Ensuring our voices are heard: Jason Wassell on credit information reform

Published 21 May 2025

Over the past year, I’ve represented the Consumer Credit Trade Association on the Industry Working Group (IWG) tasked with developing proposals for a new Credit Reporting Governance Body (CRGB). It is an important and potentially far-reaching piece of work that could change the way credit data is overseen in the UK—and it’s vital that smaller and specialist lenders are not just consulted but properly considered in how the new regime is shaped.

The FCA’s new five-year strategy and what it might mean for alternative credit

Published 01 May 2025

Earlier in the spring, the FCA launched its new five-year strategy that will run until 2030. The aim is to deepen trust, rebalance risk, support growth and improve lives. The regulator has outlined four main themes for its future areas of work as part of the strategy which can be seen below: Be a smarter regulator – predictable, purposeful and proportionate. The FCA will improve its processes and embrace technology to become more efficient and effective. Support sustained economic growth – by enabling investment, innovation and ensuring the continued competitiveness of the UK’s world-leading financial services. Help consumers – to navigate their financial lives by working with the wider industry to boost trust, product innovation and ensure the right information and support is available for people to take informed financial decisions. Fight financial crime – by focusing on those who seek to do harm. The strategy will go further to disrupt criminals and support firms to be an effective line of defence. We have reviewed the strategy and welcome much of the shift in tone. There is the promise of a move away from over-cautious regulation towards a more proportionate, risk-balanced approach. The FCA acknowledges that regulatory standards – while essential – can also unintentionally stifle innovation and create barriers for new entrants. The new strategy promises a more flexible process and smarter use of data. Despite this rhetoric of risk rebalancing and smarter regulation, just now the burden of compliance remains heavy – especially for smaller firms. This is an area where we would like to see change. Elsewhere, the strategy makes clear that the Consumer Duty isn’t going anywhere. If anything, it will become more deeply embedded in how the FCA assesses conduct. Alternative lenders will need to continue evidencing that their products offer fair value, that communications support consumer understanding, and that they’re identifying and supporting vulnerable customers appropriately. Of course we have questions that we will pick up with the FCA in future meetings. Some of this may be a cultural challenge for the FCA. For example, many decisions and interpretations rest with various FCA teams, especially in the world of principles and outcomes. How do you ensure that this change reaches the frontline discussions between firms and the FCA? How will the FCA incorporate access to financial services as a measurable outcome of the strategy, particularly for underserved markets? We must not lose focus of the need to improve access to credit. What metrics will the FCA use to assess whether competition and investment have improved across different segments of financial services? We can focus on the big numbers, but we know that small markets help underserved groups. How do we track success or failure in these different segments? At the CCTA, we will continue to be a strong voice for smaller lenders – advocating for proportionate, practical regulation that allows responsible firms to thrive and serve consumers well. We will all need to work together to ensure the regulator delivers on the aims of its new strategy.  

HM Treasury publishes action plan on regulation – aims to support growth

Published 18 March 2025

Yesterday, the Chancellor met top regulator bosses in Downing Street to discuss an action plan on regulation. The review aims to cut the administrative cost of regulation, make Britain the best place to do business and drive economic growth. We applaud the ambition and the speed at which the Government has been moving. Action plan on regulation The plan aims to overhaul the regulatory system so that it: supports growth. Provide a regulatory system that not only protects consumers and supports competition, but also encourages new investment, innovation, and growth. is targeted and proportionate. The government should regulate only where necessary and allow space for discretion and good behaviour. is transparent and predictable. To foster the certainty essential for investment, it is vital that the regulatory regime is stable, predictable and consistent. adapts to keep pace with innovation. Our approach to regulation must allow the UK to take advantage of new technologies and innovations. We welcome these aims. Recently, we wrote about the importance of the smaller non-bank lenders we represent. A big part of their challenge is regulatory. We have long discussed the need to reduce the regulatory burden on firms, but we are increasingly also discussing the importance of certainty. Yes, as the Government has identified, compliance costs have increased considerably over recent years. We have long said that regulators’ cost-benefit work can be disappointing. It can lack an understanding of actual costs and seem to be built with banks in mind. Late last year, we wrote in the media about new proposals from the Financial Conduct Authority to ask lenders to provide detailed information about every transaction they carry out. This follows a vast amount of work to implement the Consumer Duty. The burden is real and pressing. Certainty is just as important as the burden. However, certainty is equally vital. It is key to have confidence that you understand the regulator’s expectations. It allows you to grow and develop without second-guessing everything you do. Let’s be very clear. This is not about deregulation. In many areas, certainty is about providing more direction, not less. It has essential knock-on impacts. Certainty gives firms confidence that they are compliant, but it is also vital in attracting the investment they need for growth. Certainty also ensures access to credit for individuals who struggle to borrow elsewhere, as firms can continue to offer services to these consumers rather than stepping back out of fear. The action plan also includes some specific measures for financial services. The Treasury will also explore ways to streamline financial services regulators’ ‘have regards’ to improve predictability and business confidence. Regulators will now also be subject to performance reviews twice a year. They will be judged against a set of targets agreed with the businesses they affect, such as how quickly they decide on planning applications and new licenses for companies and products. It would be good to see the FCA supporting new entrants into the alternative credit sector. Examining the role of the Financial Ombudsman …

Call for Input on mass redress – an opportunity for change

Published 06 February 2025

Last week we submitted our response to the Call for Input on modernising the redress system. We took this as an opportunity to raise a couple of wider key topics that we were keen to include around the complaints process. One of these is dialogue with the industry around complaints, to improve outcomes for all concerned – firms, the Ombudsman, and ultimately, the consumer. While we believe there are some tangible changes that can be made to the process (which we raise within our submission) there is a need for a more significant change within the FOS, and how it interacts with the industry and other stakeholders. We believe that the FOS can significantly improve the current framework for managing matters with wider implications by developing a new culture, fostering greater transparency, collaboration, and efficiency. The Wider Implications Framework’s (WIF) role could be enhanced to better manage systemic issues and prevent escalation. Early identification of risks through the WIF would also reduce the likelihood of costly mass redress events and encourage proactive handling of systemic issues to deliver consistent and timely redress for consumers. So, we are calling for regular feedback loops and consultation mechanisms to be established to identify emerging trends collaboratively. This could include real-time communication channels and the establishment of stakeholder forums. Through this firms, consumer representatives and trade bodies could directly engage with the regulators. This would strengthen relationships between regulators, industry, and consumer groups. It would provide valuable insights to inform regulatory actions. There is an opportunity to enhance transparency, involving those outside the regulatory family also. Another area we have identified is the issue of time limits and the ambiguity that surrounds them. We strongly believe the FCA and FOS should review the current time limits for referring complaints to provide greater certainty for firms while maintaining fair consumer protections. The current rules—particularly the “three-year from the date of knowledge” provision introduce significant ambiguity, leaving firms vulnerable to open-ended liability and increasing the risk of inconsistent outcomes. To address this, we propose a few changes. We recommend introducing an absolute longstop from the event date, giving rise to the complaint. This would provide firms with a clear liability endpoint, while ensuring consumers have ample time to bring complaints. The “date you knew” rule should also be clarified. The three-year rule is subjective and inconsistently applied. We have seen the FOS place an unreasonable burden on firms to prove when consumers become aware of their right to complain. There should be a clear burden of proof that balances fairness between firms and consumers, ensuring firms are not unfairly burdened. We believe that this will help market integrity and competitiveness. In creating a predictable regulatory environment, it would encourage investment and innovation that has been so hard to achieve in alternative lending given their recent experience of the complaints system. These are two examples of areas that could be improved both to better handle mass redress events but also the wider complaints framework so it functions …

The importance of smaller lenders

Published 23 January 2025

The news that Santander may leave the UK market has grabbed the headlines. There has been, and we are sure there will continue to be, a lot of discussion about the regulatory burden. The costs mentioned are significant, often more like telephone numbers. The risk is that we focus on those big numbers and the big brands. However, elsewhere, some lenders face burdens that are certainly smaller numbers but can significantly impact that firm. Last year, firms moved to implement the Consumer Duty, introducing new systems and structures. Over recent months, we have seen movement on new data systems required by the FCA. There are plans for a new governance body for credit information funded primarily by lenders. All of this adds up and makes it more challenging to operate. We would suggest that smaller independent lenders frequently provide agility, innovation, and customisation to meet the needs of UK families. We mustn’t lose sight of their health. Filling the gaps Filling that gap has always been an idea that is close to the CCTA. We were formed in 1891 by a small group of retailers and lenders that saw the need for new regulated credit products. Smaller lenders have always looked for the gaps as the banks focus on smoothing their processes. Many large banks focus on high-volume, standardised lending products, prioritising economies of scale. Unfortunately, this approach often leaves certain groups with non-standard credit histories or special borrowing requirements without access to financial support. Doing so, they help ensure financial inclusion, enabling consumers and small businesses to access credit that might otherwise be unavailable. This is particularly important in the consumer credit sector, where access to affordable lending can make a critical difference in people’s lives. Driving innovation and competition Smaller lenders are often at the forefront of innovation in financial services. Unencumbered by the bureaucratic layers that can stifle creativity in larger institutions, they are more nimble in adapting to emerging technologies and market trends. Many have pioneered advancements in digital lending platforms, open banking, and data-driven credit assessments, setting new standards for efficiency and customer experience. Moreover, smaller lenders foster competition within the financial services industry. Their presence challenges the dominance of larger players, encouraging a broader range of products and services at more competitive rates. This dynamic benefits consumers, ensuring they can access choices that better suit their needs. Supporting local economies The impact of smaller lenders extends beyond their immediate customers to the communities they serve. Unlike global banking giants, many smaller lenders have strong ties to their local areas, which enables them to understand and respond to the unique challenges and opportunities within those communities. Smaller lenders often take the time to build relationships and trust within their communities, creating a ripple effect of economic resilience and opportunity. That includes CDFIs and credit unions, alongside commercial branch-based lenders. This localised approach is particularly evident in areas where access to finance is limited due to geographic or socioeconomic factors. We have seen the loss of …

An update on motor finance

Published 19 December 2024

As many of you will know, the motor finance world was hit hard in October with the Court of Appeal judgment in the Johnson v FirstRand Bank Limited, Wrench v FirstRand Bank Limited and Hopcraft v Close Brothers cases. The Court of Appeal decided it was unlawful for motor finance brokers to receive a commission from the lender providing motor finance without getting the customer’s informed consent to the payment. This decision surprised many because this case marks a significant shift in how Courts view lenders’ duties toward consumers in cases involving commission payments. Firms were tasked with making changes to their processes very quickly. This decision came on the back of what has already been a very busy year for motor finance providers. In January this year, the FCA launched a review of historical motor finance Discretionary Commission Arrangements (DCAs). The review seeks to understand if there was widespread misconduct related to DCAs before the 2021 ban, if consumers have lost out and, if so, the best way to make sure appropriate compensation is paid in an orderly, consistent and efficient way. Alongside the review, motor finance firms were given more time to provide final responses to complaints about motor finance where a DCA was involved, and consumers more time to refer their complaints to the FOS. This was to prevent inconsistent and inefficient outcomes for consumers and knock-on effects on firms and the market while the FCA reviewed the issue and determined the best way forward. In September, the FCA further extended this until 4 December 2025. Before deciding its next steps, the FCA wanted to take account of relevant court decisions. These included the judicial review by Barclays Partner Finance of a Financial Ombudsman decision relating to a DCA in a motor finance agreement and the recent Court of Appeal judgment mentioned above. Last week we got the news that the Supreme Court will hear an appeal against the Court of Appeal’s judgment. This will likely take place between January and mid-April next year. While the Supreme Court will hear an appeal, firms must still comply with the law as it stands when arranging new motor finance agreements. There was further movement today when the FCA confirmed that it will extend the time firms have to respond to complaints about motor finance agreements, not involving a DCA. Firms now have until after 4 December 2025 to provide a final response to non-DCAs, in line with the extension already provided for complaints involving DCAs. The regulator has also provided guidance for firms when communicating with affected customers. If you are reviewing your approach, we suggest this as an essential checklist of issues. So, it has undoubtedly been a tumultuous year for the sector. Firms should be focusing on ensuring that they are communicating with customers in the right way, whilst also preparing for the continuation of the FCA’s review. The FCA plans to set out next steps in May 2025, but this will be somewhat dependent on the progress of the appeal to the Supreme Court and the …

Movement on access to credit

Published 08 November 2024

Access to credit has always been central to the work of the CCTA since it was founded over 130 years ago. We have a long-standing project to protect access to responsible credit for customers that often struggle to borrow elsewhere. In recent months, we have seen a greater interest in access to credit and financial inclusion from a range of external stakeholders which as been encouraging. Firstly, we have seen this from the new Labour Government. Prior to the announcement of the General Election, the Labour Party outlined its commitment to a National Financial Inclusion Strategy, should it gain power. This was reinforced by Tulip Siddiq MP, the Economic Secretary, at the party conference which took place in September. The Secretary said that the strategy will be designed and implemented by a committee chaired by a treasury minister with representation across government, regulators, and industry. Through writing to the Secretary, and in our regular discussions with HM Treasury officials, we have expressed our desire to play a role in the process. We believe the experience our members have of lending to those currently will be vital to the development of the strategy. Over the last few years, we have tried to draw attention to the significant reduction in the supply of regulated credit for those consumers who cannot access the prime credit market. Well-regulated alternative credit can play a role in meeting unmet demand within the wider consumer credit market. Though we support Credit Unions and CDFIs—indeed, they form part of the CCTA membership—these organisations alone cannot fill the gap that has been left. We believe a blend of commercial and not-for-profit providers is needed to solve the current problems and address the use of loan sharks. This is the message we have been trying to convey in recent meetings. Our conference also was an opportunity to hear from other stakeholders about their work in this area. Fair4all Finance talked about their desire to work with the private sector on new products, referencing the c.2 billion of estimated current unmet, but potentially commercially viable, credit quoted recently by L.E.K. Consulting. Discussions continue with members of the CCTA about potential partnerships. We were also lucky enough to have Chris Pond, Chair of the Financial Inclusion Commission speak. Unsurprisingly, they are supportive of the new Strategy promised by the Government. The Commission has released new research carried out by the Centre on Household Assets and Savings Management (CHASM) at Birmingham University, which highlights the harms financial exclusion continues to cause in communities across the UK. This is a problem that needs to be addressed. We have also seen the regulator take a greater interest in access to credit in recent times. The FCA has been keen to engage with the sector on the issue and we have taken the opportunity to raise the role the industry can play in improving access to credit, as part of wider discussions on growth and innovation. Financial exclusion is costly to the country. The credit products offered by …

CCTA Annual Conference 2024

Published 10 October 2024

Last week we held our annual conference at the Radisson Blu, Manchester airport. In keeping with recent tradition, we held our member dinner the night before the conference. Our dinner provided the opportunity for attendees to catch up with colleagues from across the sector and discuss relevant issues in a relaxed setting. Conference kicked off the next morning with our Chair, Mark Fiander welcoming delegates to this year’s event. Jason Wassell, CEO, then provided an update on the work of the association and covered some of the topics that would be discussed during the day. We also got a presentation on our learning and development portal, CCTA Academy, from Naveed Asif. Walker Morris presented on the current regulatory structure and questioned where ultimate authority might lie. A thought-provoking session. We were then joined by a knowledgeable range of panellists for our session on access to credit. Fair4all Finance talked about their recent research in this area, while the FCA said there is a place for high-cost credit within responsible lending. Chris Pond from the Financial Inclusion Commission talked about their campaign for the FCA to have regard for financial inclusion. It was widely agreed that the commercial sector has a role to play in ensuring access. That session was followed by Robert McKechnie of Equifax UK delivering a keynote presentation on what the CRA sector is currently seeing in consumer credit. CCTA members are always interested to see trends and insights from the wider sector. Our last panel sessions of the day focused on the regulatory environment and the alternative lending customer. The regulatory panel talked about the implementation of the Consumer Duty, the current review of the motor finance market, and further changes expected in 2025. The consumer panel looked at the demographics of borrowers and why they need the products offered by CCTA members. Assessing vulnerability and how to help those struggling was also discussed. The last session of the day kicked off with a keynote speech from Square 4 Partners on how to take on complacency within firms. The presentation looked at areas businesses should be reviewing often to ensure continuous improvement- especially with the Consumer Duty framework now in place. For our final keynote speech, we heard from Alex MacDonald of the Financial Ombudsman Service. It is always important for industry to engage with the Ombudsman, so it was great to them as part of the agenda once again. Alex shared some updated from the Ombudsman before questions from the audience. It was once again a packed agenda with lots of topics up for discussion. We would like to thank all our speakers and panellists, along with our sponsors for supporting the event. Thanks also to those that were able to attend on the day. We are already thinking about how the discussions play into the work of the association in the coming months. As always, if there is something you want to discuss contact the team.  

FCA keeps a firm grip on the oversight of Appointed Representatives

Published 12 September 2024

Last week the FCA published the findings of its review of how principal firms are meeting its enhanced appointed representative rules, introduced in December 2022. As a reminder, an appointed representative (AR) is a firm that undertakes regulated activities and acts as an agent for a firm directly authorised by the FCA. This firm is known as the appointed representative’s “principal” firm. The FCA’s review involved a telephone survey with 251 principals and in-depth assessments of documentation from 23 firms and they are keen to share their findings. The current rules state that principal firms must oversee their ARs effectively and are responsible for making sure their ARs comply with our rules in relation to their activities as ARs. The FCA feels that while some principals do this effectively, not all firms adequately oversee the activities of their ARs. The changes made to the rules were designed to ensure that principals manage their ARs better. Following the introduction of the new rules and enhanced expectations for principal firms, the FCA has tested the implementation of how firms are embedding the new rules. The regulator reported examples of good practice from principals which included keeping clear documentation to show compliance with the FCA’s enhanced rules and using a broad range of checks and information to oversee and monitor ARs’ activities. But at same time the FCA found some firms were just taking a tick-box approach to complying with its rules, relying on basic information like website checks, or using self-declarations from their ARs, to demonstrate effective oversight. The review also found: 1 in 5 principals had not carried out a required self-assessment or annual review of their ARs. Approximately half of principals were not regularly reviewing their AR agreements. A third of principals were not using data or management information to keep tabs on whether ARs were acting within the scope of AR agreements. Most firms had not changed their AR onboarding or termination procedures since the rules were introduced. Unsurprisingly, the Consumer Duty was also mentioned as part of the review. The FCA thought it good where they saw firms embedding Consumer Duty into their review of ARs. Examples included considering fair value assessments and training for staff on Consumer Duty. The FCA has reminded firms who have ARs or intend to have ARs in future that they should read and consider the findings when assessing their obligations as principals under the rules. Principals should ensure they have assessed their existing processes in response to the new rules and have sufficiently documented any revisions that they can call on if required. The regulator will not hesitate to take swift action where they see principals are not meeting standards in the future. Like much of the regulatory regime, this is a continuous process.  FCA will monitor compliance with the rules, with a particular focus on annual reviews, self-assessments, and the quality of oversight of ARs. These are the key areas that principles should be focusing on moving forward.    

Reducing the burden

Published 08 August 2024

The end of July saw the first anniversary of the implementation of the FCA’s Consumer Duty. This meant vast amounts of work undertaken by regulated firms to prepare, looking to embed the Duty in every stage of the customer journey.  We have supported CCTA members through this process, but it is no means finished, as we know this will be a continual process, especially as requirements for closed products and the Annual Board Report have now come into force too. There is no doubt that the introduction of the Duty has meant extra regulatory requirements which come at a cost. These additional costs can particularly hit small firms, and we know there is more to come with the introduction of the new Product Sales Data requirements next year, for example. For this reason, it was good to see the FCA launch a call for input last week, focused on looking to simplify its retail conduct rules and guidance. The regulator is particularly keen to address potential areas of complexity, duplication, confusion, or over-prescription, which create regulatory costs with limited or no consumer benefit. They have also said that they want to include appropriate flexibility in the rules to be responsive to future changes and innovation. The FCA wants to hear from firms on issues including: which detailed rules or guidance could be simplified to rely on high-level rules, or have interactions with other rules which could be clarified the appropriate balance between high-level and more detailed rules the potential benefits and costs from simplifying rules The FCA has said that it has already committed to a post-implementation review of the Consumer Duty, so they are not seeking responses with suggestions for changes to the Duty within this project. The CCTA will be taking part in this process. We are interested in hearing from members if you have any recommendations. Are there particular areas you can identify that need to be clarified or are no longer required? This is your opportunity to raise these points. Staying with reducing the regulatory burden, the FCA has also recently confirmed the creation of an independent Cost Benefit Analysis (CBA) Panel to add to the other statutory panels that work with the regulator. The panel has been tasked with assessing the proportionality of proposed policy changes that the FCA would like to introduce. It will provide advice to the regulator on preparing and improving CBAs. The Panel began reviewing the CBAs of proposed new policies on 1st August. It will review them in advance of publication, allowing the regulators to consider its recommendations. We hope the creation of the Panel will mean that the impact of potential policy changes on firms will be fully considered, especially from the point of view of regulatory burden and cost to firms. It is good to see the regulator taking these steps to consider the future regulatory requirements. The FCA is after all, tasked with delivering competitive markets that work well for consumers. We need to ensure that the correct …

Consumer Duty – one year on

Published 01 August 2024

It has now been one year since the Consumer Duty came into force for new and existing financial products and services. We are sure that firms will agree; it has been quite a journey so far! The implementation of the Duty has been a somewhat phased approach. The financial services industry had deadlines in relation to approved implementation plans and information exchange requirements. We are now at the stage of the final, hard deadline set for firms under the Duty, that deadline being Annual Board Reports and closed products and services. Over the last year, firms have been living and breathing the Consumer Duty. The 31st July 2024 deadline now requires firms to have produced board-level reporting, covering their focus on good consumer outcomes as well as governance, culture and conduct. The deadline also brings into the scope of the duty, closed products and services. The CCTA has issued guidance to members throughout their implementation journey. For board reports and closed products, we issued our latest guidance paper. Members can access his via the Member Hub. The guidance paper provides useful information and advice around the content of your annual board reports. It covers aspects such as the type of data and information expected in board reports, what level of data would be appropriate, as well as proportionality and the layout and format. We have always said that this is a journey, rather than a destination. Firms should be aware that the final deadline by no means signals the end of your focus on the Consumer Duty. Firms should continue to monitor the outcomes that retail customers receive and work not only to address any harm or detriment but look to improve on those outcomes throughout their business operations. We remind firms to ensure that they have a particular focus on vulnerable customers to ensure that such customers are receiving, at least, as good outcomes as the wider target market. The CCTA will continue to support and guide its members going forward. Look out for further communications as our dialogue with the FCA develops. No doubt the regulator’s focus will move from implementation and embedding of the Duty to reviews and insights into industry-wide compliance with the requirements of the Duty. In addition, firms should continue to monitor the FCA’s Consumer Duty webpage for firms, which is regularly updated and can provide useful insights into the regulator’s expectations. This will also include information around their latest event ‘Consumer Duty- 1 year on’, held on 31st July 2024. A recording of the webinar is now available. The event focused on the impact in this first year, examples of good practice, areas for improvement, and FCA priorities for the year ahead. We will continue to engage with the regulator with the regulator as their insights on the Duty develop and it will continue to be a topic of discussion at many events, including our annual conference in October. As ever, the CCTA Advice Line Service is available for any member seeking support …

What’s happening in the motor finance market?

Published 26 July 2024

After a mortgage, the purchase of a vehicle is often the second largest expense within a household, which is why a range of motor finance options have developed over the years to assist families in making this purchase. The CCTA membership includes motor finance firms of different sizes with various specialisms across the sector. With motor finance being such a large financial services sector, the Financial Conduct Authority (FCA) has carried out various pieces of work into the sector over the years. In 2021, the FCA banned what are referred to as discretionary commission arrangements (DCAs). This removed the incentive for brokers to increase the interest rate that a customer pays for their motor finance. Moving forward to January this year, the FCA announced that they would be carrying out further work on the issue of DCAs. They confirmed that there had been a high number of complaints from customers (some driven by claims management companies) to motor finance firms claiming compensation for commission arrangements prior to the introduction of the ban. The FCA believed that some firms were unfairly rejecting such complaints from consumers based on the applicable legal and/or regulatory requirements at the time of the transaction. This was also reflected in two Financial Ombudsman Service (FOS) decisions where the complaints had initially been rejected by firms but were overturned by the FOS upon investigation. Recognising the potential large-scale impact of these developments, the FCA announced the following: Use of the powers under s166 of the Financial Services and Markets Act (FSMA) to appoint a skilled person to review historical sales of motor finance agreements involving DCAs. A temporary pause in the 8-week limit within which firms are required to provide a final response to complaints. Extending the time limit for complainants to refer complaints about DCAs to the FOS after a final response. As part of the skilled persons review many motor finance firms from across the sector were contacted and asked to share information with the regulator. This included asking firms for full, clear and transparent information in respect of their past DCAs which had to be supplied at pace. Through this the FCA hopes to gain a thorough understanding of the different types of commission models within different businesses. The regulator is now analysing the information it has received. If it finds widespread misconduct it will act accordingly. While the FCA carries out its investigation, there are also lots of relevant cases going through the courts which may have an impact on the FCA’s action. This includes a judicial review of the FOS, launched by Barclays which we understand the FOS will challenge. The FCA plans to communicate a decision on next steps by the end of September but these court cases on likely to have an impact on proceedings which could see the FCA having to extend its review. The CCTA regularly holds roundtable sessions for our motor finance members which cover issues such as the above. If you are interested in attending or …