Due diligence and contracts now need a Duty lens. Lenders should secure the right to MI, audits and mystery shops, and act when visibility is limited. Brokers, for their part, are manufacturers of the broking service: they must evidence fair value in their own charges, disclose commissions in a way customers actually understand, and share information upstream.

If you use Appointed Representatives, remember the FCA has strengthened principal responsibilities: onboarding and scope control, annual reviews, and real-time oversight. Treat AR governance as part of distribution risk, not a separate compliance ritual.

• Map each product’s target market and distribution, then monitor high-risk segments and channels. Build a contractual MI pack (acceptance rates, APR ranges, fees, complaints, arrears, forbearance usage) by broker and act on what it shows.
• Govern commissions and incentives. You should pre-approve models, test cumulative value (including broker add-ons), and link pay to sustained affordability and customer understanding, not just originations.
• Assure delivery, not just design. Run file reviews and mystery shopping focused on explanations and vulnerability handling; sample affordability assessments for data sufficiency; set outcome triggers (complaints, early arrears, “worse-off” cohorts) that force interim review and remediation. Report it to the board, not just the compliance committee.

The regulator’s scrutiny of motor-finance complaints and the in-flight redress scheme shows the direction of travel: you will be judged by your outcomes and how quickly you fix them. The smartest firms are acting like one chain, co-designing communications, sharing MI, and aligning incentives to customer success.

If you’re re-cutting broker oversight, fair-value workbooks or AR governance, it is vital that you implement controls that stand up to board and FCA challenge. For example, broker MI heat-maps (acceptance, APR dispersion, early-arrears), pre-approved commission models with outcome back-testing, and a fair-value workbook that captures total economic cost including part-exchange effects. Take the opportunity to build something robust for today and resilient for what comes next.

If you’re refreshing broker oversight, fair-value workbooks, affordability controls or AR governance, take care to build practical controls that stand up to board, and FCA challenge, such as open-banking challenge playbooks with documented sustainability tests, automatic outcome triggers that force interim reviews, and risk-based AR oversight with MI rights, mystery shops and annual onsite reviews, backed by an audit-ready evidence library you can trust.