We know that large-scale redress exercises can create conditions where volume becomes more commercially important than quality. Where that happens, incentives can point in the wrong direction.

The result can be aggressive marketing, speculative claims, duplicated complaints, weak consumer understanding and increased pressure on firms, the Financial Ombudsman Service and the wider complaints system.

This matters for consumers as well as firms. Consumers may be encouraged to pursue claims they do not fully understand, enter into agreements without appreciating the implications, or lose part of any redress to fees when direct routes are available.

For firms, particularly smaller lenders, high volumes of weak or duplicated claims can divert resources away from resolving genuine customer harm. They can increase operational pressure, slow response times and make it harder to focus on fair, evidence-based outcomes.

That is why the FCA’s wider focus is welcome. This review should not be only about individual bad actors, important though poor conduct is. It should also examine the economic and regulatory dynamics that shape behaviour across the market.

That includes advertising, lead generation, fee models, consumer understanding and the interaction between redress schemes, complaints handling and ombudsman processes.

The challenge is to improve the complaints ecosystem without restricting legitimate access to support. Some consumers will continue to need help, and some claims management firms and professional representatives provide that help responsibly.

The objective should be a market that supports informed choice, fair value and genuine consumer benefit.

From the CCTA’s perspective, this is an opportunity for a more thoughtful conversation about how to:

• maintain access to justice for consumers
• reduce nuisance, speculative and duplicated claims activity
• improve consumer understanding
• ensure fees and incentives align with consumer interests
• protect the capacity of firms, FOS and regulators to focus on genuine harm

The CCTA will engage constructively with the FCA and wider stakeholders as this work develops.

A well-functioning complaints market should support consumers, not confuse them. It should help identify and resolve genuine harm, not create unnecessary friction. Above all, it should strengthen confidence in redress, rather than undermine it.