company (for example, the Better Business Bureau), the complaint
handling policy of that third-party platform will apply and their procedure will be followed. Our policy is to
abide by their policy to resolve any complaints raised through those channels.

Contact Point for Queries or Guidance