www.LibertyCapitalGroup.com Complaints Handling Policy last update: 9/21

As a policy in handling complaints, grievances of our services, we’re stating our written complaints
procedure and that all clients are made aware of this procedure both at the point of sale and upon
making a complaint. The procedure extends to oral, as well as written complaints including third-party
sites where complained is first recorded. Liberty Capital Group, Inc. entities are referred to as “Liberty
Capital Group, Inc.” throughout this document – is a licensed lender broker under https://dfpi.ca.gov/.
Specific rules and regulations for how authorized firms must handle and resolve complaints in respect of
activities from its customers. We intend to effectively apply our policy and rules in treating customers
fairly as complaints must be dealt with promptly and fairly.

What is a complaint?
A complaint is a recordable and reportable event internally. Expression of dissatisfaction – ‘Any oral or
written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the
provision of, or failure to provide, a financial service.’ Complaints then 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 firms’ 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 the Liberty Capital Group, Inc.
Group. Customers can complain to Liberty Capital Group, Inc. by:
1. E-mail;
2. Online;
3. Letter;
4. Phone; or
5. Verbally to an authorized Liberty Capital Group, Inc. employee, for example, during a visit.

How do we view complaints at Liberty Capital Group, Inc.?
Complaints are a source of customer feedback and an opportunity to identify how to improve our

The benefits are:
• Ensuring that customers can be confident that they’re dealing with a company who has the customer
central to its corporate culture.
• Customer reassurance that their opinion matters.
• Identification of any problems, trends of potential customer detriment or lack of understanding and
then take action to put things right;
• Rectifying potential problems before they become an issue for other customers or colleagues.

• Higher levels of customer satisfaction and recommendations to other potential customers.
• Encourages or rebuilds customer loyalty.
• Demonstrates we’re committed to continuous improvement.
• Encourages or rebuilds customer loyalty.

How do we deal with complaints?
We want to make it easy for customers to complain and want to be reasonable towards our customers,
seeing their side and treating them as we would like to be treated. Sometimes we don’t get things right
and when this happens, we want to encourage our customers to tell us about their concern so we can
put it right. We’ll investigate complaints fairly, consistently and promptly, determine whether we’ve
done something wrong and ensure the appropriate action and redress is made. We’ll set out our
conclusions to complainants in a final response.
Our purpose is to help our customers achieve their investment goals. To do this our customers must feel
we put them at the heart of everything we do, to please our customers and exceed their expectations.
This is core to our ‘Customer Centricity’ in our 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.
• being 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, and
• put things right for the customer when they complain and learn from our mistakes.
We achieve this by carrying out the following activity. Record 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 – to tell us what the complaint is about
• Ownership – who dealt or is dealing with the complaint
• Progress – update 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, post final resolution settlement. We retain all complaint records for a minimum
of 3 years however there may be instances where we may elect to retain them longer. Resolve all
complaints first time, every time. 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 customers preferred method of communication, and
– resolving the complaint.
Empowering our colleagues by giving them appropriate authority to own and resolve complaints at 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
• Our colleagues ensure that customers are made aware of any rights to take their complaint to an
independent arbitration service.
• 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 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
• 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 haven’t complained.

How do we communicate with complainants?
Where we’ve been unable to resolve a customer’s concern as an expression of dissatisfaction there are
certain time limits, we must follow. If we resolve a complaint by business day three, we must issue a
summary resolution communication to the customer by letter, email or text.
Complaints must be acknowledged promptly, and the customer should be kept updated on the progress
of their complaint. Our goal is to resolve any grievances as soon as possible. If we’re unable to do so, a
written response via letter or email must be sent to the customer explaining why we’re unable to do so,
provide an idea of timeframe and advise the customer they can now refer their complaint to the
complainant. We’ll contact our customers via their preferred method of communication.

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 immediately a summary communication summary is issued by email or letter
whichever is the customers preferred method of communication.

Business day 3
For any complaints which can’t be resolved immediately we aim to resolve them by working day three
after date of receipt. These customers will be issued with a summary resolution communication by email
or letter on resolution whichever is their preferred method of communication.

Business day 7
If we’re unable to resolve the complaint at this stage, we will aim to issue a written acknowledgement
by email/letter by close of business of working day 6 at the latest. This will include our complaints
procedure. We’ll contact the customer by phone to agree a contact strategy with them regarding
updating them and resolution. If we’re unable to contact them by phone, we’ll email them or if no email
address is available, we’ll 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’ll advise why we’ve not been able to resolve their complaint and when we hope to
be able to do so. If we’re unable to contact the customer by phone, we’ll update them at least every 10
working days.

Third Party Companies:
If complaint occur at any third-party companies i.e., BBB, complaint handling policy is
transferred to the party’s handling complaint and procedure will be followed. Our policy it to
abide by their policy to resolve any complaints.

Contact point for queries or guidance

Please contact the compliance officer at Liberty Capital Group, Inc. Group, using the following
electronic address: customerservice@Liberty Capital Group.com

1011 Camino Del Rio S, San Diego, CA 92108 or 888-588-4128