As CEO of Auxillias and through my wider work across the consumer credit and motor finance sectors I spend a lot of time working with firms on conduct risk, Consumer Duty, redress and governance. This new guide is worth attention because it gives a much clearer picture of what the FCA now expects from brokers – and in one area, marks a very important change.

This comes in section one where the FCA expressly states that credit brokers are not just distributors of a lender’s product but manufacturers of their own broking service.

For many brokers, this will feel like a change in status even if technically it sits within the existing Consumer Duty framework. Historically, many brokers have seen themselves mainly as introducers – matching customers with lenders and relying heavily on lender governance, lender value assessments and lender controls.

The FCA is now making clear that this is no longer enough. If you are a broker, you are expected to look at the service you provide as a product in its own right. That means considering fair value, target market design, customer understanding and whether your fees, commissions and processes deliver good outcomes. This could be a significant adjustment for parts of the market.

The guide includes examples of brokers carrying out fair value assessments on their own broking fees, reviewing whether commission structures could affect impartiality and even removing lenders from their panel where the product itself could not be shown to provide fair value. That moves brokers much further into the Consumer Duty conversation than some may have expected.

1. Financial promotions remain a live issue

The FCA repeats that promotions must be clear, fair and not misleading across all channels including websites and social media. This comes at the same time as the FCA continues its wider CONC 3 review so firms should treat this as part of a broader push on customer communications and digital journeys.

2. Customer interactions are another key focus

Brokers are reminded to properly consider customer needs, affordability and foreseeable harm while making sure fees and commissions are clearly disclosed where relevant.

3. Complaints handling is high on the agenda

The guide makes it clear that firms should not treat complaints as a back-office process. Complaint trends should be used to identify recurring issues and improve customer outcomes.

4. Governance runs throughout the document

The FCA is keen to stress that smaller firms do not need large compliance teams but they do need clear accountability, proper oversight and good record keeping. That applies just as much to appointed representative (AR) oversight where principal firms remain under close scrutiny.

5. For principal firms, the AR section is important

The FCA continues to focus heavily on whether ARs are being properly monitored, whether they are acting within scope and whether principals can evidence meaningful oversight.

What this guide really does is strip away any suggestion that smaller brokers can rely on being ‘small’ as a reason for lighter standards.

The FCA accepts proportionality but not informality. It wants firms to be able to show who owns compliance, how customer outcomes are being monitored, how risks are escalated and how the Consumer Duty is being applied in practice.

For brokers, lenders and principal firms alike, this guide should be treated as a practical health check. The key focus is whether your business model, your customer journey and your governance can stand up to regulatory challenge.

And if the FCA’s current direction tells us anything, it is that this is only going one way.