The FCA’s review identified widespread failings in the disclosure of discretionary commission arrangements (DCAs), excessive commissions, and restrictive contractual practices - all of which created poor outcomes for consumers.
This consultation creates immediate operational, financial, and reputational challenges for lenders. Delta Capita can help firms interpret the requirements, implement the necessary changes, and manage long‑term risk.
Our Recommendations for Lenders
Lenders should prioritise the following:
- Regulatory Readiness
- Assess the FCA’s proposals against your business model.
- Map exposure across historic motor finance agreements.
- Build a compliance roadmap aligned to FCA expectations.
- Risk & Liability Assessment
- Quantify potential redress liabilities under different scenarios.
- Identify agreements most at risk (DCAs, high commissions, exclusivity clauses).
- Stress‑test financial resilience against possible compensation models.
- Operational Implementation
- Design and execute consumer contact strategies.
- Establish broker engagement processes.
- Put in place robust case review and evidence‑handling frameworks.
- Integrate redress processes with existing complaints and remediation functions.
- Strategic Advisory
- Manage reputational risk and stakeholder communications.
- Benchmark against peers to understand market positioning.
- Use proactive remediation to rebuild consumer trust.
How Delta Capita Can Help
We propose a three‑phase engagement model: Phase, Focus, Deliverables
1. Diagnostic
Exposure & risk mapping
Portfolio analysis, liability modelling, compliance gap report
2. Design
Scheme readiness
Redress framework, redress calculator build, consumer contact strategy, operational playbook
3. Delivery
Execution & monitoring
Implementation support, MI dashboards, FCA engagement pack
Why Work With Us
- Regulatory Expertise: Deep knowledge of FCA enforcement and redress schemes.
- Data Analytics: Tools to identify high‑risk agreements and model liabilities.
- Proven Experience: Delivery of large‑scale remediation programmes (PPI, IRHP).
- Reputation Management: Support on communication with regulators, investors, and customers.
Next Steps
We recommend an initial scoping workshop within the next two weeks to:
- Review your motor finance portfolio exposure.
- Prioritise immediate compliance actions.
- Define the scope and scale of our engagement.
Conclusion
The FCA’s consultation marks a decisive moment for the motor finance sector. Lenders who move quickly will be better placed to manage risk, satisfy regulatory expectations, and protect their reputation.
Delta Capita is ready to support you in delivering a structured, compliant, and practical response.
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